Top 10 Most Common Non-compliance Issues Large Quantity Generators November 2, 2011.

Slides:



Advertisements
Similar presentations
Annual RCRA Hazardous Waste Training Program
Advertisements

Florida Department of Environmental Protection October 28, 2011 | 1 What to Expect from a Hazardous Waste Inspection Central District Debby Valin, Environmental.
Universal Waste Management Training
Handling and Disposal of Universal Waste
Hazardous Waste Section
Surviving compliance inspections aka the mock inspection presentation.
What to look for, What to correct, How it should look,
Jim Rudeen Waste Reduction, Compliance and Enforcement Section Chief KDHE, Bureau of Waste Management
Universal Waste Management Training. Introduction DEC and EPA have established standards for the handling of “Universal Wastes”. “Universal Wastes”, in.
1 Joint Commission for Environmental Cooperation and U.S./Mexico Border 2012 Collection and Storage of SLABs December 4, 2007.
Environmental Health and Safety Oklahoma State University Hazard Communication Your “Right to Know”
OURAY Environmental Services, LLC
Resource Conservation and Recovery Act.
Hazardous Waste Issues Associated with Municipal Operations Dan Sowry Environmental Specialist Office of Compliance Assistance and Pollution Prevention.
May What is a Hazardous Waste?—Hazardous wastes include discarded chemicals, reagents, oil paints and thinners, unusable chemicals, unidentified.
Safety Manager Breakfast September 21, Agenda Environmental Audit Building Emergency Planning Fire Safety and Security Plans Emergency Generators.
Laboratory Accumulation of Hazardous Waste Presented By: Richard Smith Environmental Health & Safety Administrative Office Research and Extension Centers.
Hazardous Waste Initial Training Environmental Health, Safety and Risk Management June 2010.
DEVELOPING A FACILITY INSPECTION PROGRAM Or How To Make Sure The Facility You Inspect is Operating Successfully Morson Environmental Consulting, Inc.
Hazardous Waste Management
1 Hazardous Waste Storage 2 Environmental Health Requirements “Store the waste in a manner that does not threaten human health or the environment.”
STEP 3 Waste Accumulation And On-Site Management.
The Sentinel Event During a routine annual hazardous waste management inspection by the Hazardous Waste Section of NC DENR, violations in laboratory practices.
Hospital Waste and the RCRA Regulations - An Inspector’s Viewpoint Paul King Principal Environmental Specialist Bur. of Hazardous Waste Compliance & Enforcement.
What is RCRA? The Resource Conservation and Recovery Act (RCRA) was passed in 1976 as an amendment to the Solid Waste Disposal Act. Amendments were added.
Permitting, Fees, and Reports Cal Poly Lecture Tour Ron Scholtz Analog Devices, Inc.
SQGs and CESQGs California subtitle: Facilities that generate not more than 1000 kg/month and facilities that generate not more than 100 kg/month.
Preparing for a Multi-Media Inspection at your Medical Facility John Gorman EPA Region 2 What to expect when an EPA Inspector.
HEALTH AND SAFETY. RIGHT TO KNOW LAW Hazard Communication Act of 1983 Places some responsibility on Employer Places some responsibility on Employee.
RCRA 101 Michael Gage New Jersey Department of Environmental Protection County Environmental and Waste Enforcement Special Investigations and Oversight.
1 RCRA Providence VAMC Hazardous Waste Management Program Research Lab Hazardous Waste Training 2008.
UNIVERSAL WASTE SAFETY TRAINING CLASS. AGENDA Identifying Universal Waste Identifying Universal Waste Universal Waste Handlers Universal Waste Handlers.
