Beyond RCRA - 101

NCDENR - Division of Waste ManagementHazardous Waste Section

Compliance Branch

1

North CarolinaDepartment of Environment amp Natural Resources

Division of Waste ManagementHazardous Waste Section

Compliance Branch

Phil OrozcoEnvironmental Senior Specialist

Phone 919-212-2501Email philorozconcdenrgov

Primary Areas Research Triangle Park Durham and Chapel Hill NC 2

Communication is Key

With your State Inspector The EHampS Director amp Staff Department Heads ProfessorsPrincipal Investigators

ldquoSome Men You Just Canrsquot Reachrdquo - CHL

Lab Managers(Especially in graduate student labs)

Your General Services Staff Your HW Contractor

Violations Involving the Basics

Graduate Student Labs ndash SAAs

General Services ndash UW lamps Used Oil Aerosol Cans Paint Shops Power Plants Grounds-Keeping

Contractors ndash Donrsquot rely too heavily on HW vendors Keep an eye on Construction amp Demolition Contractors

Possible Remedies When necessary find a bilingual student to

serve as the lab safety manager When making pick-ups of HW at all locations

have your staff person do a quick audit Periodically do an audit of general services ndash

donrsquot wait for pick-ups of HW Demolition ndash get your inspector to OK any

temporary SAAs or 90180 - day storage areas

Rules Announced But Not Yet Proposed

Description of rule Action Scheduled date

Improvements to the hazardous waste generator regulations

NPRM 1014

Management standards for hazardous waste pharmaceuticals

NPRM 1214

Revisions to the hazardous waste import and export requirements

NPRM 215

Revisions to LDR treatment standards and recycling requirements for spent petroleum hydrotreating and hydrorefining catalyst

NPRM DND

Revisions to the biennial report NPRM DND

Hazardous waste requirements for managing waste retail products

NPRM DND

DND = date not determined LDR = land disposal restrictions NODA = notice of data availability NPRM = notice of proposed UST = underground storage tank

Proposed Rules to Be Finalized

Description of rule Action Scheduled date

Revisions to the definition of solid waste

Final rule 0714

Revisions to secondary containment and operator training requirements for USTs

Final rule 1014

Standards for Subtitle CD management of utility coal combustion residues

Final rule 1214

UST = underground storage tank CD = construction amp demolition

RCRA Authorization

Authorized RCRA Program Not RCRA Authorization

All States except AK amp IA Alaska

Iowa

District of Columbia Puerto Rico

Guam The Virgin Islands

American Samoa

Commonwealth of the Northern Marianna Islands

Tribal Lands (unless the State specifically receives authorization for them within its borders)

RCRA Authorized StatesCan be more strict amp broad in its regulation of HW then the Federal program Examples includeAnnual hazardous waste report instead of biennial

State-specific forms for the Notification of Regulated Waste Activity (EPA 8700-12 Form)

State-specific HW Codes

Containment requirements for HW in 90-Day amp 180-Day ndash EPA requires containment for permitted facilities only

Time limits for accumulation of hazardous waste in Satellite Accumulation Areas

Where is the Academic Labs Rule in Effect

Academic Labs Rule ndash Subpart K

In 2014 86 facilities are currently operating under Subpart Kbull 56 are collegesuniversitiesbull 10 are teaching hospitals onlybull 13 are non-profit research institute onlybull 2 are collegeuniversity w a teaching hospitalbull 5 are teaching hospital and non-profit research

institute

Where is the Solvent Contaminated Wipe Rule in Effect

Summary of EPArsquosAudit Policy

Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml

Incentives under Policy Penalty mitigation

No recommendation for criminal prosecution

No routine requests for audit reports

Conditions of the Audit Policy Entities that satisfy all the following conditions

are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been

realized as a result of non-compliance

Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation

Condition

Number

Short-Hand Summary ofAudit Policy Conditions

1

Systematic Discovery of the violation through an environmental audit or a compliance management system

2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure

3

Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

4 Independent Discovery and Disclosure

5

Correction and Remediation within 60 days in most cases from date of discovery

6 Prevent recurrence of a violation

7

Repeat violations are not eligible for mitigation under the Audit Policy

8 Certain violations are not eligible

9 Cooperation by the disclosing entity is required

Conditions of Policy

1 Systematic Discovery of the violation through an environmental audit or a compliance management system

2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure

Conditions of Policy cont

3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred

Conditions of Policy cont

4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party

5 Correction and remediation within 60 days in most cases from date of discovery

Conditions of Policy cont

6 Prevent recurrence of violation

7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company

Conditions of Policy cont

8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement

9 Cooperation by the disclosing entity is required

State Self Reporting Policy

Your state may have a self reporting policy similar to the federal policy

May need to notify through both EPA and your State to receive any penalty mitigation

Things you need to do Get the inspector in amp out as quickly as

possible

Keep your records neat and orderly

Ensure records are available for review bull Location of records must be known by several

people

Audit those that transport and receive your waste (HW UW E-waste amp non-haz)

Read the Inspectorrsquos Report

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

North CarolinaDepartment of Environment amp Natural Resources

Division of Waste ManagementHazardous Waste Section

Compliance Branch

Phil OrozcoEnvironmental Senior Specialist

Phone 919-212-2501Email philorozconcdenrgov

Primary Areas Research Triangle Park Durham and Chapel Hill NC 2

Communication is Key

With your State Inspector The EHampS Director amp Staff Department Heads ProfessorsPrincipal Investigators

ldquoSome Men You Just Canrsquot Reachrdquo - CHL

Lab Managers(Especially in graduate student labs)

Your General Services Staff Your HW Contractor

Violations Involving the Basics

Graduate Student Labs ndash SAAs

General Services ndash UW lamps Used Oil Aerosol Cans Paint Shops Power Plants Grounds-Keeping

Contractors ndash Donrsquot rely too heavily on HW vendors Keep an eye on Construction amp Demolition Contractors

Possible Remedies When necessary find a bilingual student to

serve as the lab safety manager When making pick-ups of HW at all locations

have your staff person do a quick audit Periodically do an audit of general services ndash

donrsquot wait for pick-ups of HW Demolition ndash get your inspector to OK any

temporary SAAs or 90180 - day storage areas

Rules Announced But Not Yet Proposed

Description of rule Action Scheduled date

Improvements to the hazardous waste generator regulations

NPRM 1014

Management standards for hazardous waste pharmaceuticals

NPRM 1214

Revisions to the hazardous waste import and export requirements

NPRM 215

Revisions to LDR treatment standards and recycling requirements for spent petroleum hydrotreating and hydrorefining catalyst

NPRM DND

Revisions to the biennial report NPRM DND

Hazardous waste requirements for managing waste retail products

NPRM DND

DND = date not determined LDR = land disposal restrictions NODA = notice of data availability NPRM = notice of proposed UST = underground storage tank

Proposed Rules to Be Finalized

Description of rule Action Scheduled date

Revisions to the definition of solid waste

Final rule 0714

Revisions to secondary containment and operator training requirements for USTs

Final rule 1014

Standards for Subtitle CD management of utility coal combustion residues

Final rule 1214

UST = underground storage tank CD = construction amp demolition

RCRA Authorization

Authorized RCRA Program Not RCRA Authorization

All States except AK amp IA Alaska

Iowa

District of Columbia Puerto Rico

Guam The Virgin Islands

American Samoa

Commonwealth of the Northern Marianna Islands

Tribal Lands (unless the State specifically receives authorization for them within its borders)

