Florida Department of Environmental Protection October 28, 2011 | 1 What to Expect from a Hazardous Waste Inspection Central District Debby 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 Classes Based on generation rate in any given month: CESQG – less than 220 pounds /25 gallons SQG – 220 and 2,200 pounds / gallons LQG –greater than 2,200 pounds / 250 gallons October 28, 2011 | 3 <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 October 28, 2011 | 4

What do Hazardous Waste Inspectors Look at or for: Process and procedures Chemicals and wastes October 28, 2011 | 5

Waste Determination Failure to perform hazardous waste determination and/or Failure to perform a proper waste determination October 28, 2011 | 6

Notification of HW Activity Failure to notify/obtain an EPA ID number Failure to use the correct EPA ID number October 28, 2011 | 7

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 October 28, 2011 | 8

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 October 28, 2011 | 9

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 October 28, 2011 | 10

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 Hazardous Waste 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 October 28, 2011 | 12

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 October 28, 2011 | 13

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 October 28, 2011 | 14

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 October 28, 2011 | 15

The Process In-Compliance Out-of-Compliance October 28, 2011 | 16

Compliance In-Compliance Inspection Report Pictures Letter acknowledging compliant status with Inspection Report October 28, 2011 | 17

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

EPAs 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 October 28, 2011 | 20

FDEP District and Tallahassee / South / NW / (ext. 410) – SW / – SE / – Central / – NE / – Headquarters! October 28, 2011 | 21

Take the Test HW inspectors look at or for: 1.Processes 2.Procedures 3.Chemicals 4.Wastes or… 5.All of the above! October 28, 2011 | 22

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