OMNI FACILITY SERVICES Copyright  Progressive Business Publications Handling Hazardous Wastes.
Session IV Chemical Storage Signage Chemical Inventory Physical Storage Storage Room Environment Waste Management Material Safety Data Sheets.
HAZARDOUS WASTE MANAGEMENT Columbia Basin College.
Region 2 Healthcare Compliance Initiative 1 Region 2's Healthcare Compliance Initiative: Environmental Results From An Integrated Strategy Leveraging Limited.
BASIC AUTO HAZARDOUS REGULATIONS. WASTE STREAMS RIGHT TO KNOW LAW n Hazard Communication Act of 1983 n Places some responsibility on Employer n Places.
Hazardous Waste Training SQGs are required to perform training for all employees who are involved with hazardous waste. Involvement includes: Handling.
Hazardous Waste Management 1 / 61 © Copyright Training 4 Today 2000 Published by EnviroWin Software LLC. WELCOME HAZARDOUS WASTE MANAGEMENT CUSTOMIZED.
Hazardous Waste Storage
Joseph G. Maternowski Moss & Barnett, P.A. Minnesota Environmental Institute April 21, 2011 Minneapolis, Minnesota.
1 Hazardous Waste Management New England Marina Meeting March 30, 2006 U.S. Environmental Protection Agency (EPA) Agency (EPA) Region 1 New England Region.
Who Wants to Be a Millionaire? $1,000,000 $250,000 $125,000 $64,000 $32,000 $16,000 $8,000 $1,000.
Managing Hazardous Chemical Waste. What is Hazardous Waste EPA Definition: A material is a hazardous waste if due to its quantity, concentration, physical,
Hazardous Waste Container Management. Are Containers in Good Condition? Some issues here Appropriate.
Copyright  Progressive Business Publications Handling Hazardous Wastes.
Consulate Emergency Response/Contingency Plan Training Topic 4
Hazardous Waste Rule Amendments ___________________________ Training Dec. 2, 2015.
LQG Top 10 Violations Compliance Assurance Northeast District January 15, 2016.
Copyright J. J. Keller & Associates, Inc. Content may be modified by subscriber per KellerOnline ® service Terms of Use. Hazardous Waste.
David Mann Waste Section Manager Waco & Austin Region Offices.
Hazardous Waste Handling Certification Hazardous Waste Handling Certification San Joaquin Delta College Revised: 09/25/13.
Hazardous Waste Handling Certification San Joaquin Delta College Revised: 04/01/16.
Common Hazardous Waste Generator Violations (and How to Avoid Them)
Hazardous Waste Disposal of hazardous waste is regulated by the EPA under Resource Conservation and Recovery Act (RCRA) 40 CFR Section 261 CSP is classified.
Before You Start Persons packing material for shipment should have 6-hr DOT Hazmat Awareness training in addition to HAZWOPER certification. Check with.
Safe Handling of Storage Containers :
Lecture (13): Hazardous Waste Management
Lecture No (10) Topic No (1): Hazardous waste conservation , storage and transportation
Advanced Environmental Management (AEM) Training Phase I
The Sentinel Event During a routine annual hazardous waste management inspection by the Hazardous Waste Section of NC DENR, violations in laboratory practices.
CIHQ - All Rights Reserved 2017
Maintenance of DOT Regulated Valves
EXSO Meeting ad hall (chemical storage etc.)
Hazardous Waste Handling Certification
Hazardous Waste Generator Improvements Rule
Hazardous Waste Disposal of hazardous waste is regulated by the EPA under Resource Conservation and Recovery Act (RCRA) 40 CFR Section 261 CSP is classified.
Labeling Requirements
Hazardous Waste Handling Certification
What is driving this change????
Presentation transcript:

Top 10 Most Common Non-compliance Issues Large Quantity Generators November 2, 2011

10. Biennial Report 40 CFR Due by March 1 of each even numbered year Covers generator activities from previous year Form can be found on the FDEP website November 2, 2011

9. Manifests 40 CFR Incorrect EPA ID No. used Incorrect waste codes used Untrained personnel signing Receive and retain final copy for at least 3 years November 2, 2011

8. Position Descriptions 40 CFR (d) Missing training requirements Missing RCRA responsibilities November 2, 2011

7. Contingency Plan 40 CFR 265 Subpart D Update emergency coordinator Emergency response times Update chemical inventory and locations November 2, 2011

Plater - Response to a Fire November 2, 2011

Response to a Fire November 2, 2011

One Spill Leads to Another November 2, 2011

One Spill Leads to Another November 2, 2011

6. Training 40 CFR Not receiving annually Not documented “Right to Know” is NOT RCRA training November 2, 2011

5. Open Containers/Releases 40 CFR / Funnels (without gaskets – open) Unsecured bungs or rings Used oil releases (40 CFR (d)) Hazardous waste releases Expired/old/failed product containers November 2, 2011

Open Cubic Yard Box November 2, 2011

Open 55-Gallon Drum November 2, 2011

Open 55-Gallon Drum November 2, 2011

Funnel with Gasket and Clamps November 2, 2011

Open 55-Gallon Drum November 2, 2011

Open 55-Gallon Drum November 2, 2011

Open Cubic Yard Box November 2, 2011

Open Satellite Accumulation Container November 2, 2011

Open Satellite Accumulation Container November 2, 2011

Open Satellite Accumulation Drum November 2, 2011

Closed Satellite Accumulation Drum November 2, 2011

Release of Resin on Ground November 2, 2011

Release of Unknown Chemical on Ground November 2, 2011

Release of Used Lubricant November 2, 2011

Very old/failed Product Container November 2, 2011

Failed Product Container November 2, 2011

Failing Container November 2, 2011

4. Weekly Inspections 40 CFR / (6), F.A.C. Untrained inspector Required information missing Date, time Printed name of inspector Number and condition of containers Observations Repairs or remedial actions November 2, 2011

WEEKLY INSPECTION LOG Inspector:Date:Time: Clearly Print Name Accumulation Area Inspected: Number of Containers: Are all containers in good condition?YesNo Is there any evidence of leaks or spills? YesNo Are all containers labeled “Hazardous Waste”? YesNo Are all containers marked with an accumulation start date? YesNo Are all containers closed? YesNo Is there adequate aisle space between rows of drums? YesNo Is spill control equipment available?YesNo Observations: (If containers in poor condition or leaks/spills were found, please note action taken in area below) Repairs or Remedial ActionDate Weekly Inspections

3. Accumulation Start Date 40 CFR (a)(2) Satellite accumulation areas Storing over 90 days 40 CFR (b) Changing date after adding additional waste November 2, 2011

No Accumulation Start Date November 2, 2011

Accumulation Start Date of 1/20 November 2, 2011

No Accumulation Start Date November 2, 2011

No Accumulation Start Date November 2, 2011

Accumulation Start Date Unreadable November 2, 2011

Two Satellite Accumulation Drums November 2, 2011

Two Satellite Accumulation Drums November 2, 2011

Six Satellite Accumulation Drums November 2, 2011

Two Satellite Accumulation Drums November 2, 2011

2. Labeling Containers 40 CFR (a)(3) Satellite accumulation areas Not properly labeled Used oil and used oil filter labeling All containers should be labeled Products Working containers Etc. November 2, 2011

Unlabeled Drums November 2, 2011

Unlabeled Drums November 2, 2011

Satellite to Satellite Accumulation Containers November 2, 2011

Properly Labeled 15-Gallon Drum Unlabeled 5-Gallon Container November 2, 2011

Unlabeled Mercury Bulb Crusher November 2, 2011

Universal Waste Management November 2, 2011

Labeled Correctly? November 2, 2011

Well, at least we know… November 2, 2011

Proper Label November 2, 2011

Properly Labeled Drums November 2, 2011

Properly Labeled Drum November 2, 2011

Unlabeled Used Coolant Drums November 2, 2011

Oil/Water Separator Bucket Properly Labeled November 2, 2011

Properly Labeled Used Oil Filters Drum? November 2, 2011

1. Waste Determination 40 CFR Know all your waste streams Generator knowledge Analytical testing Process changes, i.e. new ingredient Need additional testing November 2, 2011

Mystery Drums November 2, 2011

Evaporating Waste November 2, 2011

Unknown evaporated waste November 2, 2011

Unknown Sludge Waste November 2, 2011

Unknown liquid November 2, 2011

Mystery Drums November 2, 2011

Is Sludge a Hazardous Waste? November 2, 2011

Proper Waste Determination? November 2, 2011

Safety First! November 2, 2011