preparedness and prevention

The Requirements of 40 CFR 262.16(b)(8)(i) Maintenance and Operation of Facility for Small Quantity Generator of Hazardous Waste

Federal regulations of the U.S. Environmental Protection Agency (USEPA) mandate a small quantity generator of hazardous waste (SQG) take certain precautions to prepare for and prevent hazardous waste emergencies and to take certain measures if one were to occur. These regulations are found within the SQG conditions of exemption at 40 CFR 262.16:

  • 40 CFR 262.16(b)(8) Preparedness and prevention
  • 40 CFR 262.16(b)(9) Emergency procedures

This article is the first in a series that closely examines these regulations and attempts to make them understandable.

The purpose of this article: 40 CFR 262.16(b)(8)(i) Maintenance and operation of facility. (more…)

The Requirements of 40 CFR 262.256 Arrangements with Local Authorities for Large Quantity Generator of Hazardous Waste

The Requirements of 40 CFR 262.256 Arrangements with Local Authorities for Large Quantity Generator of Hazardous Waste

Federal regulations of the U.S. Environmental Protection Agency (USEPA) at 40 CFR 262.17(a)(6) require a large quantity generator of hazardous waste (LQG) to comply with the preparedness, prevention, and emergency procedure standards of 40 CFR 262, subpart M.  This article is the seventh in a series that looks closely at each of the sections in subpart M to clearly describe the responsibilities of a LQG.

The purpose of this article is to address the requirements of 40 CFR 262.256 Arrangements with local authorities. (more…)
The Requirements of 40 CFR 262.16(b)(8)(vi) Arrangements with Local Authorities for Small Quantity Generator of Hazardous Waste

The Requirements of 40 CFR 262.16(b)(8)(vi) Arrangements with Local Authorities for Small Quantity Generator of Hazardous Waste

Federal regulations of the U.S. Environmental Protection Agency (USEPA) require a small quantity generator of hazardous waste (SQG) to maintain equipment and processes to prevent a hazardous waste emergency and to respond to it if one occurs.  The regulations are found in the following SQG conditions for exemption:

  • 40 CFR 262.16(b)(8) Preparedness and prevention
  • 40 CFR 262.16(b)(9) Emergency procedures

This article is the sixth in a series that closely examines and explains these regulations.

In the previous article in this series I addressed the requirements of 40 CFR 262.16(b)(8)(v) Required Aisle Space for a Small Quantity Generator

The purpose of this article:  40 CFR 262.16(b)(8)(vi) Arrangements with local authorities. (more…)

RCRA Recordkeeping Requirements – Emergency Preparedness & Prevention

The RCRA regulations @ 40 CFR 265, Subpart C – Preparedness and Prevention apply to both Large Quantity Generators and Small Quantity Generators of hazardous waste [via §262.34(a)(4) & §262.34(d)(4), respectively].  A close review of the entire Subpart reveals little in the way of a requirement for documentation or recordkeeping.  The one place where a document is mentioned, “…the operating record…” is in §265.37(b), more on that later.  You may, however, wish to create documents and keep records of certain activities required by the Subpart in order to demonstrate compliance with the regulations and to fulfill the wishes of the USEPA.  This will include Testing and Maintenance of Equipment (§265.33) and Arrangements With Local Authorities (§265.37). (more…)

The Requirements of 40 CFR 265.33 Testing and Maintenance of Equipment for Generators of Hazardous Waste

In the previous article of this series I described the requirements of 40 CFR 265.32 – Required equipment.  That section identified the equipment (communication, spill response, and fire suppression) required of applicable facilities (LQGs and SQGs).

This article is the fourth in a series that will look closely at each section of 40 CFR 265, Subpart C and explain its requirements, how they apply to generators of hazardous waste, and what is required for compliance.  Keep in mind that the regulations of your State may differ from these Federal regulations.

The purpose of this article: identify and explain the requirements of 40 CFR 265.33 – Testing and maintenance of equipment for generators of hazardous waste under the emergency preparedness and prevention regulations of 40 CFR 265, subpart C.

