Hazardous & Non-Hazardous Wastes
HAZARDOUS WASTE COMPLIANCE
Admiral’s staff has considerable experience helping clients comply with hazardous waste requirements. The U.S. Environmental Protection Agency (USEPA) vigorously enforces hazardous waste rules and assesses fines for violations that can reach several hundred thousand dollars. The Illinois EPA also inspects and enforces the regulations, but not as vigorously.
If your facility is inspected by the USEPA, Admiral’s staff can help you achieve compliance quickly while satisfying the agency’s typically rigorous information requests. Prompt action on your part can work to reduce the final enforcement action and fine. We often see cases where a company thought they could handle the information requests, but actually made the situation worse. For those cases where the possible enforcement action is significant, our experienced staff can advise you through the process (with your attorney if appropriate).
WASTE DETERMINATION - Our experienced staff can identify and prepare the required Waste Determination to document the rationale for hazardous waste or nonhazardous waste decisions and applicable waste codes.
HAZARDOUS WASTE GENERATOR STATUS
Knowing your generator status - large, small, conditionally exempt - and being familiar with hazardous waste regulations can guard you from receiving violations and fines resulting from a USEPA 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 Hazardous Waste On-Site Accumulation Time Limits)
- 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.
HAZARDOUS WASTE ON-SITE ACCUMULATION TIME LIMITS
Depending on a facility’s hazardous waste generator status, specific time limits will apply to how long hazardous waste can be accumulated on-site before it must be removed (i.e., properly hauled away with requisite, corresponding documentation).
Hazardous Waste On-Site Accumulation Time Limits
- Large quantity generator: No Longer than 90 days
- Small quantity generator: No Longer than 180 days
- Conditionally exempt small quantity generators: No Time Limit
There are some exceptions to the above time limits. Please call us for more information. If your facility has a tank that stores hazardous waste, there are many additional requirements that may apply. The USEPA 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 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.
LARGE QUANTITY GENERATOR COMPLIANCE
Large Quantity Generators (LQG) of hazardous waste – facilities that generate more than 2,200 pounds of hazardous waste during any one month in the year, or more than 2.2 pounds of acutely hazardous wastes during any one month.
These facilities must comply with many requirements, notably:
- Submittal of Generator Hazardous Waste Report ( an annual requirement in Illinois and Wisconsin). Due March 1 for the previous calendar year.
- Have a Contingency Plan for Hazardous Wastes
- Have written job descriptions for hazardous waste handlers
- Maintain inspection records for hazardous waste storage areas
- Perform annual training for hazardous waste handlers
If you are not sure if you will be a Large Quantity Generator for the year, I suggest you send us your past 12 months of hazardous waste manifests to review your status.
Please note that if a company has a tank for hazardous wastes, there are rigorous requirements that need expert assistance and certification by a licensed Professional Engineer.
As always, our experienced staff is available to prepare these reports for you and/or determine if your facility falls into this category. We suggest you get an early start on this work. The reports are required even if you do not receive the forms from the state. Illinois EPA does not mail Report forms, and expects filings to be done with their software.
RCRA AIR EMISSIONS MONITORING
Some Large Quantity Generators are required to monthly monitor for volatile organic compound emissions from their hazardous waste tanks and containers. The regulations are found in 40CFR Part 265, Subparts AA, BB, and CC.
Admiral can assess your compliance situation and perform the monthly air monitoring using Method 21 - Determination of Volatile Organic Compound Leaks. We have the necessary field instruments, Thermo TVA-1000B with FID detector.
For more information, the following EPA presentation provides an overview of the regulations:
NON-HAZARDOUS / SPECIAL WASTE COMPLIANCE
In Illinois there are unique regulations covering Special Wastes, that regulate nearly all non-hazardous waste materials from industrial operations. As a team of experts that exclusively focuses on Illinois environmental compliance regulations, Admiral can help you comply with these Special Waste rules.
NONSPECIAL WASTE CERTIFICATION - In many cases Illinois EPA allows for an exemption from the Special Waste requirements. We can prepare the necessary NonSpecial Waste Certification to take advantage of this program.
SPECIAL WASTE REPORTING & LIQUID WASTE REPORTING
Starting with the 2012 reporting year, the Illinois EPA no longer requires the Annual Non-Hazardous Waste report.
The City of Chicago also requires an annual waste report called the Chicago Liquid Waste Annual Fee. If your facility is located in the City of Chicago and disposed of any liquid wastes (hazardous or nonhazardous) then you are required to pay a fee based on the amount sent out. This report is due January 31 of each year.
The following is the Chicago liquid waste form:
The following are the forms for Illinois EPA waste reports: