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What to Expect from a Hazardous Waste Inspection

What to Expect from a Hazardous Waste Inspection. Central District Debby Valin, Environmental Consultant October 28, 2011. Agenda. Generator Basics Nature of Inspections Inspection Components The Regulatory Process Compliance Non-Compliance Role of EPA Disclaimer Contacts Quiz.

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What to Expect from a Hazardous Waste Inspection

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  1. What to Expect from a Hazardous Waste Inspection Central District Debby Valin, Environmental Consultant October 28, 2011

  2. Agenda • Generator Basics • Nature of Inspections • Inspection Components • The Regulatory Process • Compliance • Non-Compliance • Role of EPA • Disclaimer • Contacts • Quiz October 28, 2011 | 2

  3. Generator Classes Based on generation rate in any given month: • CESQG – less than 220 pounds /25 gallons • SQG – 220 and 2,200 pounds / 25-250 gallons • LQG –greater than 2,200 pounds / 250 gallons <½ of a 55-G Drum > 4, 55-G Drums October 28, 2011 | 3

  4. Requirements for ALL Generators • Perform waste determinations • Ensure and document proper disposal • Keep records for at least 3 years October 28, 2011 | 4

  5. What do Hazardous Waste Inspectors Look at or for: • Process and procedures • Chemicals and wastes October 28, 2011 | 5

  6. Waste Determination • Failure to perform hazardous waste determination and/or • Failure to perform a proper waste determination October 28, 2011 | 6

  7. Notification of HW Activity • Failure to notify/obtain an EPA ID number • Failure to use the correct EPA ID number October 28, 2011 | 7

  8. Labeling • Failure to label containers with the words “Hazardous Waste” • Failure to label satellite accumulation containers with a description of the contents • Failure to label each container according to DOT regulations, prior to shipment October 28, 2011 | 8

  9. Accumulation • Storing beyond the 180 (SQG) or 90-day (LQG) limit • Not marking containers with accumulation start dates • Accumulation quantities over the limit on site October 28, 2011 | 9

  10. Container Management • Drums or containers that are open, rusting or bulging • Failure to conduct and document weekly inspections of all accumulating containers • Storing ignitable waste within 50 feet of property line • Failure to maintain aisle space between containers October 28, 2011 | 10

  11. Record Keeping • Failure to maintain uniform manifests or contractual agreements for 3 years • Failure to retain records of test results, waste analyses, or waste profiles Hazardous Waste Records Waste Manifests Test Results October 28, 2011 | 11

  12. Personnel Training • Failure to conduct training • Inadequate training to cover all areas of HW management • Inadequate training to cover job responsibilities October 28, 2011 | 12

  13. Preparedness and Prevention • No arrangements with local authorities • Arrangements not documented when made • Failure to have the proper equipment or posted information • Failure to maintain and operate facility to minimize unplanned or sudden release October 28, 2011 | 13

  14. Contingency Plan and Emergency Procedures • Failure to have a modified/full Contingency Plan • Incomplete or outdated contact information • Incomplete incident reporting • Failure to report emergency incident (assuming release to the environment) • Failure of SQG to post information by telephone October 28, 2011 | 14

  15. Land Disposal Restrictions • Florida has no hazardous waste landfills • All hazardous waste is prohibited from land disposal in our state • Land disposal records must be retained with uniform manifests • Certification that wastes meet standards, or • Notification that waste do not meet standards for land disposal in a haz waste landfill October 28, 2011 | 15

  16. The Process • In-Compliance • Out-of-Compliance October 28, 2011 | 16

  17. Compliance • In-Compliance • Inspection Report • Pictures • Letter acknowledging compliant status with Inspection Report October 28, 2011 | 17

  18. Non-Compliance • Non-Compliance or Warning Letter • Inspection Report • Pictures • Violations • Penalties • Informal Conference • Chance to respond • Discuss violations • Consent Order • Formal agreement to resolve issues DEP October 28, 2011

  19. EPA’s Role • RCRA program delegated to FDEP in our state • RCRA = federal act establishing HW rules • FDEP rules adopt 40 CFR • FDEP has 360 days from inspection date to settle a case • EPA requires penalties for certain violations October 28, 2011 | 19

  20. Disclaimer • District regulatory variations • May interpret regulation applicability differently • Develop a relationship and line of communication with your District HW Staff October 28, 2011 | 20

  21. FDEP District and Tallahassee Contacts • @dep.state.fl.us: • Karen.Bayly@ / 239-344-5616 - South • James.Byer@ / 850-595-0573 - NW • James.Dregne@ / 813-632-7600 (ext. 410) – SW • Karen.E.Kantor@ / 561-681-6670 – SE • Janine.Kraemer@ / 407-897-4303 – Central • Vicki.Valade@ / 904-256-1669 – NE • Glen.Perrigan@ / 850-245-8749 – Headquarters! October 28, 2011 | 21

  22. Take the Test HW inspectors look at or for: • Processes • Procedures • Chemicals • Wastes or… • All of the above! October 28, 2011 | 22

  23. Testing, Testing, Testing... • Determinations to identify hazardous waste may be inadequate: T or F • A notification of hazardous waste activity must be submitted to Tallahassee (SQG and LQG): T or F • Only full containers must be labeled and dated: T or F • Only full containers must be inspected weekly: T or F • Records have a 3-year retention minimum: T or F • Hazwoper or Hazmat training can substitute for Haz Waste training: T or F • Preparedness/prevention measures must be posted and documented: T or F October 28, 2011 | 23

  24. Discussion Debby Valin, Central District P2 and Compliance Assistance 321-229-8931 debby.valin@dep.state.fl.us http://www.dep.state.fl.us/central/Home/P2/default.htm http://www.dep.state.fl.us/waste/categories/hwRegulation/default.htm

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