RCRA Authorized StatesCan be more strict amp broad in its regulation of HW then the Federal program Examples includeAnnual hazardous waste report instead of biennial

State-specific forms for the Notification of Regulated Waste Activity (EPA 8700-12 Form)

State-specific HW Codes

Containment requirements for HW in 90-Day amp 180-Day ndash EPA requires containment for permitted facilities only

Time limits for accumulation of hazardous waste in Satellite Accumulation Areas

Where is the Academic Labs Rule in Effect

Academic Labs Rule ndash Subpart K

In 2014 86 facilities are currently operating under Subpart Kbull 56 are collegesuniversitiesbull 10 are teaching hospitals onlybull 13 are non-profit research institute onlybull 2 are collegeuniversity w a teaching hospitalbull 5 are teaching hospital and non-profit research

institute

Where is the Solvent Contaminated Wipe Rule in Effect

Summary of EPArsquosAudit Policy

Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml

Incentives under Policy Penalty mitigation

No recommendation for criminal prosecution

No routine requests for audit reports

Conditions of the Audit Policy Entities that satisfy all the following conditions

are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been

realized as a result of non-compliance

Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation

Condition

Number

Short-Hand Summary ofAudit Policy Conditions

1

Systematic Discovery of the violation through an environmental audit or a compliance management system

2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure

3

Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

4 Independent Discovery and Disclosure

5

Correction and Remediation within 60 days in most cases from date of discovery

6 Prevent recurrence of a violation

7

Repeat violations are not eligible for mitigation under the Audit Policy

8 Certain violations are not eligible

9 Cooperation by the disclosing entity is required

Conditions of Policy

1 Systematic Discovery of the violation through an environmental audit or a compliance management system

2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure

Conditions of Policy cont

3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred

Conditions of Policy cont

4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party

5 Correction and remediation within 60 days in most cases from date of discovery

Conditions of Policy cont

6 Prevent recurrence of violation

7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company

Conditions of Policy cont

8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement

9 Cooperation by the disclosing entity is required

State Self Reporting Policy

Your state may have a self reporting policy similar to the federal policy

May need to notify through both EPA and your State to receive any penalty mitigation

Things you need to do Get the inspector in amp out as quickly as

possible

Keep your records neat and orderly

Ensure records are available for review bull Location of records must be known by several

people

Audit those that transport and receive your waste (HW UW E-waste amp non-haz)

Read the Inspectorrsquos Report

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Communication is Key

With your State Inspector The EHampS Director amp Staff Department Heads ProfessorsPrincipal Investigators

ldquoSome Men You Just Canrsquot Reachrdquo - CHL

Lab Managers(Especially in graduate student labs)

Your General Services Staff Your HW Contractor

Violations Involving the Basics

Graduate Student Labs ndash SAAs

General Services ndash UW lamps Used Oil Aerosol Cans Paint Shops Power Plants Grounds-Keeping

Contractors ndash Donrsquot rely too heavily on HW vendors Keep an eye on Construction amp Demolition Contractors

Possible Remedies When necessary find a bilingual student to

serve as the lab safety manager When making pick-ups of HW at all locations

have your staff person do a quick audit Periodically do an audit of general services ndash

donrsquot wait for pick-ups of HW Demolition ndash get your inspector to OK any

temporary SAAs or 90180 - day storage areas

Rules Announced But Not Yet Proposed

Description of rule Action Scheduled date

Improvements to the hazardous waste generator regulations

NPRM 1014

Management standards for hazardous waste pharmaceuticals

NPRM 1214

Revisions to the hazardous waste import and export requirements

NPRM 215

Revisions to LDR treatment standards and recycling requirements for spent petroleum hydrotreating and hydrorefining catalyst

NPRM DND

Revisions to the biennial report NPRM DND

Hazardous waste requirements for managing waste retail products

NPRM DND

DND = date not determined LDR = land disposal restrictions NODA = notice of data availability NPRM = notice of proposed UST = underground storage tank

Proposed Rules to Be Finalized

Description of rule Action Scheduled date

Revisions to the definition of solid waste

Final rule 0714

Revisions to secondary containment and operator training requirements for USTs

Final rule 1014

Standards for Subtitle CD management of utility coal combustion residues

Final rule 1214

UST = underground storage tank CD = construction amp demolition

RCRA Authorization

Authorized RCRA Program Not RCRA Authorization

All States except AK amp IA Alaska

Iowa

District of Columbia Puerto Rico

Guam The Virgin Islands

American Samoa

Commonwealth of the Northern Marianna Islands

Tribal Lands (unless the State specifically receives authorization for them within its borders)

RCRA Authorized StatesCan be more strict amp broad in its regulation of HW then the Federal program Examples includeAnnual hazardous waste report instead of biennial

State-specific forms for the Notification of Regulated Waste Activity (EPA 8700-12 Form)

State-specific HW Codes

Containment requirements for HW in 90-Day amp 180-Day ndash EPA requires containment for permitted facilities only

Time limits for accumulation of hazardous waste in Satellite Accumulation Areas

Where is the Academic Labs Rule in Effect

Academic Labs Rule ndash Subpart K

In 2014 86 facilities are currently operating under Subpart Kbull 56 are collegesuniversitiesbull 10 are teaching hospitals onlybull 13 are non-profit research institute onlybull 2 are collegeuniversity w a teaching hospitalbull 5 are teaching hospital and non-profit research

institute

Where is the Solvent Contaminated Wipe Rule in Effect

Summary of EPArsquosAudit Policy

Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml

Incentives under Policy Penalty mitigation

No recommendation for criminal prosecution

No routine requests for audit reports

Conditions of the Audit Policy Entities that satisfy all the following conditions

are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been

realized as a result of non-compliance

Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation

Condition

Number

Short-Hand Summary ofAudit Policy Conditions

1

Systematic Discovery of the violation through an environmental audit or a compliance management system

2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure

3

Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

4 Independent Discovery and Disclosure

5

Correction and Remediation within 60 days in most cases from date of discovery

6 Prevent recurrence of a violation

7

Repeat violations are not eligible for mitigation under the Audit Policy

8 Certain violations are not eligible

9 Cooperation by the disclosing entity is required

Conditions of Policy

1 Systematic Discovery of the violation through an environmental audit or a compliance management system

2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure

Conditions of Policy cont

3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred

Conditions of Policy cont

4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party

5 Correction and remediation within 60 days in most cases from date of discovery

Conditions of Policy cont

6 Prevent recurrence of violation

7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company

Conditions of Policy cont

8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement

9 Cooperation by the disclosing entity is required

State Self Reporting Policy

Your state may have a self reporting policy similar to the federal policy

May need to notify through both EPA and your State to receive any penalty mitigation

Things you need to do Get the inspector in amp out as quickly as

possible

Keep your records neat and orderly

Ensure records are available for review bull Location of records must be known by several

people

Audit those that transport and receive your waste (HW UW E-waste amp non-haz)

Read the Inspectorrsquos Report

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Violations Involving the Basics

Graduate Student Labs ndash SAAs

General Services ndash UW lamps Used Oil Aerosol Cans Paint Shops Power Plants Grounds-Keeping

Contractors ndash Donrsquot rely too heavily on HW vendors Keep an eye on Construction amp Demolition Contractors

