Waste-Related and Other Regulations in Pennsylvania

Size: px
Start display at page:

Download "Waste-Related and Other Regulations in Pennsylvania"

Transcription

1 Waste-Related and Other Regulations in Pennsylvania Prepared For CATALYST CONNECTION WEBINAR SERIES Presented By Civil & Environmental Consultants, Inc. Paul W. Tomiczek III, REM, P.E. Vice President David J. Larson Project Manager November 20, 2014

2 Introduction CEC is a Multi-Disciplinary Consulting & Engineering Firm 25 th Year in business in 2014 Consistently ranked highly among the Engineering News-Record s Top 200 Environmental Firms List and Top 500 Design Firms List Named a Top Workplace in Pittsburgh and Nashville

3 Introduction More Than 650 Employees in 19 Cities 1. Austin, TX 2. Bridgeport, WV 3. Boston, MA 4. Charlotte, NC 5. Chicago, IL 6. Cincinnati, OH 7. Columbus, OH 8. Detroit, MI 9. Export, PA 10. Indianapolis, IN 11. Knoxville, TN 12. Nashville, TN 13. Philadelphia, PA 14. Phoenix, AZ 15. Pittsburgh, PA 16. Sayre, PA 17. Sevierville, TN 18. St. Louis, MO 19. Toledo, OH

4 Introduction Our Service Areas The Clients We Serve Civil Engineering & Survey Environmental Engineering & Sciences Ecological Sciences Waste Management Water Resources Manufacturing Mining Natural Gas Power Public Sector Real Estate Solid Waste

5 Webinar Introduction This webinar will focus on waste-related issues and several other regulatory program areas. There are many state and federal regulations that may apply to a manufacturing facility. This webinar will review a selection of the regulations.

6 Agenda 1. Resource Conservation and Recovery Act (RCRA) regulations address hazardous waste identification procedures, recycling exemptions, universal wastes, used oils and waste oils, and generator requirements for labeling, accumulating, and manifesting wastes; 2. Pennsylvania Residual Waste regulations (Chapter 287) govern the management, disposal, and reporting of industrial wastes; 3. Preparedness, Prevention, and Contingency (PPC) Plan requirements are intended to help prevent the release of wastes or other chemicals and petroleum products that could result in contamination of groundwater and surface water, and prepare facilities to address accidental releases that may occur; 4. Emergency Planning and Community Right-to-Know Act (EPCRA) regulations cover the storage and use of most chemicals at industrial facilities when they exceed certain threshold values, including submittal of Tier II Chemical Inventory Reports and Toxic Release Inventory Forms; and 5. Toxic Substances Control Act (TSCA) regulations pertain to new chemical manufacturing and submitting Chemical Data Report (CDR) forms for the manufacture of chemicals above certain thresholds, as well as regulations related to the use of Polychlorinated Biphenyls (PCBs) at industrial sites.

7 RCRA - Hazardous Waste Identification Hazardous Waste Identification Process Proper hazardous waste identification is essential to the success of the RCRA program. This identification process can be a very complex task. Therefore, it is best to approach the issue by asking a series of questions in a step-wise manner. 1. Is the material in question a solid waste? 2. Is the material excluded from the definition of solid waste or hazardous waste? 3. Is the waste a listed or characteristic hazardous waste? 4. Is the waste delisted?

8 RCRA - Hazardous Waste Identification Is the Material a Solid Waste? Recycled Materials Secondary Materials Sham Recycling

9 RCRA - Hazardous Waste Identification Recycled Wastes May or May Not Be Solid Wastes

10 RCRA - Hazardous Waste Identification Is the Waste Excluded? Determining whether or not a waste is excluded or exempted from hazardous waste regulation is the second step in the RCRA hazardous waste identification process. There are five categories of exclusions: Solid Waste Exclusions Hazardous Waste Exclusions Raw Material, Product Storage, and Process Unit Waste Exclusions Sample and Treatability Study Exclusions Dredged Material Regulated under the Marine Protection Research and Sanctuaries Act or the Clean Water Act

11 RCRA - Hazardous Waste Identification Solid Waste Exclusions (Examples) Domestic Sewage and Mixtures of Domestic Sewage Industrial Wastewater Discharges (Point Source Discharges) Irrigation Return Flows Pulping Liquors Spent Sulfuric Acid Closed-Loop Recycling Certain Coke By-Product Wastes Processed Scrap Metal Shredded Circuit Boards Zinc Fertilizer from Recycled Hazardous Secondary Materials

12 RCRA - Hazardous Waste Identification Hazardous Waste Exclusions (Examples) Household Hazardous Waste Agricultural Waste Bevill and Bentsen Wastes Trivalent Chromium Wastes Used Oil Filters

13 RCRA - Hazardous Waste Identification Raw Material, Product Storage, and Process Unit Waste Exclusions Hazardous wastes generated in raw material, product storage, or process (e.g., manufacturing) units are exempt from Subtitle C hazardous waste regulation while the waste remains in such units. These units include tanks, pipelines, vehicles, and vessels used either in the manufacturing process or for storing raw materials or products, but specifically do not include surface impoundments. Once the waste is removed from the unit, or when a unit temporarily or permanently ceases operation for 90 days, the waste is considered generated and is subject to regulation.

14 RCRA - Hazardous Waste Identification Waste Sample and Treatability Study Sample Exclusions Hazardous waste samples are small, discrete amounts of hazardous waste that are essential to ensure accurate characterization and proper hazardous waste treatment. In order to facilitate the analysis of these materials, RCRA exempts characterization samples and treatability study samples from Subtitle C hazardous waste regulation.

15 RCRA - Hazardous Waste Identification Is the Waste a Listed Hazardous Waste? After a facility determines that its waste is a solid waste and is not excluded from the definitions of solid or hazardous waste, the owner and operator must determine if the waste is a hazardous waste. The first step in this process is determining if the waste is a listed hazardous waste. The hazardous waste listings consist of four lists: the F, P, K, and U lists

16 Listing Criteria - The hazard codes indicating the basis for listing a waste are: Toxic Waste (T) Acute Hazardous Waste (H) Ignitable Waste (I) Corrosive Waste (C) Reactive Waste (R) Toxicity Characteristic Waste (E)

17 RCRA - Hazardous Waste Identification Hazardous Waste Lists The F list The F list includes wastes from certain common industrial and manufacturing processes. Because the processes generating these wastes can occur in different sectors of industry, the F list wastes are known as wastes from nonspecific sources. The F list is codified in the regulations in 40 CFR The K list The K list includes wastes from specific industries. As a result, K list wastes are known as wastes from specific sources. The K list is found in 40 CFR

18 RCRA - Hazardous Waste Identification The P list and the U list These two lists include pure or commercial grade formulations of specific unused chemicals. Chemicals are included on the P list if they are acutely toxic. A chemical is acutely toxic if it is fatal to humans in low doses, if scientific studies have shown that it has lethal effects on experimental organisms, or if it causes serious irreversible or incapacitating illness. The U list is generally comprised of chemicals that are toxic, but also includes chemicals that display other characteristics, such as ignitability or reactivity. Both the P list and U list are codified in 40 CFR

19 RCRA - Hazardous Waste Identification Waste Listed Solely for Exhibiting the Characteristic of Ignitability, Corrosivity, and/or Reactivity Hazardous wastes listed solely for exhibiting the characteristic of ignitability, corrosivity, and/ or reactivity are not regulated the same way that other listed hazardous wastes are regulated under RCRA. When a waste meets a listing description for one of the 29 wastes listed solely for exhibiting the characteristic of ignitability, corrosivity, and/or reactivity, the waste is not hazardous if it does not exhibit that characteristic at the point of generation.

