The Four Steps To Successful Hazardous Waste Record Keeping

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STEP 3
Waste Accumulation And
On-Site Management
Step 3: Accumulation and
Management
Hazardous Waste
• CESQG – No time limit/2,200 pounds
• SQG – 180 days*/13,200 pounds
• LQG – 90 days/No quantity
Step 3: Universal Waste
• Small Quantity Handler
– Accumulates under 11,000 pounds
– One year storage limit
• Large Quantity Handler
– Accumulates over 11,000 pounds
– One year storage limit
Step 3: Nonhazardous Waste
– Industrial - No quantity or time
limit*
– Nonindustrial – No quantity/weekly
pickup
Step 3: Accumulation and
Management – Time and Quantity
Documenting Compliance with Time and
Quantity Limits
 Satellite Accumulation Unit
 Waste Management Units
Properly labeled containers
Shipping records
Inventory or segregation systems
Step 3: Satellite Accumulation
– At or near the point of generation
– Not identified on the NOR
– Keep records of locations, etc.
– Limit of 55 gallons
– Containers must be labeled
Step 3: Waste Management Units
– Distinct areas where waste is stored
– Containers, tanks, distillation units, etc.
– Identified on facility NOR
– Inspection required
WMU –
Waste
Management
Unit
Step 3: Accumulation and
Management
WMU Inspection Records
• Tanks – Must be inspected daily
• Containers – Must be inspected
weekly
Step 3: Inspecting WMUs
Check For:
Proper Labeling
Compatibility
Closed
Condition
WMU Inspection Log
Step 3: Notice of Registration
“NOR”
Notice of Registration “NOR”
– Generated from TCEQ 00002 Form
– Printed by TCEQ
– List Generator Information
– Original identification and notification of
WMUs
– Add new WMUs to NOR
– MUST be kept up to date
Step 3: Emergency Response
Communications
Emergency coordinator
Emergency phone numbers
Employee training
Step 3: Spills
What spilled?
How much was spilled?
Where spill occurred?
Why spill was or was not reported?
Must
be
Posted
Emergency
Site Plan
ER
Notification
Hazardous
Waste
Generator
ER
Notification
STEP 4
Waste Transport and
Disposal
Shipping Hazardous Waste
Records
The most important thing is to keep track of
who transports your waste and where it goes.
Cradle to the Grave
RCRA Subtitle C, establishes a system for
tracking the progress of hazardous wastes from
their point of generation, their transport, and
their treatment and/or disposal.
Step 4: Transport and
Disposal- Cradle to Grave
Know who you are doing business with
Check registrations/permits
Ask for references
Take a field trip
Step 4: Hazardous and
Universal Waste Transport
Hazardous Waste Transport
Registered with TCEQ and EPA
Follow DOT requirements
 Universal Waste Transport
No registration required*
Follow DOT requirements
Step 4: Waste Transport
 Industrial Waste Transport
Class 1 requires registration W/ TCEQ
 Nonindustrial Waste Transport
No registration required
 Liquid/Sludge/Grease & Grit Transport
Requires registration w/TCEQ
Step 4: Hazardous and Universal
Waste Disposal
 Hazardous Waste Disposal (TSDF)
All disposal facilities must be permitted
 Universal Waste Disposal
Large Quantity Handlers must be registered W/EPA
All disposal facilities must be permitted
Step 4: Waste Disposal
 Industrial and Nonindustrial Waste Disposal
All disposal facilities must be permitted
Class 1 disposed at specific facilities only
 Special Waste Disposal
Disposal facilities must be permitted
Disposed at specific facilities only
TSDF
Profile
Transporter
Profile
Step 4:Transport and Disposal
EPA 8700-22
“Federal Uniform Hazardous Waste Manifest”
– Must accompany all hazardous waste and all
Class 1 waste in Texas
– 6 Part - multiple copies of a single form
– Original form / 35 days
– CESQGs & SQGs may get up to 25 manifest per
year from the TCEQ.
Record Keeping & Reporting
NEW Manifest (EPA 8700-22)
– LQGs must contact an approved printer to
order the new manifest.
– Contact the EPA website for approved
printers:
List of Approved Printers
EPA 8700-22
Uniform
Hazardous
Waste
Manifest
Step 4:Transport and Disposal“Exception Report”
– No standard report format/name
– Filed if Original copy not received back
– 45 days from original shipment date
Step 4: Transport and Disposal- LDR
– “Land Disposal Restriction/Land Ban”
– Attached to the manifest
– Used by the disposal facility
Step 4:Transport and DisposalTCEQ Form- 0757
– “One Time Shipment Form”
– Inactive/unregistered generators only
– Temporary waste codes & ID number
One-Time Shipment
Step 4:Transport and DisposalTCEQ Form- 0040A
– “Monthly Waste Shipment Summary”
– Used by unregistered generators
– Due the 25th of the month following the
shipment
Waste Shipment Summary
Step 4:Transport and DisposalTCEQ Form- 0152
 Request For Authorization For Disposal Of
Special Waste
 May be initiated by the generator or landfill
Special Waste - TCEQ-0152
Identifying Hazardous Waste
when Classifying
1.
2.
3.
4.
5.
Is
Is
Is
Is
Is
it
it
it
it
it
a SOLID WASTE?
EXEMPT?
LISTED?
CHARACTERISTIC?
Industrial or Universal Waste?
Be In The Know
 Know What Records And Reports Are Required.
 Know When Records and Reports Are Due.
 Know Where Things Are.
 Know Who You Are Doing Business With.
 Know Your Inspector.
Questions
TCEQ Small Business and Local Assistance
- 1-800-447-2827
- texasenvirohelp@tceq.texas.gov
- TexasEnviroHelp.org
Compliance Specialists
Carmen Ramirez
956.721.8457
carmen.ramirez@tceq.texas.gov
Charlie Adams
409.899.8788
charlie.adams@tceq.texas.gov
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