Possible Remedies When necessary find a bilingual student to

serve as the lab safety manager When making pick-ups of HW at all locations

have your staff person do a quick audit Periodically do an audit of general services ndash

donrsquot wait for pick-ups of HW Demolition ndash get your inspector to OK any

temporary SAAs or 90180 - day storage areas

Rules Announced But Not Yet Proposed

Description of rule Action Scheduled date

Improvements to the hazardous waste generator regulations

NPRM 1014

Management standards for hazardous waste pharmaceuticals

NPRM 1214

Revisions to the hazardous waste import and export requirements

NPRM 215

Revisions to LDR treatment standards and recycling requirements for spent petroleum hydrotreating and hydrorefining catalyst

NPRM DND

Revisions to the biennial report NPRM DND

Hazardous waste requirements for managing waste retail products

NPRM DND

DND = date not determined LDR = land disposal restrictions NODA = notice of data availability NPRM = notice of proposed UST = underground storage tank

Proposed Rules to Be Finalized

Description of rule Action Scheduled date

Revisions to the definition of solid waste

Final rule 0714

Revisions to secondary containment and operator training requirements for USTs

Final rule 1014

Standards for Subtitle CD management of utility coal combustion residues

Final rule 1214

UST = underground storage tank CD = construction amp demolition

RCRA Authorization

Authorized RCRA Program Not RCRA Authorization

All States except AK amp IA Alaska

Iowa

District of Columbia Puerto Rico

Guam The Virgin Islands

American Samoa

Commonwealth of the Northern Marianna Islands

Tribal Lands (unless the State specifically receives authorization for them within its borders)

RCRA Authorized StatesCan be more strict amp broad in its regulation of HW then the Federal program Examples includeAnnual hazardous waste report instead of biennial

State-specific forms for the Notification of Regulated Waste Activity (EPA 8700-12 Form)

State-specific HW Codes

Containment requirements for HW in 90-Day amp 180-Day ndash EPA requires containment for permitted facilities only

Time limits for accumulation of hazardous waste in Satellite Accumulation Areas

Where is the Academic Labs Rule in Effect

Academic Labs Rule ndash Subpart K

In 2014 86 facilities are currently operating under Subpart Kbull 56 are collegesuniversitiesbull 10 are teaching hospitals onlybull 13 are non-profit research institute onlybull 2 are collegeuniversity w a teaching hospitalbull 5 are teaching hospital and non-profit research

institute

Where is the Solvent Contaminated Wipe Rule in Effect

Summary of EPArsquosAudit Policy

Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml

Incentives under Policy Penalty mitigation

No recommendation for criminal prosecution

No routine requests for audit reports

Conditions of the Audit Policy Entities that satisfy all the following conditions

are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been

realized as a result of non-compliance

Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation

Condition

Number

Short-Hand Summary ofAudit Policy Conditions

1

Systematic Discovery of the violation through an environmental audit or a compliance management system

2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure

3

Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

4 Independent Discovery and Disclosure

5

Correction and Remediation within 60 days in most cases from date of discovery

6 Prevent recurrence of a violation

7

Repeat violations are not eligible for mitigation under the Audit Policy

8 Certain violations are not eligible

9 Cooperation by the disclosing entity is required

Conditions of Policy

1 Systematic Discovery of the violation through an environmental audit or a compliance management system

2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure

Conditions of Policy cont

3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred

Conditions of Policy cont

4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party

5 Correction and remediation within 60 days in most cases from date of discovery

Conditions of Policy cont

6 Prevent recurrence of violation

7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company

Conditions of Policy cont

8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement

9 Cooperation by the disclosing entity is required

State Self Reporting Policy

Your state may have a self reporting policy similar to the federal policy

May need to notify through both EPA and your State to receive any penalty mitigation

Things you need to do Get the inspector in amp out as quickly as

possible

Keep your records neat and orderly

Ensure records are available for review bull Location of records must be known by several

people

Audit those that transport and receive your waste (HW UW E-waste amp non-haz)

Read the Inspectorrsquos Report

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Possible Remedies When necessary find a bilingual student to

serve as the lab safety manager When making pick-ups of HW at all locations

have your staff person do a quick audit Periodically do an audit of general services ndash

donrsquot wait for pick-ups of HW Demolition ndash get your inspector to OK any

temporary SAAs or 90180 - day storage areas

Rules Announced But Not Yet Proposed

Description of rule Action Scheduled date

Improvements to the hazardous waste generator regulations

NPRM 1014

Management standards for hazardous waste pharmaceuticals

NPRM 1214

Revisions to the hazardous waste import and export requirements

NPRM 215

Revisions to LDR treatment standards and recycling requirements for spent petroleum hydrotreating and hydrorefining catalyst

NPRM DND

Revisions to the biennial report NPRM DND

Hazardous waste requirements for managing waste retail products

NPRM DND

DND = date not determined LDR = land disposal restrictions NODA = notice of data availability NPRM = notice of proposed UST = underground storage tank

Proposed Rules to Be Finalized

Description of rule Action Scheduled date

Revisions to the definition of solid waste

Final rule 0714

Revisions to secondary containment and operator training requirements for USTs

Final rule 1014

Standards for Subtitle CD management of utility coal combustion residues

Final rule 1214

UST = underground storage tank CD = construction amp demolition

RCRA Authorization

Authorized RCRA Program Not RCRA Authorization

All States except AK amp IA Alaska

Iowa

District of Columbia Puerto Rico

Guam The Virgin Islands

American Samoa

Commonwealth of the Northern Marianna Islands

Tribal Lands (unless the State specifically receives authorization for them within its borders)

RCRA Authorized StatesCan be more strict amp broad in its regulation of HW then the Federal program Examples includeAnnual hazardous waste report instead of biennial

State-specific forms for the Notification of Regulated Waste Activity (EPA 8700-12 Form)

State-specific HW Codes

Containment requirements for HW in 90-Day amp 180-Day ndash EPA requires containment for permitted facilities only

Time limits for accumulation of hazardous waste in Satellite Accumulation Areas

Where is the Academic Labs Rule in Effect

Academic Labs Rule ndash Subpart K

In 2014 86 facilities are currently operating under Subpart Kbull 56 are collegesuniversitiesbull 10 are teaching hospitals onlybull 13 are non-profit research institute onlybull 2 are collegeuniversity w a teaching hospitalbull 5 are teaching hospital and non-profit research

institute

Where is the Solvent Contaminated Wipe Rule in Effect

Summary of EPArsquosAudit Policy

Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml

Incentives under Policy Penalty mitigation

No recommendation for criminal prosecution

No routine requests for audit reports

Conditions of the Audit Policy Entities that satisfy all the following conditions

are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been

realized as a result of non-compliance

Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation

Condition

Number

Short-Hand Summary ofAudit Policy Conditions

1

Systematic Discovery of the violation through an environmental audit or a compliance management system

2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure

3

Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

4 Independent Discovery and Disclosure

5

Correction and Remediation within 60 days in most cases from date of discovery

6 Prevent recurrence of a violation

7

Repeat violations are not eligible for mitigation under the Audit Policy

8 Certain violations are not eligible

9 Cooperation by the disclosing entity is required

Conditions of Policy

1 Systematic Discovery of the violation through an environmental audit or a compliance management system

2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure

Conditions of Policy cont

3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred

Conditions of Policy cont

4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party

5 Correction and remediation within 60 days in most cases from date of discovery

Conditions of Policy cont

6 Prevent recurrence of violation

7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company

Conditions of Policy cont

8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement

9 Cooperation by the disclosing entity is required

State Self Reporting Policy

Your state may have a self reporting policy similar to the federal policy

May need to notify through both EPA and your State to receive any penalty mitigation