20 RCRA - Hazardous Waste Identification Delisting Petitions The RCRA regulations provide a form of relief for listed wastes with low concentrations of hazardous constituents. Through a site-specific process known as delisting, a waste handler can submit to an EPA region or authorized state a petition demonstrating that, even though a particular wastestream generated at its facility is a listed hazardous waste, it does not pose sufficient hazard to merit RCRA regulation.

21 RCRA - Hazardous Waste Identification Is the Waste a Characteristic Hazardous Waste? Ignitability Corrosivity Reactivity Toxicity

22 RCRA - Hazardous Waste Identification Ignitability The ignitability characteristic identifies wastes that can readily catch fire and sustain combustion. Many paints, cleaners, and other industrial wastes pose such a hazard. Liquid and non-liquid wastes are treated differently by the ignitability characteristic. The flash point test determines the lowest temperature at which the fumes above a waste will ignite when exposed to flame. Liquid wastes with a flash point of less than 60 C (140 F) in closed-cup test are ignitable. Many wastes in solid or non-liquid physical form (e.g., wood or paper) can also readily catch fire and sustain combustion, but EPA did not intend to regulate most of these non-liquid materials as ignitable wastes. A non-liquid waste is considered ignitable only if it can spontaneously catch fire or catch fire through friction or absorption of moisture under normal handling conditions and can burn so vigorously that it creates a hazard.

23 RCRA - Hazardous Waste Identification Corrosivity The corrosivity characteristic identifies wastes that are acidic or alkaline (basic). Such wastes can readily corrode or dissolve flesh, metal, or other materials. Aqueous wastes with a ph greater than or equal to 12.5 or less than or equal to 2 are corrosive. A liquid waste may also be corrosive if it has the ability to corrode steel under specific conditions. Corrosive wastes carry the waste code D002. The regulations describing the corrosivity characteristic are found in 40 CFR

24 RCRA - Hazardous Waste Identification Reactivity The reactivity characteristic identifies wastes that readily explode or undergo violent reactions or react to release toxic gases or fumes. A waste is reactive if it meets any of the following criteria: o It can explode or violently react when exposed to water or under normal handling conditions o It can create toxic fumes or gases at hazardous levels when exposed to water or under normal waste handling conditions o It can explode if heated under confinement or exposed to a strong igniting source, or it meets the criteria for classification as an explosive under DOT rules o It generates toxic levels of sulfide or cyanide gas when exposed to a ph range of 2 through 12.5 Wastes exhibiting the characteristic of reactivity assigned the waste code D003. The reactivity characteristic is described in the regulations in 40 CFR

25 RCRA - Hazardous Waste Identification Toxicity When hazardous waste is disposed of in a land disposal unit, toxic compounds or elements can leach into underground drinking water supplies and expose users of the water to hazardous chemicals and constituents. EPA developed the toxicity characteristic to identify wastes likely to leach dangerous concentrations of toxic chemicals into ground water. A lab procedure was developed to evaluate the leaching properties of waste, the Toxicity Characteristic Leaching Procedure (TCLP). The regulations describing the toxicity characteristic are codified in 40 CFR , and the TC regulatory levels appear in Table 1 of that same section.

26 RCRA - Hazardous Waste Identification

27 RCRA - Hazardous Waste Identification Mixture Rule The mixture rule is intended to ensure that mixtures of listed wastes with nonhazardous solid wastes are regulated in a manner that minimizes threats to human health and the environment Listed Wastes: The mixture rule regulates a combination of any amount of a nonhazardous solid waste and any amount of a listed hazardous waste as a listed hazardous waste Characteristic Wastes: The mixture rule applies differently to listed and characteristic wastes. A mixture involving characteristic wastes is hazardous only if the mixture itself exhibits a characteristic.

28 RCRA - Hazardous Waste Identification Mixture Rule (Continued) Wastes Listed solely for exhibiting the characteristic of Ignitability, corrosivity, and/or Reactivity: All wastes listed solely for exhibiting the characteristic of ignitability, corrosivity and/ or reactivity characteristic are not regulated as hazardous wastes once they no longer exhibit a characteristic. If a hazardous waste listed only for a characteristic is mixed with a solid waste, the original listing does not carry through to the resulting mixture if that mixture does not exhibit any hazardous waste characteristics. De Minimis Exemptions may apply in some cases.

29 RCRA - Hazardous Waste Identification Derived From Rule: Listed Wastes: EPA created the derived-from rule which states that any material derived from a listed hazardous waste is also a listed hazardous waste Characteristic Wastes: Treatment residues and materials derived from characteristic wastes are hazardous only if they themselves exhibit a characteristic.

30 RCRA Universal Wastes Universal Waste Universal wastes are subject to management provisions intended to ease the management burden and facilitate the recycling or proper treatment and disposal of such materials. Four types of waste are covered under universal waste regulations: hazardous waste batteries, hazardous waste pesticides that are either recalled or collected in waste pesticide collection programs, hazardous waste mercurycontaining equipment, and hazardous waste lamps. Universal Waste Management Standards are discussed at 40 CFR Part 273

31 RCRA Used Oil/Waste Oil Used oil is any oil that has been refined from crude oil or any synthetic oil that has been used and, as a result of such use, is contaminated by physical or chemical impurities. Used Oil Management Standards are discussed at 40 CFR Part 279 Pennsylvania regulations require Used Oil to be labeled as Waste Oil.

32 RCRA Electronics Waste Disposal In November 2010, the Pennsylvania General Assembly passed the Covered Device Recycling Act (CDRA), which establishes a number of requirements for individuals and entities involved throughout the life cycle of certain covered electronic devices. Covered devices include items such as: desktop computers, laptop computers, computer monitors, computer peripherals and televisions.

33 RCRA Electronics Waste Disposal Beginning Jan. 24, 2013, a disposal ban on covered devices went into effect in Pennsylvania. Business may not dispose of a covered device with their municipal solid waste. These devices and their components must be properly recycled and may not be taken to (or accepted by) landfills or other solid waste disposal facilities for disposal.

34 RCRA Generator Categories and Requirements Who Are The Regulated Generators? Large Quantity Generators Small Quantity Generators Conditionally Exempt Small Quantity Generators Episodic Generation State Regulations

35 RCRA Generator Categories and Requirements Large Quantity Generators (LQGs) Large quantity generators are defined as those facilities that generate: o 1,000 kg or more of hazardous waste per calendar month (approximately 2,200 lbs) OR o 1 kg or more of acutely hazardous waste per calendar month (approximately 2.2 lbs).

36 RCRA Generator Categories and Requirements Small Quantity Generators (SQGs) SQGs are defined as those facilities that: Generate between 100 kg (approximately 220 lbs) and 1,000 kg of hazardous waste per calendar month AND Accumulate less than 6,000 kg (approximately 13,200 lbs) of hazardous waste at any time.

37 RCRA Generator Categories and Requirements Conditionally Exempt Small Quantity Generators (CESQGs). These generators are defined as those facilities that produce: 100 kg or less of hazardous waste per calendar month OR 1 kg or less of acutely hazardous waste per calendar month. Beyond the monthly generation limits, the CESQG requirements additionally limit the facility s total waste accumulation quantities to 1,000 kg of hazardous waste, 1 kg of acute hazardous waste, or 100 kg of any residue from the cleanup of a spill of acute hazardous waste at any time.

38 RCRA Generator Categories and Requirements Because generator status is determined on a monthly basis, it is possible that a generator s status can change from one month to the next, depending on the amount of waste generated in a particular month. This is referred to as episodic generation. If a generator s status does in fact change, the generator is required to comply with the respective regulatory requirements for that class of generators for the waste generated in that particular month.