Hold on a minute!  These regulations were revised and moved to a new location within Title 40 of the CFR by the Generator Improvements Rule.  If your state has not yet adopted the Generator Improvements Rule, then this article is still applicable to you (but it won’t be for much longer).  If your state has adopted and been authorized to enforce the Generator Improvements Rule, then these regulations no longer apply to you.  Read: What is the status of the Generator Improvements Rule in my state?

To see an explanation of these regulations as revised by the Generator Improvements Rule you must refer to the following:

Not sure of your hazardous waste generator category?

Take this short survey

To see an explanation of the regulations prior to the revisions of the Generator Improvements Rule, please continue reading this article.

(more…)

The Requirements of 40 CFR 265.31 Maintenance and Operation of Facility for Generators of Hazardous Waste

In an earlier article I identified and explained the regulations of 40 CFR 265.30 for the applicability of the Emergency Preparedness and Prevention Regulations.  As determined by those regulations, only the following are subject to the regulations of 40 CFR 265, subpart C:

  • Permitted treatment, storage, & disposal facilities (TSDFs).
  • Large quantity generators of hazardous waste (LQG).
  • Small quantity generators of hazardous waste (SQG).

Not sure of your hazardous waste generator category?

Take this short survey

This article is the second in a series that will look closely at each section of 40 CFR 265, Subpart C and explain its requirements, how they apply to generators of hazardous waste, and what is required for compliance.  Keep in mind that the regulations of your State may differ from these Federal regulations.

The purpose of this article:  identify and explain the requirements of 40 CFR 265.31 – Maintenance and operation of the facility under the emergency preparedness and prevention regulations of 40 CFR 265, subpart C.

Hold on a minute!  These regulations were revised and moved to a new location within Title 40 of the CFR by the Generator Improvements Rule.  If your state has not yet adopted the Generator Improvements Rule, then this article is still applicable to you (but it won’t be for much longer).  If your state has adopted and been authorized to enforce the Generator Improvements Rule, then these regulations no longer apply to you.  Read: What is the status of the Generator Improvements Rule in my state?

To see an explanation of these regulations as revised by the Generator Improvements Rule you must refer to the following:

To see an explanation of the regulations prior to the revisions of the Generator Improvements Rule, please continue reading this article.

(more…)

The Requirements of 40 CFR 265.30 Applicability for Generators of Hazardous Waste

Most generators of hazardous waste must comply with the requirements of 40 CFR 265.30 through 265.37 (aka: Subpart C of Part 265).  However, they may not realize these regulations apply to their operations or lack a firm grasp of what they must do to ensure compliance with them.  All too often little effort is made to understand the hazardous waste regulations because they seem to complex to grasp.  “Better”, it is thought, “to continue on with current procedures and hope any mistakes don’t result in significant violations.”  I’m here to tell you that most of the RCRA regulations, either those of the US EPA or those of an authorized State, can be understood with a little time and effort.

This article is the first in a series that will look closely at each section of 40 CFR 265, Subpart C and explain its requirements, how they apply to generators of hazardous waste, and what is required for compliance.  Keep in mind that the regulations of your State may differ from these Federal regulations.

The purpose of this article: identify and explain the requirements of 40 CFR 265.30 – Applicability of the emergency preparedness and prevention regulations to generators of hazardous waste.

Hold on a minute!  These regulations were revised and moved to a new location within Title 40 of the CFR by the Generator Improvements Rule.  If your state has not yet adopted the Generator Improvements Rule, then this article is still applicable to you (but it won’t be for much longer).  If your state has adopted and been authorized to enforce the Generator Improvements Rule, then these regulations no longer apply to you.  Read: What is the status of the Generator Improvements Rule in my state?

To see an explanation of these regulations as revised by the Generator Improvements Rule you must refer to the following:

To see an explanation of the regulations prior to the revisions of the Generator Improvements Rule, please continue reading this article.

(more…)