Things you need to do Get the inspector in amp out as quickly as

possible

Keep your records neat and orderly

Ensure records are available for review bull Location of records must be known by several

people

Audit those that transport and receive your waste (HW UW E-waste amp non-haz)

Read the Inspectorrsquos Report

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Rules Announced But Not Yet Proposed

Description of rule Action Scheduled date

Improvements to the hazardous waste generator regulations

NPRM 1014

Management standards for hazardous waste pharmaceuticals

NPRM 1214

Revisions to the hazardous waste import and export requirements

NPRM 215

Revisions to LDR treatment standards and recycling requirements for spent petroleum hydrotreating and hydrorefining catalyst

NPRM DND

Revisions to the biennial report NPRM DND

Hazardous waste requirements for managing waste retail products

NPRM DND

DND = date not determined LDR = land disposal restrictions NODA = notice of data availability NPRM = notice of proposed UST = underground storage tank

Proposed Rules to Be Finalized

Description of rule Action Scheduled date

Revisions to the definition of solid waste

Final rule 0714

Revisions to secondary containment and operator training requirements for USTs

Final rule 1014

Standards for Subtitle CD management of utility coal combustion residues

Final rule 1214

UST = underground storage tank CD = construction amp demolition

RCRA Authorization

Authorized RCRA Program Not RCRA Authorization

All States except AK amp IA Alaska

Iowa

District of Columbia Puerto Rico

Guam The Virgin Islands

American Samoa

Commonwealth of the Northern Marianna Islands

Tribal Lands (unless the State specifically receives authorization for them within its borders)

RCRA Authorized StatesCan be more strict amp broad in its regulation of HW then the Federal program Examples includeAnnual hazardous waste report instead of biennial

State-specific forms for the Notification of Regulated Waste Activity (EPA 8700-12 Form)

State-specific HW Codes

Containment requirements for HW in 90-Day amp 180-Day ndash EPA requires containment for permitted facilities only

Time limits for accumulation of hazardous waste in Satellite Accumulation Areas

Where is the Academic Labs Rule in Effect

Academic Labs Rule ndash Subpart K

In 2014 86 facilities are currently operating under Subpart Kbull 56 are collegesuniversitiesbull 10 are teaching hospitals onlybull 13 are non-profit research institute onlybull 2 are collegeuniversity w a teaching hospitalbull 5 are teaching hospital and non-profit research

institute

Where is the Solvent Contaminated Wipe Rule in Effect

Summary of EPArsquosAudit Policy

Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml

Incentives under Policy Penalty mitigation

No recommendation for criminal prosecution

No routine requests for audit reports

Conditions of the Audit Policy Entities that satisfy all the following conditions

are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been

realized as a result of non-compliance

Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation

Condition

Number

Short-Hand Summary ofAudit Policy Conditions

1

Systematic Discovery of the violation through an environmental audit or a compliance management system

2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure

3

Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

4 Independent Discovery and Disclosure

5

Correction and Remediation within 60 days in most cases from date of discovery

6 Prevent recurrence of a violation

7

Repeat violations are not eligible for mitigation under the Audit Policy

8 Certain violations are not eligible

9 Cooperation by the disclosing entity is required

Conditions of Policy

1 Systematic Discovery of the violation through an environmental audit or a compliance management system

2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure

Conditions of Policy cont

3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred

Conditions of Policy cont

4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party

5 Correction and remediation within 60 days in most cases from date of discovery

Conditions of Policy cont

6 Prevent recurrence of violation

7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company

Conditions of Policy cont

8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement

9 Cooperation by the disclosing entity is required

State Self Reporting Policy

Your state may have a self reporting policy similar to the federal policy

May need to notify through both EPA and your State to receive any penalty mitigation

Things you need to do Get the inspector in amp out as quickly as

possible

Keep your records neat and orderly

Ensure records are available for review bull Location of records must be known by several

people

Audit those that transport and receive your waste (HW UW E-waste amp non-haz)

Read the Inspectorrsquos Report

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Proposed Rules to Be Finalized

Description of rule Action Scheduled date

Revisions to the definition of solid waste

Final rule 0714

Revisions to secondary containment and operator training requirements for USTs

Final rule 1014

Standards for Subtitle CD management of utility coal combustion residues

Final rule 1214

UST = underground storage tank CD = construction amp demolition

RCRA Authorization

Authorized RCRA Program Not RCRA Authorization

All States except AK amp IA Alaska

Iowa

District of Columbia Puerto Rico

Guam The Virgin Islands

American Samoa

Commonwealth of the Northern Marianna Islands

Tribal Lands (unless the State specifically receives authorization for them within its borders)

RCRA Authorized StatesCan be more strict amp broad in its regulation of HW then the Federal program Examples includeAnnual hazardous waste report instead of biennial

State-specific forms for the Notification of Regulated Waste Activity (EPA 8700-12 Form)

State-specific HW Codes

Containment requirements for HW in 90-Day amp 180-Day ndash EPA requires containment for permitted facilities only

Time limits for accumulation of hazardous waste in Satellite Accumulation Areas

Where is the Academic Labs Rule in Effect

Academic Labs Rule ndash Subpart K

In 2014 86 facilities are currently operating under Subpart Kbull 56 are collegesuniversitiesbull 10 are teaching hospitals onlybull 13 are non-profit research institute onlybull 2 are collegeuniversity w a teaching hospitalbull 5 are teaching hospital and non-profit research

institute

Where is the Solvent Contaminated Wipe Rule in Effect

Summary of EPArsquosAudit Policy

Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml

Incentives under Policy Penalty mitigation

No recommendation for criminal prosecution

No routine requests for audit reports

Conditions of the Audit Policy Entities that satisfy all the following conditions

are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been

realized as a result of non-compliance

Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation

Condition

Number

Short-Hand Summary ofAudit Policy Conditions

1

Systematic Discovery of the violation through an environmental audit or a compliance management system

2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure

3

Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

4 Independent Discovery and Disclosure

5

Correction and Remediation within 60 days in most cases from date of discovery

6 Prevent recurrence of a violation

7

Repeat violations are not eligible for mitigation under the Audit Policy

8 Certain violations are not eligible

9 Cooperation by the disclosing entity is required

Conditions of Policy

1 Systematic Discovery of the violation through an environmental audit or a compliance management system

2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure

Conditions of Policy cont

3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred

Conditions of Policy cont

4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party

5 Correction and remediation within 60 days in most cases from date of discovery

Conditions of Policy cont

6 Prevent recurrence of violation

7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company

Conditions of Policy cont

8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement

9 Cooperation by the disclosing entity is required

State Self Reporting Policy

Your state may have a self reporting policy similar to the federal policy

May need to notify through both EPA and your State to receive any penalty mitigation

Things you need to do Get the inspector in amp out as quickly as

possible

Keep your records neat and orderly

Ensure records are available for review bull Location of records must be known by several

people

Audit those that transport and receive your waste (HW UW E-waste amp non-haz)

Read the Inspectorrsquos Report

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

RCRA Authorization

Authorized RCRA Program Not RCRA Authorization

All States except AK amp IA Alaska

Iowa

District of Columbia Puerto Rico

Guam The Virgin Islands

American Samoa

Commonwealth of the Northern Marianna Islands

Tribal Lands (unless the State specifically receives authorization for them within its borders)

RCRA Authorized StatesCan be more strict amp broad in its regulation of HW then the Federal program Examples includeAnnual hazardous waste report instead of biennial

State-specific forms for the Notification of Regulated Waste Activity (EPA 8700-12 Form)

State-specific HW Codes

Containment requirements for HW in 90-Day amp 180-Day ndash EPA requires containment for permitted facilities only

Time limits for accumulation of hazardous waste in Satellite Accumulation Areas

Where is the Academic Labs Rule in Effect

Academic Labs Rule ndash Subpart K

In 2014 86 facilities are currently operating under Subpart Kbull 56 are collegesuniversitiesbull 10 are teaching hospitals onlybull 13 are non-profit research institute onlybull 2 are collegeuniversity w a teaching hospitalbull 5 are teaching hospital and non-profit research

institute

Where is the Solvent Contaminated Wipe Rule in Effect

Summary of EPArsquosAudit Policy

Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml

Incentives under Policy Penalty mitigation

No recommendation for criminal prosecution

No routine requests for audit reports

Conditions of the Audit Policy Entities that satisfy all the following conditions

are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been

realized as a result of non-compliance

Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation

Condition

Number

Short-Hand Summary ofAudit Policy Conditions

1

Systematic Discovery of the violation through an environmental audit or a compliance management system

2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure

3

Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

4 Independent Discovery and Disclosure

5

Correction and Remediation within 60 days in most cases from date of discovery

6 Prevent recurrence of a violation

7

Repeat violations are not eligible for mitigation under the Audit Policy

8 Certain violations are not eligible

9 Cooperation by the disclosing entity is required

Conditions of Policy

1 Systematic Discovery of the violation through an environmental audit or a compliance management system

2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure

Conditions of Policy cont

3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred

Conditions of Policy cont

4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party

5 Correction and remediation within 60 days in most cases from date of discovery

Conditions of Policy cont

6 Prevent recurrence of violation

7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company

Conditions of Policy cont

8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement

9 Cooperation by the disclosing entity is required

State Self Reporting Policy

Your state may have a self reporting policy similar to the federal policy

May need to notify through both EPA and your State to receive any penalty mitigation

Things you need to do Get the inspector in amp out as quickly as

possible

Keep your records neat and orderly

Ensure records are available for review bull Location of records must be known by several

people

Audit those that transport and receive your waste (HW UW E-waste amp non-haz)

Read the Inspectorrsquos Report

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

RCRA Authorized StatesCan be more strict amp broad in its regulation of HW then the Federal program Examples includeAnnual hazardous waste report instead of biennial

State-specific forms for the Notification of Regulated Waste Activity (EPA 8700-12 Form)

State-specific HW Codes

Containment requirements for HW in 90-Day amp 180-Day ndash EPA requires containment for permitted facilities only

Time limits for accumulation of hazardous waste in Satellite Accumulation Areas

Where is the Academic Labs Rule in Effect

Academic Labs Rule ndash Subpart K

In 2014 86 facilities are currently operating under Subpart Kbull 56 are collegesuniversitiesbull 10 are teaching hospitals onlybull 13 are non-profit research institute onlybull 2 are collegeuniversity w a teaching hospitalbull 5 are teaching hospital and non-profit research

institute

Where is the Solvent Contaminated Wipe Rule in Effect

Summary of EPArsquosAudit Policy

Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml

Incentives under Policy Penalty mitigation

No recommendation for criminal prosecution

No routine requests for audit reports

Conditions of the Audit Policy Entities that satisfy all the following conditions

are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been

realized as a result of non-compliance

Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation

Condition

Number

Short-Hand Summary ofAudit Policy Conditions

1

Systematic Discovery of the violation through an environmental audit or a compliance management system

2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure

3

Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

4 Independent Discovery and Disclosure

5

Correction and Remediation within 60 days in most cases from date of discovery

6 Prevent recurrence of a violation

7

Repeat violations are not eligible for mitigation under the Audit Policy

8 Certain violations are not eligible

9 Cooperation by the disclosing entity is required

Conditions of Policy

1 Systematic Discovery of the violation through an environmental audit or a compliance management system

2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure

Conditions of Policy cont

3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred

Conditions of Policy cont

4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party

5 Correction and remediation within 60 days in most cases from date of discovery

Conditions of Policy cont

6 Prevent recurrence of violation

7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company

Conditions of Policy cont

8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement

9 Cooperation by the disclosing entity is required

State Self Reporting Policy

Your state may have a self reporting policy similar to the federal policy

May need to notify through both EPA and your State to receive any penalty mitigation

Things you need to do Get the inspector in amp out as quickly as

possible

Keep your records neat and orderly

Ensure records are available for review bull Location of records must be known by several

people

Audit those that transport and receive your waste (HW UW E-waste amp non-haz)

Read the Inspectorrsquos Report

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Where is the Academic Labs Rule in Effect

Academic Labs Rule ndash Subpart K

In 2014 86 facilities are currently operating under Subpart Kbull 56 are collegesuniversitiesbull 10 are teaching hospitals onlybull 13 are non-profit research institute onlybull 2 are collegeuniversity w a teaching hospitalbull 5 are teaching hospital and non-profit research

institute

Where is the Solvent Contaminated Wipe Rule in Effect

Summary of EPArsquosAudit Policy

Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml

Incentives under Policy Penalty mitigation

No recommendation for criminal prosecution

No routine requests for audit reports

Conditions of the Audit Policy Entities that satisfy all the following conditions

are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been

realized as a result of non-compliance

Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation

Condition

Number

Short-Hand Summary ofAudit Policy Conditions

1

Systematic Discovery of the violation through an environmental audit or a compliance management system

2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure

3

Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

4 Independent Discovery and Disclosure

5

Correction and Remediation within 60 days in most cases from date of discovery

6 Prevent recurrence of a violation

7

Repeat violations are not eligible for mitigation under the Audit Policy

8 Certain violations are not eligible

9 Cooperation by the disclosing entity is required

Conditions of Policy

1 Systematic Discovery of the violation through an environmental audit or a compliance management system

2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure

Conditions of Policy cont

3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred

Conditions of Policy cont

4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party

5 Correction and remediation within 60 days in most cases from date of discovery

Conditions of Policy cont

6 Prevent recurrence of violation

7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company

Conditions of Policy cont

8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement

9 Cooperation by the disclosing entity is required

State Self Reporting Policy

Your state may have a self reporting policy similar to the federal policy

May need to notify through both EPA and your State to receive any penalty mitigation

Things you need to do Get the inspector in amp out as quickly as

possible

Keep your records neat and orderly

Ensure records are available for review bull Location of records must be known by several

people

Audit those that transport and receive your waste (HW UW E-waste amp non-haz)

Read the Inspectorrsquos Report

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Academic Labs Rule ndash Subpart K