39 RCRA Generator Categories and Requirements Large and Small Quantity Generator Regulatory Requirements Waste Identification and Counting EPA Identification Numbers Accumulation of Waste Preparation for Transport Regulations Manifest Recordkeeping and Reporting Quantity and Time Limits for Storage of Wastes

40 RCRA Generator Categories and Requirements General Facility Standards EPA Identification Numbers Waste Analysis Security Inspection Requirements Personnel Training Requirements for Ignitable, Reactive, or Incompatible Waste Location Standards

41 RCRA Generator Categories and Requirements Preparedness and Prevention Contingency Plans and Emergency Procedures Contingency Plan Emergency Coordinator Emergency Procedures

42 RCRA Generator Categories and Requirements

43 RCRA TSDF Standards and Requirements Standards for Hazardous Waste Treatment Storage, and Disposal Units Containers Containment Buildings Drip Pads Land Treatment Units Landfills Surface Impoundments Tanks Waste Piles

44 RCRA - References EPA RCRA Hotline Training Modules EPA RCRA Orientation Manual Electronic Code of Federal Regulations 40 CFR

45 PA Residual Waste Regulations Regulations are covered in Chapter 287. Responsibilities under these regulations include proper waste characterization, management and disposal. Source reduction strategy planning (25R) is also required under the PA residual waste regulations. Reporting obligations include biennial residual waste reporting and annual 26R reporting.

46 Form 26R - Chemical Analysis of Residual Waste Annual Report by the Generator Residual waste Garbage, refuse, other discarded material or other waste, including solid, liquid, semisolid or contained gaseous materials resulting from industrial, mining and agricultural operations and sludge from an industrial, mining or agricultural water supply treatment facility, wastewater treatment facility or air pollution control facility, if it is not hazardous.

47 Form 26R Types of Residual Waste Combustion Residues Metallurgical Process Residues Sludges, Scales Chemical Wastes Generic Manufacturing Wastes Wood Wastes Process Wastewaters Grease Special Handling Wastes Asbestos Containing Waste Waste Tires Industrial Equipment, Maintenance Waste/Scrap Do Not Report: sanitary sewage or uncontaminated non-contact cooling waters; office, lunchroom, or restroom wastes; construction/demolition debris

48 Form 26R - Chemical Analysis of Residual Waste Annual Report by the Generator SECTION A. CLIENT (GENERATOR OF THE WASTE) INFORMATION Company Name Contact Information Waste Generation Location SECTION B. WASTE DESCRIPTION General Properties: o ph Range o Physical State o Physical Appearance Amount and Unit of Measure Residual Waste Code

49 Form 26R Residual Waste Codes The list of Residual Waste Codes (RWC) can be found on the Codes Residual Waste PADEP document 2540-PM-BWM040 Also include: code s description, the amount of waste, the unit of measurement, and the timeframe for disposal/processing.

50 Form 26R SECTION B. WASTE DESCRIPTION (Continued) Chemical Analysis Attachments o Detailed Chemical Characterization o Description of Waste Sampling Method o Laboratory QA/QC procedures o Hazardous Waste Determination o Generator Knowledge in Lieu of Chemical Analysis

51 Form 26R SECTION B. WASTE DESCRIPTION (Continued) Process Description & Schematic Attachments o Manufacturing and/or pollution Control Processes o Schematic Detailing Waste Production o Confidentiality Claim

52 Form 26R SECTION C. MANAGEMENT OF RESIDUAL WASTE Processing Or Disposal Facilities Beneficial Use o General Permit Number o Approval Number o Volume of Waste SECTION D. CERTIFICATION General Properties Chemical Analysis Process Description

53 Form 26R Department of Environmental Protection Southeast Regional Office 2 East Main Street Norristown, PA Phone (484) Northeast Regional Office 2 Public Square Wilkes-Barre, PA Phone (570) Southcentral Regional Office 909 Elmerton Avenue Harrisburg, PA Phone (717) Southwest Regional Office 400 Waterfront Drive Pittsburgh, PA Phone (412) Northcentral Regional Office 208 W. 3rd St., Suite 101 Williamsport, PA Phone (570) Northwest Regional Office 230 Chestnut Street Meadville, PA Phone (814)

54 Form 26 R - References PADEP Form 26R Chemical Analysis Of Residual Waste Annual Report By The Generator; 2540-PM-BWM0347 Rev. 1/2011 PADEP Form 26R Chemical Analysis Of Residual Waste Annual Report By The Generator Instructions; 2540-PM- BWM0347 Rev. 7/2010 PADEP Residual Waste Codes (RWC); 2540-PM-BWM0404 Rev. 8/ Pa. Code Section 287 Residual Waste Management General Provisions - oc.html

55 Preparedness, Prevention, and Contingency (PPC) Plan 1. Who needs to develop and implement a PPC Plan? 2. What is a PPC Plan?

56 Who needs to develop and implement a PPC Plan? Pennsylvania industrial and commercial installations which have the potential for causing accidental pollution of air, land, or water, or the endangerment of public health and safety are required to develop and implement. Authority: The Federal Clean Water Act, Pennsylvania Clean Streams Law, Pennsylvania Solid Waste Management Act, Pennsylvania Storage Tank and Spill Prevention Act, and Federal Oil Pollution Act

57 Who needs to develop and implement a PPC Plan? Pennsylvania industrial and commercial installations: applying for an NPDES Storm Water Discharge General Permit, Industrial Wastewater Discharge Permit, or Water Management Permit; that are non-npdes facilities directed by the DEP to develop a PPC plan (on a case-by-case basis); that have regulated storage tank(s) with an aggregate aboveground storage capacity > 21,000 gallons [note: a Spill Prevention Response (SPR) plan is also required]; or that generate hazardous waste, or which involve treatment, recycling, storage, or disposal of hazardous waste [note: generators, of between 100 and 1,000 kilograms of hazardous waste per month, may not be required to have a PPC plan if they comply with the Preparedness and Prevention requirements in the regulations

58 PPC Plan - Policy To plan and provide effective and efficient response to emergencies and accidents for any situation dealing with public health, safety, and the environment.

59 PPC Plan - Purpose To improve and preserve the purity of the Waters of the Commonwealth by prompt adequate response to all emergencies and accidental spills of polluting substances for the protection of public health, animal and aquatic life and for recreation. Many manufacturing and commercial activities have the potential for causing environmental degradation or endangerment of public health and safety through accidental releases of toxic, hazardous, or other polluting materials.

60 PPC Plan Water-Related Considerations Purpose: prevention/control of accidental discharge of polluting materials to surface water or groundwater Covered Activities: all industrial activities having potential for accidental pollution transportation, storage, processing of raw materials, intermediates, products, fuels, wastes Hazards Addressed: container leaks, ruptures, spills, floods, power failures, mechanical failure, human error, strikes, vandalism

61 PPC Plan Waste-Related Considerations Purpose: minimize and abate hazards to human health and the environment from fires, explosions, or release of solid wastes to air, soil, or surface water Covered Activities: generating, storing, recycling, treating, transporting, or disposing of solid wastes, hazardous wastes, residual wastes, municipal wastes, or medical wastes Hazards Addressed: container leaks, ruptures, spills, floods, power failures, mechanical failure, human error, strikes, vandalism, fires, explosions

62 PPC Plan Other Emergency Response Plans Oil-related Spill Prevention, Control, and Countermeasure (SPCC) plans, which are or have been developed pursuant to EPA s oil-related SPCC regulations, can be incorporated into a PPC plan; as can other emergency response plans (e.g. PIPPs and SWPPPs). Likewise, the additional downstream notification requirement of an Spill Prevention Response (SPR) plan can be added to an existing plan to satisfy the Storage Tank and Spill Prevention Act, providing all required elements of a SPR plan are completed for the existing plan.

63 PPC Plan - Submission to PADEP NPDES dischargers should submit (2) copies of the PPC plan for review, along with the NPDES application materials. All Stormwater General Permit applicants must complete and implement the Plans before or at the same time as application submission. Facilities which are not required to obtain NPDES permits, but which must obtain Water Quality Protection Part II permits, should submit (2) copies of the PPC plan for review, along with the Part II permit application. Other facilities which are not normally required to obtain NPDES or WQM Part II permits may also be required to develop and submit a PPC Plan, should conditions warrant, pursuant to Chapter 92 of the Department s regulations.

