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

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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

October 28, 2011 | 19

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

October 28, 2011 | 23

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