In 2014 86 facilities are currently operating under Subpart Kbull 56 are collegesuniversitiesbull 10 are teaching hospitals onlybull 13 are non-profit research institute onlybull 2 are collegeuniversity w a teaching hospitalbull 5 are teaching hospital and non-profit research

institute

Where is the Solvent Contaminated Wipe Rule in Effect

Summary of EPArsquosAudit Policy

Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml

Incentives under Policy Penalty mitigation

No recommendation for criminal prosecution

No routine requests for audit reports

Conditions of the Audit Policy Entities that satisfy all the following conditions

are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been

realized as a result of non-compliance

Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation

Condition

Number

Short-Hand Summary ofAudit Policy Conditions

1

Systematic Discovery of the violation through an environmental audit or a compliance management system

2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure

3

Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

4 Independent Discovery and Disclosure

5

Correction and Remediation within 60 days in most cases from date of discovery

6 Prevent recurrence of a violation

7

Repeat violations are not eligible for mitigation under the Audit Policy

8 Certain violations are not eligible

9 Cooperation by the disclosing entity is required

Conditions of Policy

1 Systematic Discovery of the violation through an environmental audit or a compliance management system

2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure

Conditions of Policy cont

3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred

Conditions of Policy cont

4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party

5 Correction and remediation within 60 days in most cases from date of discovery

Conditions of Policy cont

6 Prevent recurrence of violation

7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company

Conditions of Policy cont

8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement

9 Cooperation by the disclosing entity is required

State Self Reporting Policy

Your state may have a self reporting policy similar to the federal policy

May need to notify through both EPA and your State to receive any penalty mitigation

Things you need to do Get the inspector in amp out as quickly as

possible

Keep your records neat and orderly

Ensure records are available for review bull Location of records must be known by several

people

Audit those that transport and receive your waste (HW UW E-waste amp non-haz)

Read the Inspectorrsquos Report

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Where is the Solvent Contaminated Wipe Rule in Effect

Summary of EPArsquosAudit Policy

Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml

Incentives under Policy Penalty mitigation

No recommendation for criminal prosecution

No routine requests for audit reports

Conditions of the Audit Policy Entities that satisfy all the following conditions

are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been

realized as a result of non-compliance

Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation

Condition

Number

Short-Hand Summary ofAudit Policy Conditions

1

Systematic Discovery of the violation through an environmental audit or a compliance management system

2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure

3

Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

4 Independent Discovery and Disclosure

5

Correction and Remediation within 60 days in most cases from date of discovery

6 Prevent recurrence of a violation

7

Repeat violations are not eligible for mitigation under the Audit Policy

8 Certain violations are not eligible

9 Cooperation by the disclosing entity is required

Conditions of Policy

1 Systematic Discovery of the violation through an environmental audit or a compliance management system

2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure

Conditions of Policy cont

3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred

Conditions of Policy cont

4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party

5 Correction and remediation within 60 days in most cases from date of discovery

Conditions of Policy cont

6 Prevent recurrence of violation

7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company

Conditions of Policy cont

8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement

9 Cooperation by the disclosing entity is required

State Self Reporting Policy

Your state may have a self reporting policy similar to the federal policy

May need to notify through both EPA and your State to receive any penalty mitigation

Things you need to do Get the inspector in amp out as quickly as

possible

Keep your records neat and orderly

Ensure records are available for review bull Location of records must be known by several

people

Audit those that transport and receive your waste (HW UW E-waste amp non-haz)

Read the Inspectorrsquos Report

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Summary of EPArsquosAudit Policy

Revised Policy1048708 65 FR 19617 - Effective May 11 20001048708 wwwepagovcomplianceincentivesauditingauditpolicyhtml

Incentives under Policy Penalty mitigation

No recommendation for criminal prosecution

No routine requests for audit reports

Conditions of the Audit Policy Entities that satisfy all the following conditions

are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been

realized as a result of non-compliance

Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation

Condition

Number

Short-Hand Summary ofAudit Policy Conditions

1

Systematic Discovery of the violation through an environmental audit or a compliance management system

2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure

3

Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

4 Independent Discovery and Disclosure

5

Correction and Remediation within 60 days in most cases from date of discovery

6 Prevent recurrence of a violation

7

Repeat violations are not eligible for mitigation under the Audit Policy

8 Certain violations are not eligible

9 Cooperation by the disclosing entity is required

Conditions of Policy

1 Systematic Discovery of the violation through an environmental audit or a compliance management system

2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure

Conditions of Policy cont

3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred

Conditions of Policy cont

4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party

5 Correction and remediation within 60 days in most cases from date of discovery

Conditions of Policy cont

6 Prevent recurrence of violation

7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company

Conditions of Policy cont

8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement

9 Cooperation by the disclosing entity is required

State Self Reporting Policy

Your state may have a self reporting policy similar to the federal policy

May need to notify through both EPA and your State to receive any penalty mitigation

Things you need to do Get the inspector in amp out as quickly as

possible

Keep your records neat and orderly

Ensure records are available for review bull Location of records must be known by several

people

Audit those that transport and receive your waste (HW UW E-waste amp non-haz)

Read the Inspectorrsquos Report

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Incentives under Policy Penalty mitigation

No recommendation for criminal prosecution

No routine requests for audit reports

Conditions of the Audit Policy Entities that satisfy all the following conditions

are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been

realized as a result of non-compliance

Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation

Condition

Number

Short-Hand Summary ofAudit Policy Conditions

1

Systematic Discovery of the violation through an environmental audit or a compliance management system

2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure

3

Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

4 Independent Discovery and Disclosure

5

Correction and Remediation within 60 days in most cases from date of discovery

6 Prevent recurrence of a violation

7

Repeat violations are not eligible for mitigation under the Audit Policy

8 Certain violations are not eligible

9 Cooperation by the disclosing entity is required

Conditions of Policy

1 Systematic Discovery of the violation through an environmental audit or a compliance management system

2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure

Conditions of Policy cont

3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred

Conditions of Policy cont

4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party

5 Correction and remediation within 60 days in most cases from date of discovery

Conditions of Policy cont

6 Prevent recurrence of violation

7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company

Conditions of Policy cont

8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement

9 Cooperation by the disclosing entity is required

State Self Reporting Policy

Your state may have a self reporting policy similar to the federal policy

May need to notify through both EPA and your State to receive any penalty mitigation

Things you need to do Get the inspector in amp out as quickly as

possible

Keep your records neat and orderly

Ensure records are available for review bull Location of records must be known by several

people

Audit those that transport and receive your waste (HW UW E-waste amp non-haz)

Read the Inspectorrsquos Report

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Conditions of the Audit Policy Entities that satisfy all the following conditions

are eligible for 100 penalty mitigation EPA retains its discretion to collect any economic benefit that may have been

realized as a result of non-compliance

Entities that satisfy all but the first condition -- systematic discovery -- are eligible for 75 penalty mitigation

Condition

Number

Short-Hand Summary ofAudit Policy Conditions

1

Systematic Discovery of the violation through an environmental audit or a compliance management system

2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure

3

Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

4 Independent Discovery and Disclosure

5

Correction and Remediation within 60 days in most cases from date of discovery

6 Prevent recurrence of a violation

7

Repeat violations are not eligible for mitigation under the Audit Policy

8 Certain violations are not eligible

9 Cooperation by the disclosing entity is required

Conditions of Policy

1 Systematic Discovery of the violation through an environmental audit or a compliance management system

2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure

Conditions of Policy cont

3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred

Conditions of Policy cont

4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party

5 Correction and remediation within 60 days in most cases from date of discovery

Conditions of Policy cont

6 Prevent recurrence of violation

7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company

Conditions of Policy cont

8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement

9 Cooperation by the disclosing entity is required

State Self Reporting Policy

Your state may have a self reporting policy similar to the federal policy

May need to notify through both EPA and your State to receive any penalty mitigation