64 PPC Plan - Submission to PADEP Hazardous waste generators are required to develop PPC plans and to maintain them on site. They are required to submit PPC plans to the Department for review upon request by the Department. Hazardous waste treatment, recycling, storage, or disposal facilities should submit one copy of the PPC plan for each copy of the Hazardous Waste Part B permit application being submitted. Residual and/or municipal waste disposal/processing/transfer/ composting facilities are required to develop and submit a PPC Plan as part of the residual and/or municipal waste permit application. Facilities permitted under permit-by-rule are required to develop PPC Plans and maintain them on site. Aboveground storage tank facilities (with aggregate capacity >21,000 gallons) are required to submit one copy of the SPR plan to the appropriate regional DEP office for review.

65 PPC Plan - Distribution A copy of the plan and any subsequent revisions must be maintained on-site. All members of the installation s organization responsible for implementing and maintaining the plan and all emergency coordinators must review the plan and be thoroughly familiar with provisions. PPC and other facility plans should be made available to the following agencies, to the extent which they may become involved in an actual emergency: 1. County and Local Emergency Management Agencies 2. Local Fire Service Agencies and/or Hazmat Team 3. Local Emergency Medical Service Agencies 4. Local Police

66 PPC Plan - Content and Format Effectiveness depends upon simplicity and readability Diagrams, charts, tables, maps, and plans must be legible and understandable, particularly in times of an actual emergency Indexed or tabbed for quick reference in an emergency

67 PPC Plan - Description of Facility 1. Description of the Industrial or Commercial Activity 2. Description of Existing Emergency Response Plans 3. Material and Waste Inventory 4. Pollution Incident History 5. Implementation Schedule for Plan Elements Not Currently in Place

68 PPC Plan - Implementation Description of How Plan is Implemented by Organization 1. Organizational Structure of Facility for Implementation 2. List of Emergency Coordinators 3. Duties and Responsibilities of the Coordinator 4. Chain of Command

69 PPC Plan - Spill Leak Prevention and Response 1. Pre-Release Planning 2. Material Compatibility 3. Inspection and Monitoring Program 4. Preventive Maintenance 5. Housekeeping Program 6. Security 7. External Factor Planning 8. Employee Training Program

70 PPC Plan - Countermeasures 1. Countermeasures to be Undertaken by Facility 2. Countermeasures to be Undertaken by Contractors 3. Internal and External Communications and Alarm Systems 4. Evacuation Plan for Installation Personnel 5. Emergency Equipment Available for Response

71 PPC Plan - Emergency Spill Control Network 1. Arrangements with Local Emergency Response Agencies 2. Notification Lists 3. Downstream Notification Requirement for Storage Tanks (>21,000 gallons of regulated substances)

72 PPC Plan DEP Notification

73 PPC Plan - Certification Requirements for Non- Storm Water Discharges Provide a certification that the discharge has been tested or evaluated for the presence of nonstormwater discharges, including the identification of potential significant sources of non-stormwater at the site Except for sources including: fire-fighting activities; fire hydrant flushing; irrigation drainage; lawn watering; routine external building washdown which does not use detergents or other compounds; uncontaminated air conditioning or compressor condensate

74 PPC Plan - Storm Water Management Practices Description of BMPs to control storm water runoff and prevent storm water pollution that are reasonable and appropriate, and will be implemented and maintained Traditional measures reduce pollutant discharges by reducing the volume of storm water discharges, such as swales, or preventing storm water run-on in areas of industrial activities Low cost measures may include: diverting rooftop or other drainage across grass swales, cleaning catch basins, and installing and maintaining oil and grit separators.

75 PPC Plan - Sediment and Erosion Prevention Identify areas which, due to topography, activities, or other factors, have a high potential for significant soil erosion, and identify measures to limit erosion. Develop and implement sediment and erosion prevention and control measures in accordance with Chapter 102 of the Department s rules and regulations and the Bureau of Soil and Water Conservation s Erosion and Sediment Pollution Control Program Manual.

76 PPC Plan - Additional Requirements for EPCRA, Section 313 Facilities Facilities that manufacture, import, process, or otherwise use listed toxic chemicals and are required to report annually their releases of those chemicals to any environmental media 1. Stormwater controls in areas where Section 313 water priority chemicals are stored, processed or otherwise handled. 2. Secondary containment for the entire capacity of largest single container or tank plus sufficient freeboard to allow for precipitation (25-year, 24-hour storm event), 3. Managed operations where Section 313 water priority chemicals are transferred, processed, or otherwise handled 4. Annual Certification by a Registered Professional Engineer

77 PPC Plan - References PADEP Guidelines for the Development and Implementation of Environmental Emergency Response Plans Document ID ; August 6, 2005 PADEP PAG-03 Authorization To Discharge Under The National Pollutant Discharge Elimination System (NPDES) General Permit For Discharges Of Stormwater Associated With Industrial Activities 3800-PM-WSFR0083d Rev. 12/2010

78 Emergency Planning and Community Right-to-Know Act (EPCRA) On December 4, 1984, methyl isocyanate, an extremely toxic chemical escaped from a Union Carbide chemical plant in Bhopal, India. Thousands died and many more were injured. Approximately six months later, a similar but less severe chemical release incident occurred at a facility located in Institute, West Virginia. These two events raised concern about local preparedness for chemical emergencies and the availability of information on hazardous chemicals. In response to these concerns, Congress passed the Emergency Planning and Community Right-to-Know Act (EPCRA) in 1986.

79 EPCRA Program Areas EPCRA has four major provisions: Emergency Planning (Sections ) Emergency Release Notification (Section 304) Hazardous Chemical Storage Reporting Requirements (Sections ) Toxic Chemical Release Inventory (Section 313)

80 EPCRA Sections Emergency Response Plans (Sections ) Emergency Response plans contain information that community officials can use at the time of a chemical accident. Any facility that has EHS at or above its threshold planning quantity must notify the State Emergency Response Commission (SERC) or the Tribal Emergency Response Commission (TERC) and Local Emergency Planning Committee (LEPC) within 60 days after they first receive a shipment or produce the substance on site.

81 EPCRA Section 304 Emergency Notification Requirements (Section 304) Facilities must immediately notify the LEPC and the SERC or the TERC if there is a release into the environment of a hazardous substance that is equal to or exceeds the minimum reportable quantity set in the regulations. This requirement covers the 355 extremely hazardous substances, as well as the more than 700 hazardous substances subject to the emergency notification requirements under CERCLA section 103(a)(40 CFR 302.4).

82 EPCRA Section 304 This emergency notification needs to include: The chemical name; An indication of whether it is an extremely hazardous substance; An estimate of the quantity released into the environment; The time and duration of the release; Whether the release occurred into air, water, and/or land; Any known or anticipated acute or chronic health risks associated with the emergency, and where necessary, advice regarding medical attention for exposed individuals; Proper precautions, such as evacuation or sheltering in place; and, Name and telephone number of contact person. A written follow-up written notice must also be submitted.

83 EPCRA Sections Community Right-to-know Requirements (Sections 311 and 312) Under Occupational Safety and Health Administration (OSHA) regulations, employers must maintain a material safety data sheet (MSDS) for any hazardous chemicals stored or used in the work place. Approximately 500,000 products are required to have MSDSs. Section 311 requires facilities that have MSDSs for chemicals held above certain threshold quantities to submit either copies of their MSDSs or a list of these chemicals to the SERC or TERC, LEPC, and local fire department.

