Hazardous Waste Compliance

Knowing your generator status and being familiar with hazardous waste regulations can guard you from receiving violations and fines resulting from an EPA hazardous waste inspection. Not only can you avoid the headache and financial burden of receiving a violation, but you will also be protecting your company name.

The following violations are often identified by agency inspectors:

• Labels on drums or tanks do not have a start date. The inspector will then assume that the accumulation time was more than 90 days.
• Accumulating a hazardous waste longer than allowed. (See Accumulation Time Limits below for details)
• Drums are not properly closed at all times. This also applies to drums that are not full.
• Accumulating more than 55 gallons at a satellite accumulation point.
• Not having an adequate hazardous waste contingency plan.
• No records of training the employees that handle hazardous waste.
• No records of weekly inspections of hazardous waste storage areas.
• Drums are not properly labeled as Hazardous Waste or as Used Oil.

Accumulation Time Limits

• 90 days for a large quantity generator.
• 180 days for a small quantity generator.
• No time limit for conditionally exempt small quantity generators.
  
  There are some exceptions to these time limits. Please call us for more information.

If your facility has a tank that stores hazardous waste, there are many requirements that apply. The U.S. EPA has recently been particularly tough on this issue.

When a company exceeds the waste accumulation time, then they are also cited for not having a hazardous waste storage permit. This can be expensive to resolve, because it necessitates preparing a detailed closure plan, and often sampling and cleaning the storage areas. The sampling may then identify bigger contamination problems.

Admiral Environmental Services can help you take the guess work out of your hazardous waste program. Call us for an inspection of your waste handling procedures. Our experienced professionals will review your waste generation and management activities and let you know if there are any areas that need improvement. You can also contact me by email.

Philip A. Twomey, PE