Things you need to do Get the inspector in amp out as quickly as

possible

Keep your records neat and orderly

Ensure records are available for review bull Location of records must be known by several

people

Audit those that transport and receive your waste (HW UW E-waste amp non-haz)

Read the Inspectorrsquos Report

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Condition

Number

Short-Hand Summary ofAudit Policy Conditions

1

Systematic Discovery of the violation through an environmental audit or a compliance management system

2Voluntary Discovery in other words it is not through a legally required monitoring sampling or auditing procedure

3

Prompt Disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

4 Independent Discovery and Disclosure

5

Correction and Remediation within 60 days in most cases from date of discovery

6 Prevent recurrence of a violation

7

Repeat violations are not eligible for mitigation under the Audit Policy

8 Certain violations are not eligible

9 Cooperation by the disclosing entity is required

Conditions of Policy

1 Systematic Discovery of the violation through an environmental audit or a compliance management system

2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure

Conditions of Policy cont

3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred

Conditions of Policy cont

4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party

5 Correction and remediation within 60 days in most cases from date of discovery

Conditions of Policy cont

6 Prevent recurrence of violation

7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company

Conditions of Policy cont

8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement

9 Cooperation by the disclosing entity is required

State Self Reporting Policy

Your state may have a self reporting policy similar to the federal policy

May need to notify through both EPA and your State to receive any penalty mitigation

Things you need to do Get the inspector in amp out as quickly as

possible

Keep your records neat and orderly

Ensure records are available for review bull Location of records must be known by several

people

Audit those that transport and receive your waste (HW UW E-waste amp non-haz)

Read the Inspectorrsquos Report

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Conditions of Policy

1 Systematic Discovery of the violation through an environmental audit or a compliance management system

2 Voluntary Discovery that is not through a legally required monitoring sampling or auditing procedure

Conditions of Policy cont

3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred

Conditions of Policy cont

4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party

5 Correction and remediation within 60 days in most cases from date of discovery

Conditions of Policy cont

6 Prevent recurrence of violation

7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company

Conditions of Policy cont

8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement

9 Cooperation by the disclosing entity is required

State Self Reporting Policy

Your state may have a self reporting policy similar to the federal policy

May need to notify through both EPA and your State to receive any penalty mitigation

Things you need to do Get the inspector in amp out as quickly as

possible

Keep your records neat and orderly

Ensure records are available for review bull Location of records must be known by several

people

Audit those that transport and receive your waste (HW UW E-waste amp non-haz)

Read the Inspectorrsquos Report

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Conditions of Policy cont

3 Prompt disclosure in writing to EPA within 21 days of discovery or any shorter time required by law

bull Discovery occurs when any officer director employee or agent of the facility has an objectively reasonable basis for believing that a violation has or may have occurred

Conditions of Policy cont

4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party

5 Correction and remediation within 60 days in most cases from date of discovery

Conditions of Policy cont

6 Prevent recurrence of violation

7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company

Conditions of Policy cont

8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement

9 Cooperation by the disclosing entity is required

State Self Reporting Policy

Your state may have a self reporting policy similar to the federal policy

May need to notify through both EPA and your State to receive any penalty mitigation

Things you need to do Get the inspector in amp out as quickly as

possible

Keep your records neat and orderly

Ensure records are available for review bull Location of records must be known by several

people

Audit those that transport and receive your waste (HW UW E-waste amp non-haz)

Read the Inspectorrsquos Report

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Conditions of Policy cont

4 Independent discovery and disclosure before EPA likely would have identified the violation through its own investigation or based on information from a third party

5 Correction and remediation within 60 days in most cases from date of discovery

Conditions of Policy cont

6 Prevent recurrence of violation

7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company

Conditions of Policy cont

8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement

9 Cooperation by the disclosing entity is required

State Self Reporting Policy

Your state may have a self reporting policy similar to the federal policy

May need to notify through both EPA and your State to receive any penalty mitigation

Things you need to do Get the inspector in amp out as quickly as

possible

Keep your records neat and orderly

Ensure records are available for review bull Location of records must be known by several

people

Audit those that transport and receive your waste (HW UW E-waste amp non-haz)

Read the Inspectorrsquos Report

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Conditions of Policy cont

6 Prevent recurrence of violation

7 Repeat violations are not eligible that is violations that occurred within the past 3 years at the same facility or as part of a pattern of violations within the past 5 years at facilities owned or operated by the same company

Conditions of Policy cont

8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement

9 Cooperation by the disclosing entity is required

State Self Reporting Policy

Your state may have a self reporting policy similar to the federal policy

May need to notify through both EPA and your State to receive any penalty mitigation

Things you need to do Get the inspector in amp out as quickly as

possible

Keep your records neat and orderly

Ensure records are available for review bull Location of records must be known by several

people

Audit those that transport and receive your waste (HW UW E-waste amp non-haz)

Read the Inspectorrsquos Report

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Conditions of Policy cont

8 Certain violations are not eligible -- those that result in serious actual harm that may have presented an imminent and substantial endangerment or that violate specific terms of an administrative or judicial order or consent agreement

9 Cooperation by the disclosing entity is required

State Self Reporting Policy

Your state may have a self reporting policy similar to the federal policy

May need to notify through both EPA and your State to receive any penalty mitigation

Things you need to do Get the inspector in amp out as quickly as

possible

Keep your records neat and orderly

Ensure records are available for review bull Location of records must be known by several

people

Audit those that transport and receive your waste (HW UW E-waste amp non-haz)

Read the Inspectorrsquos Report

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

State Self Reporting Policy

Your state may have a self reporting policy similar to the federal policy

May need to notify through both EPA and your State to receive any penalty mitigation

Things you need to do Get the inspector in amp out as quickly as

possible

Keep your records neat and orderly

Ensure records are available for review bull Location of records must be known by several

people

Audit those that transport and receive your waste (HW UW E-waste amp non-haz)

Read the Inspectorrsquos Report

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Things you need to do Get the inspector in amp out as quickly as

possible

Keep your records neat and orderly

Ensure records are available for review bull Location of records must be known by several

people

Audit those that transport and receive your waste (HW UW E-waste amp non-haz)

Read the Inspectorrsquos Report

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

SQG vs LQG Paperwork RequirementsSmall Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authorities

bull Emergency Info posted by a phone

bull Employees must be thoroughly familiarhellip

Large Quantity Generator

bull ManifestsLDRsbull Waste Profilesbull Weekly Inspectionsbull Arrangements made with

local emergency authoritiesbull Contingency Plan

bull Documented RCRA Training job descriptions

bull Biennial Reportbull Waste Min Plan (Written)

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Waste minimization certification for both SQGs amp LQGs

Common Violation

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Item 13 Waste Codesbull Enter up to six federalstate

waste codes to describe each waste stream identified in Item 9bndash State waste codes that are

not redundant with federal codes must be entered here in addition to the federal waste codes which are most representative of the properties of the waste

ndash No specific required order or hierarchy for state and federal waste codes

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Manifests vs LDRs

Manifests and Land Disposal Restrictions are inter-connected but separate rules

40 CFR 26220 Appendix vs 2689(b)

Example F005 w MEK LDR ndash marking just F005 is OK HW manifest ndash must list D001 D035 F005