84 EPCRA Sections Section 311(e) of EPCRA excludes the following substances: 1) Any food, food additive, color additive, drug, or cosmetic regulated by the Food and Drug Administration; 2) Any substance present as a solid in any manufactured item to the extent exposure to the substance does not occur under normal conditions of use; 3) Any substance to the extent it is used for personal, family, or household purposes, or is present in the same form and concentration as a product packaged for distribution and use by the general public; 4) Any substance to the extent it is used in a research laboratory or a hospital or other medical facility under the direct supervision of a technically qualified individual; and 5) Any substance to the extent it is used in routine agricultural operations or is a fertilizer held for sale by a retailer to the ultimate customer.

85 EPCRA Sections If the facility owner or operator chooses to submit a list of chemicals, the list must include the chemical or common name of each substance and must identify the applicable hazard categories. These hazard categories are: Immediate (acute) health hazard Delayed (chronic) health hazard Fire hazard Sudden release of pressure hazard Reactive hazard

86 EPCRA Sections If a list is submitted, the facility must submit a copy of the MSDSs for any chemical on the list upon request by the LEPC. Facilities that start using a hazardous chemical or increase the quantity to exceed the thresholds must submit MSDSs or a list of MSDSs chemicals within three months after they become covered. Facilities must provide a revised MSDS to update the original MSDS or list if significant new information is discovered about the hazardous chemical.

87 EPCRA Sections Facilities covered by section 311 must submit annually an Emergency and Hazardous Chemical Inventory Form to the LEPC, the SERC or the TERC, and the local fire department as required under section 312. Facilities provide either a Tier I or Tier II inventory form. Tier I inventory form include the following aggregate information for each applicable hazard category: An estimate (in ranges) of the maximum amount of hazardous chemicals for each category present at the facility at any time during the preceding calendar year; An estimate (in ranges) of the average daily amount of hazardous chemicals in each category; and, The general location of hazardous chemicals in each category.

88 EPCRA Sections The Tier II inventory form contains basically the same information as the Tier I, but it must list the specific chemicals. Tier II inventory form provide the following information for each chemical: The chemical name or the common name as indicated on the MSDS; An estimate (in ranges) of the maximum amount of the chemical present at any time during the preceding calendar year and the average daily amount; A brief description of the manner of storage of the chemical; The location of the chemical at the facility; and An indication of whether the owner elects to withhold location information from disclosure to the public. Many states (such as Pennsylvania) require completion of the Tier II inventory form. Section 312 information must be submitted on or before March 1 each year for information on chemicals present at the facility in the previous year.

89 EPCRA Sections 313 Toxics Release Inventory (Section 313) Section 313 of EPCRA established the Toxics Release Inventory. TRI tracks the management of certain toxic chemicals that pose a threat to human health and the environment. Facilities in different industry sectors must annually report how much of each chemical they managed through recycling, energy recovery, treatment and environmental releases. TRI reporting forms must be submitted to EPA and the appropriate state or tribe by July 1 of each year. These forms cover environmental releases and other management of toxic chemicals that occurred during the previous calendar year.

90 EPCRA Sections 313 The information submitted by facilities is compiled in the Toxics Release Inventory and made available to the public through the TRI website: TRI includes information about: On-site releases (including disposal) of toxic chemicals to air, surface water and land On-site recycling, treatment and energy recovery associated with TRI chemicals Off-site transfers of toxic chemicals from TRI facilities to other locations Pollution prevention activities at facilities Releases of lead, mercury, dioxin and other persistent, bioaccumulative and toxic (PBT) chemicals Facilities in a variety of industry sectors (including manufacturing, metal mining and electric power generation) and some federal facilities

91 EPCRA Reporting Timetables Reporting Schedules for EPCRA Section Numbers: 302 One time notification to SERC / TERC and LEPC 304 Each time a release above a reportable quantity of an EHS or CERCLA Hazardous Substance occurs to LEPC and SERC or TERC 311 One time submission of MSDS or list of hazardous chemicals. An update is required for new chemicals or new information about chemicals already submitted to the SERC or TERC, LEPC, and the fire department with jurisdiction over the facility 312 Annually, by March 1 to SERC or TERC, LEPC, and the fire department with jurisdiction over the facility 313 Annually, by July 1, to EPA, states and tribes

92 EPCRA References EPA EPCRA Webpage EPA EPCRA TRI Webpage EPA EPCRA Fact Sheet Electronic Code of Federal Regulations 40 CFR

93 TOXIC SUBSTANCES CONTROL ACT (TSCA) Premanufacture Notice This section briefly touches on a few areas of TSCA of potential interest to manufacturers: Mandated by section 5 of the TSCA, EPA's New Chemicals program helps manage the potential risk to human health and the environment from chemicals new to the marketplace. The program functions as a "gatekeeper" that can identify conditions, up to and including a ban on production, to be placed on the use of a new chemical before it is entered into commerce. Section 5 of TSCA requires anyone who plans to manufacture (including import) a new chemical substance for a nonexempt commercial purpose to provide EPA with notice before initiating the activity. This premanufacture notice, or PMN, must be submitted at least 90 days prior to the manufacture of the chemical. A PMN includes information such as specific chemical identity, use, anticipated production volume, exposure and release information, and existing available test data.

94 TSCA Chemical Data Reporting (CDR) Next CDR Reporting in 2016 The submission period for the 2016 CDR will be from June 1, 2016, to September 30, The CDR rule requires manufacturers, including importers of certain chemical substances included on the TSCA Chemical Substance Inventory, to report information on chemicals manufactured (including imported) in volumes of 25,000 lbs. or more at their site during any calendar year since Manufacturers (including importers) need to report production volume information for calendar years 2012, 2013, 2014, and While submitters will not report to EPA until 2016, they should start keeping track of their production volumes for these four years. For the 2016 CDR, the principal reporting year will be calendar year Full manufacturing, processing, and use information will be required only for 2015.

95 TSCA - Chemical Data Reporting Below are the requirements for the 2016 CDR: Manufacturers (including importers) will be required to report if, for any calendar year since 2011, a chemical substance was manufactured (including imported) at a site in production volumes of 25,000 lbs. or greater. The reporting threshold for processing and use information will be 25,000 lbs. Note: This is lower than the 100,000 lb threshold for processing and use information required for the 2012 CDR. The reporting threshold will be 2,500 lbs. for chemical substances that are: o Subject of a rule proposed or promulgated under TSCA section 5(a)(2), 5(b)(4), or 6 o Subject of an order issued under TSCA section 5(e) or 5(f) o Subject of relief that has been granted under a civil action under TSCA section 5 or 7

96 TSCA - Polychlorinated Biphenyls (PCBs) PCBs belong to a broad family of man-made organic chemicals known as chlorinated hydrocarbons. PCBs were domestically manufactured from 1929 until their manufacture was banned in They have a range of toxicity and vary in consistency from thin, light-colored liquids to yellow or black waxy solids. Due to their non-flammability, chemical stability, high boiling point, and electrical insulating properties, PCBs were used in hundreds of industrial and commercial applications including electrical, heat transfer, and hydraulic equipment; as plasticizers in paints, plastics, and rubber products; in pigments, dyes, and carbonless copy paper; and many other industrial applications.

97 TSCA - Polychlorinated Biphenyls PCBs may be present in products and materials produced before the 1979 PCB ban. Example products that may contain PCBs include: Transformers and capacitors Other electrical equipment including voltage regulators, switches, bushings, and electromagnets Oil used in motors and hydraulic systems Old electrical devices or appliances containing PCB capacitors Fluorescent light ballasts Cable insulation Oil-based paint Caulking

98 TSCA - Polychlorinated Biphenyls Authorized Uses of PCBs are described in 40 Code of Federal Regulations Part The authorized uses also provide various requirements (e.g. various inspections and recordkeeping) Marking Requirements for PCBs and PCB Items Each of the following PCB Items must be marked with the mark ML: (1) PCB containers; (2) PCB Transformers; (3) Large High-Voltage Capacitors; (4) Large Low-Voltage Capacitors; (5) PCB Large Low Voltage Capacitors at the time of removal from use; (6) Electric motors using PCB coolants; (7) Hydraulic systems; (8) Heat transfer systems; (9) PCB Article Containers containing articles or equipment; (10) Each storage area used to store PCBs and PCB Items for disposal.

