1. David Mann Waste Section Manager Waco & Austin Region Offices

2.  Updates on Waste Compliance  Solvent Contaminated Wipes  Generator Regulations  Dave’s Top 10 RCRA Violations

3.  Solvent Contaminated Wipes may be exempted from definition of solid waste under certain conditions (40 CFR 261.4(b)(18)  reusable wipes: exempt from solid waste  disposable wipes: exempt from hazardous waste  trichloroethylene (TCE) wipes are ineligible

4.  Storage Requirements non-leaking, closed containers  Labeling Containers must be labeled “Excluded Solvent-Contaminated Wipes.”  Accumulation Time Limits containers must be dated and disposed within 180 days  Recordkeeping Generators must maintain documentation that includes: ○ name and address of the laundry, dry cleaner, landfill, or combustor; ○ documentation that the 180-day accumulation time limit is being met; and ○ description of the process the generator is using to meet the “no free liquids” condition

5.  EPA proposed significant rule changes to the hazardous waste generator regulations on August 31, 2015 Consolidation of Generator regulations to Part 262 reduce cross-references to Parts 261, 265, and 268  VSQGs replace CESQGs monthly quantity limits that define each generator category would be clarified VSQGs would be allowed to send hazardous waste to an offsite LQG (if both facilities are under the control of the same person).  Episodic Generation VSQGs and SQGs maintain their existing generator category if certain conditions are met

6.  Satellite containers and 90/180-day accumulation tanks, containers, containment buildings, and drip pads would be subject to additional requirements.  Preparedness, prevention, and emergency procedures for SQGs and LQGs would be clarified and strengthened.  Closure requirements for LQG waste management units would be expanded.ž  Pharmaceutical waste rules would be overhauled and replaced in a new section of rules CFR 266

7. 1. Waste determinations & classifications 2. Failure to Update the Notice of Registration (NOR) 3. Container management 4. Inspections (container storage areas, tanks, etc.) 5. Marking/Dating containers 6. Emergency Preparedness/Prevention 7. Personnel Training 8. Universal Waste Management 9. Used Oil 10. Annual Waste Summaries

8. 1. Accumulation Time 2. Posting of Information by the Telephone by SQG’s 3. Satellite area waste not stored at or near the point of generation 4. Moving hazardous waste between satellite areas

10.  Documentation of all waste streams is required Hazardous, Class 1, Class 2, Class 3, etc.  Forgotten/Missed waste streams Examples: absorbents, rags, waste gasoline, spent antifreeze, sandblast media, filters, wastewater treated in evaporators, expired products, office and plant trash, light bulbs, batteries, paint cans, etc.

11.  Incomplete determinations Include all hazardous waste codes (e.g., D008, F003) Include all underlying hazardous characteristics Include description of the process generating the waste and potential contaminants We generally don’t complain about “overclassification”

12.  Process Knowledge ( 30 TAC 335.511) Must be documented! Best used for what a waste isn’t!

13.  Documentation (30 TAC 335.513) MSDS/SDS alone is not adequate

14.  Container inspections ~ weekly 90 or 180 day storage areas Records not required, but recommended  Tanks ~ daily

15.  Did not provide adequate training No training at all Certain personnel not trained Lack of annual refresher training  Inadequate Training documentation List of names/job titles for required employees Job descriptions missing or inadequate No written description of training program Incomplete training records

16.  Content of contingency plan Requires inclusion of specific information in 40 CFR 265.52  Examples: procedures for fires, spills and explosions, emergency coordinator info; changes in personnel; primary & secondary evacuation routes; list, map & capabilities of emergency equipment, etc. Lack of emergency coordinator  Personnel changes, lack of training

17.  Inadequate coordination with local authorities (40 CFR 265.37) Must familiarize PD, FD, hospital, emergency response authorities with facility information and types of waste  Failed to send a copy of contingency plan to local authorities (40 CFR 265.53)

18.  Emergency info posted next to on-site phone Contingency plan not required

19.  Open containers 90 or 180 day accumulation areas  Satellite accumulation area (SAA) Open bungs, or funnels “under the control of the operator” “at or near the point of generation”

20.  Inadequate aisle space  Incompatible wastes stored together Must be separated by a structure or device

23.  Hazardous Waste Containers i n Storage “Hazardous Waste” label or marking Accumulation Start Date

24.  Satellite C ontainers “Hazardous Waste” label or other words which identify the contents Accumulation Date not required

25.  “Complete & Correct” (30 TAC 335.9)  Incorrect waste totals reported Poor records/illegible manifests  Missing waste streams (Haz & Class 1) disposed but not reported Often misclassified as a Class 2/3  Confusion between generated and handled waste totals may vary due to carryover between years

26.  Satellite containers are dated when exceed quantity limits 55 gal. or 1 qt. acutely hazardous Moved to 90-day or 180 day storage area within 3 days  Container storage areas 90 days = LQG 180 days = SQG 270 days if waste is being transported > 200 miles

27.  Containers or tanks not marked, “Used Oil” Improperly marked (e.g., “Waste Oil”) Determination of Total Halogen Content (279.10)  Didn’t test, forgot to document generator knowledge Releases/spills to ground

29.  Universal waste = hazardous waste, but with less restrictions  Batteries  Hazardous lamps (not green-tips)  Mercury-containing equipment  Pesticides  Paint (not latex)

30.  Disposal is prohibited!!  Improper marking Not marked; or improper wording on label  Improper storage Open containers; or no containers  Accumulation limits Must be dated Limit for small quantity handlers = 1 year  Lamp Crushers require TCEQ approval

31.  Required for LQG’s, SQG’s also CESQG’s who generate >220 lbs./month of industrial Class 1 waste (30 TAC 335.6(c))  Generator must update the Notice of Registration (NOR) any time the information changes  Submit changes within 90 days of change

32.  Common issues: Waste streams added or discontinued  even Plant Trash must be listed! Contact information obsolete Waste management units missing  even Class 2 dumpsters count! Haz waste codes not associated to wastes (D008, F003, etc.) Wastes not associated to waste management units Change in ownership Change in generator status (LQG, SQG, CESQG)

33.  Incorrect waste totals reported ○ Poor records/illegible manifests  Missing waste streams (Haz & Class 1) ○ disposed but not reported  Confusion between generated and handled waste ○ totals may vary due to carryover between years

34.  Follow up on inspection findings ASAP!  Periodic reviews of IHW compliance program  Frequent staff meetings  Perform audits Hire consultant Periodic self-audits (TCEQ checklists available: Go to https://www.tceq.texas.gov/assistance/c2/CklstIndex.html https://www.tceq.texas.gov/assistance/c2/CklstIndex.html  “Clean sweeps” to find and get rid of old chemicals and contraband materials

35.  Events that tend to have an effect on your compliance  Examples: New hires/personnel changes New wastes, processes or raw materials Changes in waste storage locations Changes in waste handling (e.g., switch from disposal to recycling) Changes in waste generation amounts (generator status) Remediation/cleanup activities/spills

36.  Self-evaluation is key  “An ounce of prevention is worth a pound of cure”  Mind the details

37.  TCEQ Website : http://www.tceq.state.tx.us/ http://www.tceq.state.tx.us/  STEERS help line 512-239-6925  TCEQ phone numbers: Waste Permits: 512-239-5176 Small Business & Local Govt. Assistance: 1-800-447-2827  EPA Region 6 Website: http://www2.epa.gov/aboutepa/epa-region-6-south- central http://www2.epa.gov/aboutepa/epa-region-6-south- central