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Manifests HW Storage Limits SQGs only

40 CFR 26234(e)Allows storage of HW for 270 days when being

transported gt 200 miles an additional 90 days

40 CFR 26234(f) Allows for an extension of 30 days when ldquounforeseen temporary and uncontrollable circumstancesrdquo prevents you from complying with your 180270-day storage limit

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

LQG 90-Day Storage Limit

40 CFR 26234(b)

Allows a LQG an extension of 30 days to the 90-day storage limit due to ldquounforeseen temporary and uncontrollable circumstancesrdquo

Exceeding the time limit is a MAJOR violation

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Hospitals

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Hazardous Waste Pharmaceutical Management Standards

The EPA decided not to finalize the 2008 proposed rule but rather develop another proposal for the management and disposal of HW pharmaceuticals that are generated by healthcare-related facilities

ndash Proposed rule anticipated publication date August 2013

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Hazardous Waste Pharmaceutical Management Standards

For more information

httpwwwepagovoswhazardgenerationpharmaceuticalshtm

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Waste Generated at Hospitals

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Using a MSDS for Waste Determinations

OSHA regs do not require manufacturers to identify constituents present in material at concentrations below

ndash For noncarcinogen 1 (10000 ppm)ndash For carcinogen 01 (1000 ppm)

The product may contain toxicity characteristic constituents above RCRA regulatory levels even when not identified on the MSDS

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Salts and Esters not P-listed

If a parent compound is listed but the salt or ester of that compound is not then only the parent compound is regulated

Because of confusion over nomenclature EPA has provided a list of Chemical Abstract Service (CAS) Registration Numbers for each of the commercial chemical products

EPA Guidance RO12155

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Epinephrine Salts

P042 listing (Epinephrine) does not apply to Epinephrine salts

Most or all Epi-pens are Epinephrine salts

EPA Guidance RO14788

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Using CAS Number for Waste Determinations

Formaldehyde (CAS No 50-00-0)ndash U122 when unused

If formaldehyde polymerizes to form paraformaldehyde (CAS No 30525-89-4)minus Considered off-specification species of

formaldehyde when disposed of amp = U122

EPA Guidance RO13658

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Silver Recovery Units

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Low Level Mixed Waste - LLMW

Found under 266 - Subpart N - Standards for Management of Specific Hazardous Waste

Only applies to facilities with NRC permits Notification is required if conditional

exemption is claimed Read the Rule There are conditions to to

be met

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Conditions for LLMW

Conditions include (but not limited to) Maintaining an accurate emergency plan and provide it to all local authorities who may have to respond to fire explosion or release of hazardous waste Specific training requirements Annual inventory of LLMW Quarterly inspection LLMW for compliance with subpart N

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Audit OthersIt is very important to audit all facilities receiving waste from your siteThis includes (but not limited to)bullHazardous WastebullNon-Hazardous WastebullNon-RCRA Regulated WastebullUsed OilbullUniversal WastebullE-waste

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

10 Common RCRA Violations

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

10

Emergency Arrangements (esp Small Quantity Generators)

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Arrangements with Local Authorities

26537

The owner or operator must attempt to make the following arrangements as appropriate for the type of waste handled at his facility and the potential need for the services of the following organizations

SQG

LQG

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Arrangements with Local Authorities(40 CFR 26537)

Arrangements to familiarizendash Policendash Fire Departmentsndash Emergency Response Teams

Layout of the facilityProperties amp associated hazards of

hazardous wastePlaces where personnel normally workEntrances to roads inside the facilityEvacuation routes

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Arrangements with Local Authorities - Hospitals

Arrangements to familiarize local hospitalsndash The properties of hazardous waste handled at the

facilityndash The types of injuries or illnesses which could result

from fires explosions or releases at the facility

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

9

Hazardous Waste not in Containers

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

8

Documentation

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Common ViolationsLQG

ndash Job Descriptionsndash LQG contingency plan

Change in Emergency Coordinator Emergency Equip Capabilities Evac Routes from outside storage area

LQG and SQGndash Arrangements with local emergency authoritiesndash Weekly inspections of hazardous waste storage

area(s) documented

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Job Descriptions A written job description for each position

ndash Must include the requisite skill education or other qualifications and duties of the facility personnel assigned to each position

ndash Duties describe the HW responsibilities of the individual holding that position

ndash Match name(s) to current title

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Container Inspection Records

The owner or operator must inspect areas where containers are stored at least weekly looking for amp notingndash Leaksndash Deterioration caused by corrosion or other

factors (ldquoNo Leaksrdquo does not mean no deterioration of containers)

SQGLQG

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

7

Used Oil

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

6

Waste Determinations

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Hazardous Waste Determination

Is the material1) Solid waste2) Excludedexempt3) ldquoListedrdquo hazardous waste4) ldquoCharacteristicrdquo hazardous waste

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

5 Aisle Space

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

4

Time Frames

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Time Frames

Weekly inspections Annual RCRA training Manifests back to generator

ndash LQG after 35 days contact transporterTSDafter 45 days file exception report

ndash SQG after 60 days file ldquoexception reportrdquo

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

Also RememberRecord Retention for Training Records

Training records on current personnel must be kept until closure of the facility

Training records on former employees must be kept for at least 3 years from the date the employee last worked at the facility

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

3

Used Lamp Management

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

2

Labeling

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1

1

Open Containers

• Beyond RCRA - 101
• North Carolina Department of Environment amp Natural Resources Division of Waste Management Hazardous Waste Section Compliance Branch
• Communication is Key
• Violations Involving the Basics
• Possible Remedies
• Slide 6
• Slide 7
• RCRA Authorization
• RCRA Authorized States
• Where is the Academic Labs Rule in Effect
• Academic Labs Rule ndash Subpart K
• Where is the Solvent Contaminated Wipe Rule in Effect
• Summary of EPArsquos Audit Policy
• Incentives under Policy
• Conditions of the Audit Policy
• Slide 16
• Conditions of Policy
• Conditions of Policy cont
• Slide 19
• Slide 20
• Slide 21
• State Self Reporting Policy
• Things you need to do
• SQG vs LQG Paperwork Requirements
• Slide 25
• Item 13 Waste Codes
• Manifests vs LDRs
• Manifests HW Storage Limits SQGs only
• LQG 90-Day Storage Limit
• Hospitals
• Hazardous Waste Pharmaceutical Management Standards
• Slide 32
• Waste Generated at Hospitals
• Using a MSDS for Waste Determinations
• Salts and Esters not P-listed
• Epinephrine Salts
• Using CAS Number for Waste Determinations
• Silver Recovery Units
• Low Level Mixed Waste - LLMW
• Conditions for LLMW
• Audit Others
• 10 Common RCRA Violations
• 10
• Arrangements with Local Authorities 26537
• Arrangements with Local Authorities (40 CFR 26537)
• Arrangements with Local Authorities - Hospitals
• 9
• 8
• Common Violations
• Slide 50
• Job Descriptions
• Container Inspection Records
• 7
• 6
• Hazardous Waste Determination
• 5
• 4
• Time Frames
• Also Remember Record Retention for Training Records
• 3
• 2
• 1