step 3 waste accumulation and on-site management
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Step 3: Accumulation and Management
Hazardous Waste
• CESQG – No time limit/2,200 pounds
• SQG – 180 days*/13,200 pounds
• LQG – 90 days/No quantity
Step 3: Universal Waste
• Small Quantity Handler– Accumulates under 11,000 pounds– One year storage limit
• Large Quantity Handler– Accumulates over 11,000 pounds– One year storage limit
Step 3: Nonhazardous Waste
– Industrial - No quantity or time limit*
–Nonindustrial – No quantity/weekly pickup
Step 3: Accumulation and Management – Time and Quantity
Documenting Compliance with Time and Quantity Limits Satellite Accumulation Unit Waste Management Units
Properly labeled containersShipping recordsInventory or segregation systems
Step 3: Satellite Accumulation
– At or near the point of generation– Not identified on the NOR– Keep records of locations, etc.– Limit of 55 gallons– Containers must be labeled
– Distinct areas where waste is stored– Containers, tanks, distillation units, etc.– Identified on facility NOR– Inspection required
Step 3: Waste Management Units
Step 3: Accumulation and Management
WMU Inspection Records
• Tanks – Must be inspected daily
• Containers – Must be inspected weekly
Step 3: Notice of Registration “NOR”
Notice of Registration “NOR”– Generated from TCEQ 00002 Form– Printed by TCEQ– List Generator Information– Original identification and notification of WMUs– Add new WMUs to NOR– MUST be kept up to date
Step 3: Emergency Response
CommunicationsEmergency coordinatorEmergency phone numbersEmployee training
Step 3: Spills
What spilled?How much was spilled?Where spill occurred?Why spill was or was not reported?
Shipping Hazardous Waste Records
The most important thing is to keep track of who transports your waste and where it goes.
Cradle to the Grave
RCRA Subtitle C, establishes a system for tracking the progress of hazardous wastes from their point of generation, their transport, and their treatment and/or disposal.
Step 4: Transport and Disposal- Cradle to Grave
Know who you are doing business withCheck registrations/permitsAsk for referencesTake a field trip
Hazardous Waste TransportRegistered with TCEQ and EPAFollow DOT requirements
Universal Waste TransportNo registration required* Follow DOT requirements
Step 4: Hazardous and Universal Waste Transport
Industrial Waste TransportClass 1 requires registration W/ TCEQ
Nonindustrial Waste TransportNo registration required
Liquid/Sludge/Grease & Grit TransportRequires registration w/TCEQ
Step 4: Waste Transport
Hazardous Waste Disposal (TSDF)All disposal facilities must be permitted
Universal Waste DisposalLarge Quantity Handlers must be registered W/EPAAll disposal facilities must be permitted
Step 4: Hazardous and Universal Waste Disposal
Industrial and Nonindustrial Waste DisposalAll disposal facilities must be permittedClass 1 disposed at specific facilities only
Special Waste DisposalDisposal facilities must be permittedDisposed at specific facilities only
Step 4: Waste Disposal
EPA 8700-22“Federal Uniform Hazardous Waste Manifest”– Must accompany all hazardous waste and all
Class 1 waste in Texas– 6 Part - multiple copies of a single form– Original form / 35 days– CESQGs & SQGs may get up to 25 manifest per
year from the TCEQ.
Step 4:Transport and Disposal
Record Keeping & Reporting
NEW Manifest (EPA 8700-22)– LQGs must contact an approved printer to
order the new manifest.– Contact the EPA website for approved
printers: List of Approved Printers
– No standard report format/name
– Filed if Original copy not received back
– 45 days from original shipment date
Step 4:Transport and Disposal- “Exception Report”
– “Land Disposal Restriction/Land Ban”
– Attached to the manifest
– Used by the disposal facility
Step 4: Transport and Disposal- LDR
– “One Time Shipment Form”
– Inactive/unregistered generators only
– Temporary waste codes & ID number
Step 4:Transport and Disposal- TCEQ Form- 0757
– “Monthly Waste Shipment Summary”
– Used by unregistered generators
– Due the 25th of the month following the shipment
Step 4:Transport and Disposal- TCEQ Form- 0040A
Request For Authorization For Disposal Of Special Waste
May be initiated by the generator or landfill
Step 4:Transport and Disposal- TCEQ Form- 0152
Identifying Hazardous Waste when Classifying
1. Is it a SOLID WASTE?2. Is it EXEMPT?3. Is it LISTED?4. Is it CHARACTERISTIC?5. Is it Industrial or Universal Waste?
Be In The Know
Know What Records And Reports Are Required.
Know When Records and Reports Are Due.
Know Where Things Are.
Know Who You Are Doing Business With.
Know Your Inspector.
Questions
TCEQ Small Business and Local Assistance
- 1-800-447-2827- texasenvirohelp@tceq.texas.gov- TexasEnviroHelp.org
Compliance SpecialistsCarmen Ramirez
956.721.8457carmen.ramirez@tceq.texas.gov
Charlie Adams409.899.8788
charlie.adams@tceq.texas.gov
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