The Comprehensive Environmental Response,

The Comprehensive Environmental Response, Purpose and Applicability of Regulations Chapter 7 The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) was enacted by Congress in 1980 to clean up the nation s hazardous

More information

The Comprehensive Environmental Response,

The Comprehensive Environmental Response, Purpose and Applicability of Regulations The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) was enacted by Congress in 1980 to clean up the nation s hazardous waste sites

More information

Here are some hazardous wastes commonly generated by the marina industry:

Here are some hazardous wastes commonly generated by the marina industry: Important Note: The following text is excerpted directly from the New York State Department of Environmental Conservation s publication, Environmental Compliance, Pollution Prevention, and Self Assessment

More information

Guidelines for the Development and Implementation of Environmental Emergency Response Plans

Guidelines for the Development and Implementation of Environmental Emergency Response Plans COMMONWEALTH OF PENNSYLVANIA Department of Environmental Protection Guidelines for the Development and Implementation of Environmental Emergency Response Plans PA Department of Environmental Protection

More information

Guidelines for the Development and Implementation of Environmental Emergency Response Plans

Guidelines for the Development and Implementation of Environmental Emergency Response Plans COMMONWEALTH OF PENNSYLVANIA Department of Environmental Protection Guidelines for the Development and Implementation of Environmental Emergency Response Plans 400-2200-001 PA Department of Environmental

More information

Hazardous Waste Compliance Awareness For Faculty and Staff

Hazardous Waste Compliance Awareness For Faculty and Staff Hazardous Waste Compliance Awareness For Faculty and Staff Important information for campus employees generating, handling or storing hazardous waste I. Hazardous Waste A. Materials being used for their

More information

Compliance Bulletin Hazardous Waste Lighting Waste reviewed/revised March 2012

Compliance Bulletin Hazardous Waste Lighting Waste reviewed/revised March 2012 Lamp Wastes Many commonly used lamps contain small amounts of mercury and other metals. Such lamps include fluorescent, compact fluorescent, high-pressure sodium, mercury vapor and metal halide lamps.

More information

Hazardous Waste Generator Requirements

Hazardous Waste Generator Requirements Pennsylvania Hazardous Waste Regulation Compliance Guide Hazardous Waste Generator Requirements Title Pennsylvania Code 25 TWENTY-FIVE TABLE OF CONTENTS 1. What Is This Guide About?...1 2. Do The Hazardous

More information

Hazardous Waste Determination and Management Plan

Hazardous Waste Determination and Management Plan Hazardous Waste Determination and Management Plan Prepared By: Triumvirate Environmental Developed: November 2014 Updated: Program Approval Associate Vice President of Public Safety & Administrative Services

More information

SARA Title III Program General Information

SARA Title III Program General Information Virginia Department of Environmental Quality (DEQ) From http://www.deq.virginia.gov/sara3 SARA Title III Program General Information The provisions from the Superfund Amendments and Reauthorization Act

More information

HAZARDOUS WASTE MANAGEMENT PROGRAM

HAZARDOUS WASTE MANAGEMENT PROGRAM HAZARDOUS WASTE MANAGEMENT PROGRAM UNIVERSITY RISK MANAGEMENT Occupational Safety and Health Programs 19 Hagood Avenue, Suite 908 Charleston, SC 29425 843-792-3604 Revised: January 2015 TABLE OF CONTENTS

More information

Berea College Chemical waste/product Management Guide. October 2014

Berea College Chemical waste/product Management Guide. October 2014 Berea College Chemical waste/product Management Guide October 2014 Chemical Waste Chemical waste is generated in many locations across campus. Chemical waste is generated in laboratories, from painting

More information

2013 CONSTRUCTION CONTRACTOR CATALOGUE ECATTS. Copyright ECATTS. All Rights Reserved.

2013 CONSTRUCTION CONTRACTOR CATALOGUE ECATTS. Copyright ECATTS. All Rights Reserved. 2013 CONSTRUCTION CONTRACTOR CATALOGUE ECATTS Copyright ECATTS. All Rights Reserved. TABLE OF CONTENTS Introduction Course Descriptions Construction Contractors... 5 Air/Emissions Asbestos Drinking Water

More information

FLORIDA HAZARDOUS WASTE MANAGEMENT REGULATIONS THAT DIFFER FROM FEDERAL REQUIREMENTS

FLORIDA HAZARDOUS WASTE MANAGEMENT REGULATIONS THAT DIFFER FROM FEDERAL REQUIREMENTS FLORIDA HAZARDOUS WASTE MANAGEMENT REGULATIONS THAT DIFFER FROM FEDERAL REQUIREMENTS Chapter 1: Introduction General Notes Lead Agency: Florida Department of Environmental Protection (DEP) Division of

More information

ENVIRONMENTAL HEALTH AND SAFETY HAZARDOUS MATERIALS MANAGEMENT PLAN

ENVIRONMENTAL HEALTH AND SAFETY HAZARDOUS MATERIALS MANAGEMENT PLAN ENVIRONMENTAL HEALTH AND SAFETY HAZARDOUS MATERIALS MANAGEMENT PLAN November 2011 University of Northern Colorado Hazardous Materials Management Plan I. General II. III. IV. Responsibilities Definition

More information

IDENTIFYING YOUR WASTE

IDENTIFYING YOUR WASTE United States Environmental Protection Agency EPA530-F-97-029 September 1997 http://www.epa.gov Solid Waste and Emergency Response IDENTIFYING YOUR WASTE THE STARTING POINT This brochure explains the methodology

More information

Chapter 5: Spills Response

Chapter 5: Spills Response Chapter 5: Spills Response When printing materials are spilled, the response required by the owner or operator depends on what is spilled and the quantity. The entities who must be informed of a spill

More information

Guidelines for the Responsible Disposal of Wastes and Containers from Polyurethane Processing

Guidelines for the Responsible Disposal of Wastes and Containers from Polyurethane Processing Guidelines for the Responsible Disposal of Wastes and Containers from Polyurethane ISSUE AX151 January 2014 Table of Contents Purpose...1 Regulations... 2 What is a Hazardous Waste?... 2 Listed Wastes...3

More information

Spill Prevention, Control & Cleanup SC-11

Spill Prevention, Control & Cleanup SC-11 Objectives Cover Contain Educate Reduce/Minimize Product Substitution Description Spills and leaks, if not properly controlled, can adversely impact the storm drain system and receiving waters. Due to

More information

WHAT IS A HAZARDOUS WASTE? Kansas Department of Health and Environment Bureau of Waste Management

WHAT IS A HAZARDOUS WASTE? Kansas Department of Health and Environment Bureau of Waste Management WHAT IS A HAZARDOUS WASTE? Kansas Department of Health and Environment Bureau of Waste Management REGULATORY BACKGROUND Resource Conservation & Recovery Act (RCRA) 1976 EPA implemented hazardous waste

More information

Health Care Alert. Disposing of Hazardous Pharmaceutical Wastes: It s Not Just for Hospitals Anymore

Health Care Alert. Disposing of Hazardous Pharmaceutical Wastes: It s Not Just for Hospitals Anymore December 2008 Authors: Raymond P. Pepe +1.717.231.5988 raymond.pepe@klgates.com Patricia Shea +1.717.231.5870 patricia.shea@klgates.com Jessica Leigh Wray +1.717.231.4815 leigh.wray@klgates.com K&L Gates

More information

CONTRACTOR ENVIRONMENTAL LIABILITY 101. Violation of environmental laws may result in fine or imprisonment or both.

