Post on 26-Mar-2015
transcript
Florida Department of Environmental Protection
October 28, 2011 | 1
What to Expect from a
Hazardous Waste Inspection
Central DistrictDebby 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
October 28, 2011 | 2
Generator ClassesBased 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
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<½ of a 55-G Drum > 4, 55-G Drums
Requirements for ALL Generators
• Perform waste determinations
• Ensure and document proper disposal
• Keep records for at least 3 years
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What do Hazardous Waste Inspectors Look at or for:
• Process and procedures
• Chemicals and wastes
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Waste Determination• Failure to perform hazardous waste
determination and/or • Failure to perform a proper waste
determination
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Notification of HW Activity
• Failure to notify/obtain an EPA ID number
• Failure to use the correct EPA ID number
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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
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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
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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
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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
October 28, 2011 | 11
HazardousWaste
Records
Test Results
Waste Manifests
Personnel Training• Failure to conduct training• Inadequate training to cover all areas
of HW management• Inadequate training to cover job
responsibilities
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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
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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
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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
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The Process
• In-Compliance
• Out-of-Compliance
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Compliance
• In-Compliance• Inspection Report• Pictures• Letter acknowledging compliant status
with Inspection Report
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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
October 28, 2011
DEP
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
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Disclaimer
• District regulatory variations• May interpret regulation applicability
differently• Develop a relationship and line of
communication with your District HW Staff
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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!
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Take the Test
HW inspectors look at or for:1.Processes2.Procedures3.Chemicals4.Wastes or…5.All of the above!
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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
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Florida Department of Environmental Protection
October 28, 2011 | 24
Discussion
Debby Valin, Central District
P2 and Compliance Assistance
321-229-8931
debby.valin@dep.state.fl.ushttp://www.dep.state.fl.us/central/Home/P2/default.htm
http://www.dep.state.fl.us/waste/categories/hwRegulation/default.htm