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Hazardous Waste Inspections

Hazardous Waste Inspections. What to Expect!. Penny J. Wilson Inspector Supervisor Hazardous Waste Division. When the Inspector Arrives. The Inspector will provide: Official ADEQ Identification Card Reason for the Inspection Routine Complaint. Opening Conference.

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Hazardous Waste Inspections

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  1. Hazardous Waste Inspections What to Expect! Penny J. Wilson Inspector Supervisor Hazardous Waste Division

  2. When the Inspector Arrives • The Inspector will provide: • Official ADEQ Identification Card • Reason for the Inspection • Routine • Complaint

  3. Opening Conference • Discuss the Scope of the Inspection • Facility Tour • Manufacturing Processes • Generation Areas • Waste Management Areas • Records Review • Manifests • Inspection Records • Training Documents

  4. Facility Tour The inspector will… • Look at your manufacturing processes from A to Z • Process Flow • Evaluate ALL waste streams • Points of generation

  5. Satellite Accumulation Areas • Is the SAA at or near the point of generation? AND • Under the control of the operator? • Is the container in each SAA… • In good condition? • Marked “Hazardous Waste” or other words to describe the contents? • Closed? • Has the amount exceeded 55-gallons?

  6. <90/180 Day Accumulation Areas • Are containers… • Labeled “Hazardous Waste”? • Marked with the accumulation start date? • In good condition? • Closed? • Located at least 50 feet from property line (if ignitable or reactive and an LQG)? • Incompatible waste separated? • Adequate aisle space? • Has the waste been shipped off-site within 90 days (LQG) or 180 days (SQG)?

  7. Tanks • Labeled “Hazardous Waste” • Engineering Assessment • Secondary Containment • Free of Cracks & Gaps • Methods to Prevent Overflows

  8. Universal Waste • Types of Universal Waste Generated • Most Common… • Batteries • Lamps • E-Waste • General Management • Labeling/Marking • Accumulation Time Limits

  9. Records Review • Manifests (3 years)/LDR Notifications • Waste Profiles • Annual Reports • Training Records (LQG) • Contingency Plan (LQG) • Container Inspection Records • Tank Inspection Records

  10. Closing Conference • Discuss concerns noted • Findings are preliminary • Will conduct a more thorough review of information gathered • Answer any questions

  11. Report Process • Inspection report includes • Description of the facility operations • Waste streams generated • Description of violations noted • Conclusion with list of violations • Significant • Secondary • Routed through Supervisor, Branch Manager, and Chief

  12. Next Steps • For Secondary Violations • Respond within 30 days of receipt with documentation to show steps taken to return to compliance • Include copies of documents, photographs, etc. • If response is adequate, a “correction” letter will be sent

  13. Next Steps • For Significant Non-Compliance • Report is forwarded to Enforcement • Respond within 30 days of receipt with documentation to show steps taken to return to compliance • Include copies of documents, photographs, etc.

  14. Next Steps • Enforcement will draft a Consent Administrative Order (CAO) • Will include: • Findings of Fact • Will include description of issues observed during inspection; steps taken to return to compliance • Order and Agreement • Will include any additional actions to take to return to compliance; civil penalty

  15. Common Violations • Waste Identification • Preparedness & Prevention • Container Management • Generator Accumulation • Universal Waste Management

  16. Waste Identification • Not identifying waste streams • Incorrectly identifying waste • Not including ALL waste codes • Not identifying UHCs

  17. Preparedness & Prevention • Failure to maintain & operate to minimize releases, fires, & explosions

  18. Preparedness & Prevention • Aisle Space

  19. Preparedness & Prevention • Aisle Space

  20. Preparedness & Prevention • APC&EC Regulation No. 23 Section 265.35: Aisle space must be maintained to allow the unobstructed movement of personnel, fire protection equipment, and decontamination equipment to any area of facility operations in an emergency.

  21. Container Management • Poor Condition

  22. Container Management • Open Containers

  23. Container Management • Open Container

  24. Generator Accumulation • No Labels or Dates

  25. Universal Waste Management • General Management • Are the items contained? • Have there been releases?

  26. Universal Waste Management • Is the container Labeled/Marked? • Is the container closed?

  27. Issues we come across during inspections that could result in non-compliance

  28. Distillation Units • Most common method used to “recycle” spent solvents

  29. Example of Distillation Unit

  30. Example of Distillation Unit

  31. Management Prior to Recycling • If using a batch process…the solvent must be managed as a Hazardous Waste prior to recycling! • Labeled as Hazardous Waste • Dated • Closed • In good condition • Inspected

  32. After Recycling • Once the solvent is recycled…it is now considered a product. • Still bottoms (solids removed during the distillation process) • Must be identified…is it also a hazardous waste? If yes…When removed from the distillation unit,: • Labeled • Dated • Closed • In good condition • Inspected

  33. How Do You Count the Waste? • Only count the spent solvent one time each calendar month • Hazardous Waste still bottoms should not be counted toward your generator status! • They are initially counted with the spent solvent

  34. Why Recycle Spent Solvents? • Could reduce your need to purchase virgin products; • Could reduce your generator status; • Will reduce the amount of waste you ship off-site for disposal

  35. Questions Penny J. Wilson wilson@adeq.state.ar.us 501-682-0868

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