OURAY
Environmental Services, LLC
www.ourayservices.com
Presented By:
Daniel Motisi, CHMM
• What we do…
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Emergency Response
Hazardous and Industrial Waste Disposal
Remediation
Sampling and Waste Determination
Facility Audits and other Customized Services
The Audit
EPA Encourages Voluntary Self-Audits
www.epa.gov/
 “Protocol for Conducting Environmental
Compliance Audits for Hazardous Waste
Generators under RCRA”
Pre-Audit
Continuously maintain records
Employee Training Certificates.
Disposal documents.
Biennial/annual reporting.
Follow-up to Notice-of-violation (NOV).
Spill reporting.
Pre – Audit (cont’d)
Organization starts at the beginning!
Document employee training.
Document deficiencies.
Correct deficiencies immediately.
General Aspects of an Audit
 Record Keeping
 Inspection logs
 Facilities (physical)
 Temporary Storage
 Off-Site Storage
 Permits
Benefits of an Self-Audit
Voluntary audit programs play an important role in
helping companies meet their obligation to comply
with environmental requirements.
Environmental audits may identify pollution
prevention opportunities that can substantially reduce
an organization’s operating costs.
Environmental audits can also serve as a diagnostic
tool in evaluating a facility’s overall environmental
management system.
Generator Status
Audit
Identify Deficiencies
Correct Action
Improved
EMS
Develop Corrective
Action
Exceptions
Group Exceptions
(Common Causes)
Examine for
Common Causes
Ultimate Goal:
Facility Compliance
Improved EMS
Reduction of generator status
Types of Records to Review:
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Notification of Hazardous Waste Activity (EPA ID No.);
Hazardous waste manifests;
Manifest exception reports;
Biennial reports (LQG’s only);
Inspection logs;
Land disposal restriction certifications;
Employee training documentation;
Hazardous substance spill control and contingency plan;
Safety Data Sheets (SDSs);
Inventory records;
Hazardous Communication Plan (HAZCOM);
Chemical Hygiene Plan (labs); and
Spill records.
RCRA Facilities (physical)
 Hazardous waste generations sites (e.g., production and
manufacturing areas);
 Waste storage areas;
 Satellite accumulation points;
 Vehicles used for transport;
 Container storage areas;
 Generation points;
 Shipping and receiving areas.
continued….
Label all tanks/drums (even if empty).
Perform routine facility inspections.
Fire Suppression – adequate?
Fire Suppression – Inspection?
Contingency Plan – Updated?
Security.
Documentation
Starts at the beginning
EPA ID number
Generator address
Shipping description
Signatures
Maintain Label integrity
Documents You Should Keep
 Manifests
 LDR’s
 Certificate of Disposal
 Bill-of-Laden
 Waste characterization
(profiles/analytical)
 SQG’s/LQG’s – record keeping ( 3 years) (40 CFR 262.40(c)).
 Employee training certificates
RECORD KEEPING
Find out what your company record keeping
requirements are:
Develop/implement a program that meets
company needs and OSHA & RCRA requirements.
Employee Training Certificates.
HAZMAT Storage
Weekly Inspections
Proper ventilation
Labeled containers
Organization
Clean environment
Container integrity
STORING HAZARDOUS WASTE:
 Reactives must be segregated from ignitables.
 Acids must be segregated from caustics.
 Corrosives should be segregated from flammables.
 Oxidizers should be segregated from EVERYTHING.
 Organic reactives must be segregated from inorganic
reactives (metals).
Facility Cleanliness
Clean up spills immediately
Remove tripping hazardous
- hoses
- debris
- ice/snow
Definitions:
 RCRA hazardous waste regulations classify generators of
hazardous waste into three categories based on the
quantity generated, as follows:
 Conditionally exempt small quantity generators (CESQGs)
generate no more than 100 kilograms (220 pounds) of
hazardous waste in a calendar month.
 Small quantity generators (SQGs) generate between 100
kilograms (220 pounds) and 1,000 kilograms (2,200 pounds)
of hazardous waste in a calendar month.
 Large quantity generators (LQGs) generate more than 1,000
kilograms (2,200 pounds) of hazardous waste in a calendar
month.
“CESQG facilities are not required to use manifests, but
are required to ensure delivery of the hazardous waste
to a permitted hazardous waste treatment or disposal
facility or to a facility that reuses, recycles, or reclaims
the hazardous waste (40 CFR 261.5(g)(3)).
“CESQG facilities should maintain receipts from
hazardous waste contractors that list the EPA or state
identification numbers of the transporter and the
facility to which the waste is to be taken.”
The time period of 262.34(d) for accumulation of
wastes on-site begins when the accumulated wastes
equals or exceeds 1 kilogram of acute or 1000
kilograms hazardous waste.
continued……
“SQG and LQG facilities must consign with
hazardous waste transporters and hazardous
waste management facilities that have EPA
identification numbers (40 CFR 262.12(c)).”
SQG Exception Reporting (40 CFR 262.42)
 Exception Reporting is part of the RCRA tracking system.
 After waste has been transported off-site for disposal,
the TSDF is required to return a copy of the original
manifest within 45 days from the date the initial
transporter accepted the waste. An Exception Report,
must be filed with the EPA/State, if the SQG has not
received a copy of the manifest within 60 days (40 CFR
262.42).
LQG Exception Reporting (40 CFR 262.42)
 The Exception Reporting requirements for LQGs are a
little different.
 If the LQG does not receive a copy of the manifest within
35 days of the date that the waste was accepted by the
original transporter, you must contact the transporter
and TSDF to determine the status of the waste. If a copy
of the manifest has not been received within 45 days,
then you must submit the Exception Report to the
EPA/State as described in 40 CFR 262.42.
There is no special form for the Exception
Report. You can write directly on a copy of the
manifest or attach a separate sheet of paper
(handwritten or typed). Must include:
A legible copy of the manifest in question.
A statement explaining the efforts taken to
locate the hazardous waste.
Your signature.
Exception Reporting for LQG’s (cont’d)
LQG’s must retain copies of the Exception Reports
for the purpose of biennial reporting.
Periods of retention for reports may be extended
automatically during the course of any unresolved
enforcement action…a.k.a. NOV.
Some states are more stringent and require
annual reports prior to March 1 for the previous
year (40 CFR 262.41).
Audit
Identify Deficiencies
Correct Action
Improved
EMS
Develop Corrective
Action
Exceptions
Group Exceptions
(Common Causes)
Examine for
Common Causes
Stay Organized
 Designate a file cabinet for manifests:
File by name of product, purchase
order, or by manifest number etc…..
 “SQGs and LQGs must retain copies of hazardous waste
manifests for at least three years from the date the waste
was accepted by the initial transporter, or until the generator
receives a signed copy from the designated facility that
received the waste.”
 “This signed copy must be retained for at least three years
from the date the waste was accepted by the initial
transporter (40 CFR 262.40(a)).”
 Organization and employee knowledge is the key to success.
Did You Know?????
• Author - unknown
CESQG, SQG and LQG’s
Verify that the facility has not exceeded the
respective quantities (100Kg/1,000Kg/>1,000Kg)
of hazardous waste.
and < 1Kg of acute hazardous waste for CESQG’s
and SQG’s.
Determine if any prior Notice-of-Violation(s) are
unresolved.
Reliable Transporter
Transporters of hazardous waste must have a EPA
ID number.
Interview HAZMAT transporters.
Do transporters meets company
insurance requirements?
Verify transporters retain signed manifest records
(3 years minimum)
What is there safety record?
Training Documentation:
Why?
Part of the audit – records review
What?
Hazardous waste management
procedures relevant to positions in which
they are employed.
When?
Within six months and annually thereafter
(RCRA).
Prior to working at a TSDF and annual 8-hr
refresher training thereafter (OSHA).
Training Requirements for TSDF’s
RCRA vs. OSHA
Areas of Overlap
40 CFR 264/265
40 CFR 1910.120
LQG’s
OSHA
RCRA
Overlap
RCRA (40 CFR 264/265)
OSHA (40 CFR 1910.120)
Comment
Train waste management personnel
Complete classroom or OJT;
Train personnel to respond to emergencies.
Personnel who are exposed to
health/hazardous substances at TSD
facilities must complete a 24 hour
training program – to safely perform
assigned duties.
OSHA meets or exceeds
RCRA. However, nonexposed employees are
not required to meet 40
CFR 1910.120.
Training program must be directed by a
person trained in hazardous waste
management.
Instructors have completed training
courses for teaching relative subject
matter or; have the academic
credentials/experience to demonstrate
competent instructional skills.
OSHA meets or exceeds
RCRA.
Training records are to be maintained for a
minimum of 3 years at the facility from the
last date worked.
Training records should be maintained for
a minimum of 5 years after participation
in a training program.
OSHA requirement less
restrictive.
Complete training within 6 months for their
assignment at the facility.
Initial training should be provided prior
to beginning work.
OSHA requirement more
restrictive than RCRA.
Facility personnel must take part in an
annual review of the training program.
Refresher training is required annually.
OSHA specifies 8-hr training.
OSHA requirement is
more stringent.
Other Things To Remember:
SQG – “The 180 day time period is extended to
270 days if the waste must be transported more
than 200 miles to a TSDF. This extension does not
apply if a TSDF is available within 200 miles and
the facility chooses to transport the waste to a
more distant TSDF.” (40 CFR 262.34)
SQG’s and LQG’s are required to keep records of
waste analyses, tests, and waste determinations
(40 CFR 262.40(c) for at least three years.
continued……
SQG’s and LQG’s are required to have an
emergency coordinator at the site or on call at ALL
times. (40 CFR 262.34)
“TSDF owner and operator must keep original,
signed copies of all manifests for inspection
purposes. All records and plans must be available
for inspection.”
Reporting – Biennial/Annual
Biennial reports for TSDF’s must be submitted prior to
March 1 of even numbered years to the Regional
Administrator (40 CFR 262.41).
Primary exporters (shipped outside the US) must
submit annual reports to the Regional Administrator,
prior to March 1 of every year (40 CFR 262.56).
Summary
Continuously maintain documents
Provide annual training to employees
Perform and document facility inspections
Stay organized
Maintain documents for a minimum of 3 years
Report Exceptions when necessary
Know training and record keeping requirements
– OSHA vs. RCRA
THANK YOU!
OURAY
Environmental Services, LLC
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storing hazardous waste