CONTRACTOR ENVIRONMENTAL LIABILITY 101. Violation of environmental laws may result in fine or imprisonment or both. CONTRACTOR ENVIRONMENTAL LIABILITY 101 Violation of environmental laws may result in fine or imprisonment or both. To avoid potential liability, contractors must be aware of the requirements of the various

More information

INFOCUS 1EPA DRY CLEANING REGULATORY REVIEW REDUCING WASTE POLLUTION RESOURCES FOR DRY CLEANERS AND PREVENTING

INFOCUS 1EPA DRY CLEANING REGULATORY REVIEW REDUCING WASTE POLLUTION RESOURCES FOR DRY CLEANERS AND PREVENTING INFOCUS DRY CLEANING REGULATORY REVIEW REDUCING WASTE AND PREVENTING POLLUTION RESOURCES FOR DRY CLEANERS 1EPA United States Environmental Protection Agency Solid Waste and Emergency Response (5305W) EPA530-K-99-005

More information

FUELING AND FUEL STORAGE

FUELING AND FUEL STORAGE FUELING AND FUEL STORAGE BENCHMARK Implement spill prevention measures whenever fuel is handled or stored. Report, minimize, contain and clean up spills that do occur. FUELING BMPS Spills of diesel, oil,

More information

Instructions for Reporting 2016 TSCA Chemical Data Reporting. U.S. Environmental Protection Agency Office of Pollution Prevention and Toxics

Instructions for Reporting 2016 TSCA Chemical Data Reporting. U.S. Environmental Protection Agency Office of Pollution Prevention and Toxics Instructions for Reporting 2016 TSCA Chemical Data Reporting U.S. Environmental Protection Agency Office of Pollution Prevention and Toxics May 13, 2016 DOCUMENT HISTORY Document Date March 21, 2016 April

More information

Generator Requirements Summary Chart

Generator Requirements Summary Chart guidance Generator Requirements Summary Chart This chart is designed to give inspectors a fairly detailed comparison of the requirements as they apply to Large Quantity Generators (LQGs), Small Quantity

More information

Guide to Generator Requirements of the Colorado Hazardous Waste Regulations

Guide to Generator Requirements of the Colorado Hazardous Waste Regulations Guide to Generator Requirements of the Colorado Hazardous Waste Regulations Hazardous Materials and Waste Management Division (303) 692-3300 Seventh Edition August 2013 Purpose of this Guidance This is

More information

sara 312 & 313 emergency planning & community right-to-know act

sara 312 & 313 emergency planning & community right-to-know act sara 312 & 313 lorin jaeger, C: 512-417-0186, lorin.jaeger@sageenvironmental.com kari keegan, C: 312-965-8038, kari.keegan@sageenvironmental.com October 2012. ALL RIGHTS RESERVED. Revised Nov. 12, 2012

More information

ENVIRONMENTAL COMPLIANCE PROGRAM

ENVIRONMENTAL COMPLIANCE PROGRAM Chapter 4. Handling and Disposal of Hazardous Waste 4.1 Hazardous waste: Hazardous waste is defined in section IV under definitions. The following diagram can aide in the process of determination: Is the

More information

MARSHALL UNIVERSITY HAZARDOUS WASTE DISPOSAL SECTION

MARSHALL UNIVERSITY HAZARDOUS WASTE DISPOSAL SECTION MARSHALL UNIVERSITY HAZARDOUS WASTE DISPOSAL SECTION TABLE OF CONTENTS POLICY STATEMENT.2 REFERENCE PROCEDURE 3 l.0 Purpose.3 2.0 Scope 3 3.0 Definitions 4 4.0 Responsibilities 5 5.0 Procedure.7 11/16/2005

More information

Frequently Asked Questions about Hazardous Waste Lamps (e.g., fluorescent or other lights containing mercury)

Frequently Asked Questions about Hazardous Waste Lamps (e.g., fluorescent or other lights containing mercury) Frequently Asked Questions about Hazardous Waste Lamps (e.g., fluorescent or other lights containing mercury) I. Current Regulatory Status of Fluorescent Lamps in NC What is the current regulatory status

More information

Notification of RCRA Subtitle C Activity

Notification of RCRA Subtitle C Activity United States Environmental Protection Agency January 2015 Notification of RCRA Subtitle C Activity Instructions and Form EPA Form 8700-12 (OMB #2050-0024; Expires 01/31/2017) Office of Resource Conservation

More information

regulations governing TreaTmenT, storage, and aaadisposal facilities aaa

regulations governing TreaTmenT, storage, and aaadisposal facilities aaa regulations governing TreaTmenT, storage, and aaadisposal facilities aaa Overview... III-53 What is a TSDF?... III-54 - Permits and Interim Status... III-54 - Exemptions... III-55 General Facility Standards...

More information

Pollution Prevention And Best Management Practices For Dry Cleaners Operating In Broward County

Pollution Prevention And Best Management Practices For Dry Cleaners Operating In Broward County FORWARD In 1991, the Broward County Environmental Protection and Growth Management Department, who was then known as the Department of Natural Resource Protection (DNRP), initiated the development of Pollution

More information

Waste Hazardous? Why?

Waste Hazardous? Why? Doc. No. 801 Hazardous Waste M anagement Auto body shops typically generate several kinds of potentially hazardous waste, including waste solvent and coatings, contaminated rags, wipes, and absorbents,

More information

Pollution Liability Exposure: Adjustments your automotive business should consider to maintain compliance

Pollution Liability Exposure: Adjustments your automotive business should consider to maintain compliance : Adjustments your automotive business should consider to maintain compliance Pollution sounds like such a dirty word. And as an automotive service business owner, employee or operator, you might be producing

More information

Policies and Procedures Manual Waste Management Plan Policy No. 06:04:00 Page 1 of 12

Policies and Procedures Manual Waste Management Plan Policy No. 06:04:00 Page 1 of 12 Page 1 of 12 Revision Responsibility: Director of Facility Services and Safety Responsible Executive Officer: Vice President for Financial & Administrative Services Source / Reference: Tennessee Division

More information

Hazardous Waste Accumulation, Storage, & Labeling

Hazardous Waste Accumulation, Storage, & Labeling Nadine Deak, Kalamazoo District Office 269-567-3592 or deakn@michigan.gov Jenny Bennett, Gaylord District Office 989-705-2421 or bennettj6@michigan.gov Hazardous Waste Accumulation, Storage, & Labeling

More information

Hazardous Waste Management Plan

Hazardous Waste Management Plan Hazardous Waste Management Plan Introduction The management of hazardous waste is governed by the Environmental Protection Agency (EPA) regulations, specifically, 40CFR260-262. These regulations are the

More information

EcoSystem sm - City of Scottsdale, Arizona Environmental Management System

EcoSystem sm - City of Scottsdale, Arizona Environmental Management System Environmental Regulations Guide Section 4 Pollution Prevention 4. 0 Pollution Prevention The Pollution Prevention Act (PPA) focuses on source reduction, i.e. on reducing the amount of pollution through

More information

APPENDIX G Materials Storage and Handling Guidelines

APPENDIX G Materials Storage and Handling Guidelines APPENDIX G Materials Storage and Handling Guidelines 1.0 INTRODUCTION Operations at Austin-Bergstrom International Airport (ABIA) comprise several different industrial activities including aircraft, ground

More information

Hazardous Waste Recycling. The dreaded definition of solid waste table (40 CFR 261.2) and other equally confusing regulations

Hazardous Waste Recycling. The dreaded definition of solid waste table (40 CFR 261.2) and other equally confusing regulations Hazardous Waste Recycling The dreaded definition of solid waste table (40 CFR 261.2) and other equally confusing regulations 1 Why is hazardous waste recycling regulation so complicated? Must look in many

