The first step in the waste identification process – assuming you’ve already identified the material as a waste – is to determine if it is a solid waste as defined at 40 CFR 261.2. Once identified it is the responsibility of…
US EPA Regulations for the Management of Used Oil
The prospect of burning used oil on-site for energy recovery may seem daunting. You may think that the regulatory burden and related costs would far outstrip any savings on fuel consumption. I think you may be pleasantly surprised to learn…
Hospitals and Hazardous Waste Violations
Most of the attendees at my training events – check my Schedule of Events to see when I’ll be in your area – come from the manufacturing industry. There are many other commercial activities that are subject to the US DOT…
The Universal Waste Option for the Management of Hazardous Waste
Recently, Waste Management LampTracker, Inc. was fined $118,800 for violations at its Kaiser, MO facility where it collects and recycles universal waste lamps, mercury-containing equipment, and batteries (US EPA news release). Its violations include: Failure to maintain adequate aisle space…
An Extension to the Hazardous Waste On-Site Accumulation Limits for Large Quantity Generators of Hazardous Waste that Generate F006 Wastewater Treatement Sludge from Electroplating Operations
As a Large Quantity Generator (LQG) of hazardous waste, you are aware that hazardous waste may not accumulate at your site for longer than 90 days unless it is managed in a satellite accumulation area pursuant to 40 CFR 262.34(c)(1). However, did…
A Hazardous Waste Treatment Storage and Disposal Facility (TSDF) Faces Stiff Fines From the US EPA
When facing an inspection and possible enforcement actions from the US EPA or their state regulatory agency a hazardous waste generator may wonder, “Why me? Why don’t they go after one of those big companies like BP, DuPont, or Goodyear…
USEPA Regulations for the Management of Medical Waste
USEPA Regulations for the Management of Medical Waste: It was the summer between my freshman and sophomore years of college at the University of Wisconsin – Stevens Point when news broke in July of 1988 about needles and other medical…
Stiff Fines From the US EPA for Hazardous Waste Generators are Easily Avoidable
No matter how many times I read about it, I never fail to be surprised by two things: The severity of penalties faced by regulated facilities that violate US EPA hazardous waste (RCRA) regulations; and, How easily avoidable those violations…
EPA Finalizes Agreement to Begin First Phase of Newtown Creek Superfund Cleanup
Superfund is the common name for the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980. This law was designed to create a mechanism and funding source for the cleanup of sites contaminated with hazardous substances. In many cases,…
Proposed Changes to the Uniform Hazardous Waste Manifest
In 1984 US EPA created the Uniform Hazardous Waste Manifest. An improvement on its predecessor, it nonetheless allowed States to customize the forms to meet their state-specific needs. Twenty three states adapted the Federal form to include a state letterhead and…