More information

Hazardous Waste Definitions

Hazardous Waste Definitions Hazardous Waste Definitions Acceptable Closed Conveyance System: A system in which waste reclamation operations are literally enclosed, or hard-plumbed with pipe to the unit that generates the waste. A

More information

Emergency Planning and Community Right-to-Know

Emergency Planning and Community Right-to-Know Emergency Planning and Community Right-to-Know CT Business and Facility Required Reporting Guidance EPCRA Law and Regulations Updated November 2011 For more detail and specific required reporting instructions

More information

UDOT SPILL PREVENTION and RESPONSE PLAN for CONSTRUCTION SITES

UDOT SPILL PREVENTION and RESPONSE PLAN for CONSTRUCTION SITES UDOT SPILL PREVENTION and RESPONSE PLAN for CONSTRUCTION SITES February 2014 The plan contained in the following pages was developed in part from UDOT Construction Division s Safety and Health Manual,

More information

Contingency Plan. Facility Name

Contingency Plan. Facility Name Contingency Plan Facility Name This plan is reviewed annually and amended whenever changes occur that will significantly affect the ability of this facility to respond to an emergency situation. This includes

More information

4.7 HAZARDS AND HAZARDOUS MATERIALS

4.7 HAZARDS AND HAZARDOUS MATERIALS LSA ASSOCIATES, INC. MARCH 2008 FINAL ENVIRONMENTAL IMPACT REPORT YUCCA VALLEY RETAIL SPECIFIC PLAN The State defines hazardous material as any material that, because of its quantity, concentration, or

More information

Hazardous Waste Generator Handbook

Hazardous Waste Generator Handbook Hazardous Waste Generator Handbook May 1, 2011 Revised April 16, 2014 A Guide to Complying with Kansas Hazardous Waste Generator Regulations Kansas Department of Health and Environment Division of Environment

More information

RCRA and Pharmaceutical Waste Management: A Brief Federal Overview

RCRA and Pharmaceutical Waste Management: A Brief Federal Overview RCRA and Pharmaceutical Waste Management: A Brief Federal Overview Lisa Lauer (EPA) Office of Resource Conservation and Recovery Lauer.lisa@epa.gov; 703-308-7418 1 What is RCRA? RCRA = Resource Conservation

More information

Multi Family Household Hazardous Waste Disposal New Options for Residential Landlords

Multi Family Household Hazardous Waste Disposal New Options for Residential Landlords Multi Family Household Hazardous Waste Disposal New Options for Residential Landlords Hazardous waste generated by a residential (multi family) property owner while maintaining his/her building and/or

More information

ALLEGANY WIND POWER PROJECT CONSTRUCTION SPILL PREVENTION PLAN

ALLEGANY WIND POWER PROJECT CONSTRUCTION SPILL PREVENTION PLAN ALLEGANY WIND POWER PROJECT CONSTRUCTION SPILL PREVENTION PLAN Best Management Practices (BMPs) will be implemented during construction of the Allegany Wind Power Project to prevent and contain spills.

More information

The Bevill Exemption from Hazardous Waste Regulation

The Bevill Exemption from Hazardous Waste Regulation The Bevill Exemption from Hazardous Waste Regulation Dean Miller Davis Graham & Stubbs LLP Roadmap What s at Stake RCRA 101 Hazardous Waste Identification, Management, and Exemptions Solid Waste Identification,

More information

HAZARDOUS WASTE MANAGEMENT PROGRAM. For OTTERBEIN UNIVERSITY. Prepared by: 140 North Otterbein Avenue Westerville, Ohio 43081

HAZARDOUS WASTE MANAGEMENT PROGRAM. For OTTERBEIN UNIVERSITY. Prepared by: 140 North Otterbein Avenue Westerville, Ohio 43081 HAZARDOUS WASTE MANAGEMENT PROGRAM For OTTERBEIN UNIVERSITY Prepared by: 140 North Otterbein Avenue Westerville, Ohio 43081 Otterbein University 0 TABLE OF CONTENTS 1.0 PURPOSE AND SCOPE... 1 2.0 ROLES

More information

Extraction Oil and Gas, LLC. Diamond Valley Central Oil Terminal Waste Management Plan

Extraction Oil and Gas, LLC. Diamond Valley Central Oil Terminal Waste Management Plan Extraction Oil and Gas, LLC. Diamond Valley Central Oil Terminal Waste Management Plan Scope: This Extraction Oil and Gas Waste Management Plan has been prepared to provide operations personnel at the

More information

TITLE 29: EMERGENCY SERVICES, DISASTERS, AND CIVIL DEFENSE CHAPTER I: EMERGENCY MANAGEMENT AGENCY SUBCHAPTER d: STATE EMERGENCY RESPONSE

TITLE 29: EMERGENCY SERVICES, DISASTERS, AND CIVIL DEFENSE CHAPTER I: EMERGENCY MANAGEMENT AGENCY SUBCHAPTER d: STATE EMERGENCY RESPONSE TITLE 29: EMERGENCY SERVICES, DISASTERS, AND CIVIL DEFENSE CHAPTER I: EMERGENCY MANAGEMENT AGENCY SUBCHAPTER d: STATE EMERGENCY RESPONSE PART 430 EMERGENCY AND WRITTEN NOTIFICATION OF AN INCIDENT OR ACCIDENT

More information

Outdoor Storage of Raw Materials SC-33

Outdoor Storage of Raw Materials SC-33 Objectives Cover Contain Educate Reduce/Minimize Description Raw materials, by-products, finished products, containers, and material storage areas exposed to rain and/or runoff can pollute stormwater.

More information

Hazardous and Regulated Waste Management Plan Purpose

Hazardous and Regulated Waste Management Plan Purpose Hazardous and Regulated Waste Management Plan Purpose Purpose This Hazardous and Regulated Waste Management Plan describes the chemical and biological waste management practices at Normandale Community

More information

Learning Objectives. Solid and Hazardous Wastes. Definitions. Statement of Problem. Gene D. Schroder PhD

Learning Objectives. Solid and Hazardous Wastes. Definitions. Statement of Problem. Gene D. Schroder PhD Learning Objectives Solid and Hazardous Wastes Gene D. Schroder PhD To understand the sources of solid and hazardous wastes. To understand methods of solid waste disposal. To evaluate the health risks

More information

Worcester Polytechnic Institute. Hazardous Waste Management Plan

Worcester Polytechnic Institute. Hazardous Waste Management Plan Plan Issued: December, 2000 Revised: July, 2004 Worcester Polytechnic Institute Plan Table of Contents Topic Page Table of Contents 2 1.0 Introduction 5 2.0 Regulatory Authority 6 3.0 Program Organization

More information

Hazardous Waste Management in Connecticut

Hazardous Waste Management in Connecticut Hazardous Waste Management in Connecticut Hazardous wastes are a group of wastes that are subject to special handling requirements because their mismanagement may lead to serious hazards to human health

More information

Training Module. Hazardous Waste Identification (40 CFR Parts 261) Introduction to. Solid Waste and Emergency Response (5305W) EPA530-K-05-012

Training Module. Hazardous Waste Identification (40 CFR Parts 261) Introduction to. Solid Waste and Emergency Response (5305W) EPA530-K-05-012 Training Module Introduction to Solid Waste and Emergency Response (5305W) EPA530-K-05-012 Hazardous Waste Identification (40 CFR Parts 261) United States Environmental Protection Agency September 2005

More information

TRAINING SPCC/SWPP Training UGA. Automotive Center. Campus Transit

TRAINING SPCC/SWPP Training UGA. Automotive Center. Campus Transit SPILL PREVENTION, CONTROL, AND COUNTERMEASURE TRAINING SPCC/SWPP Training UGA STORM WATER Automotive Center POLLUTION Campus Transit PREVENTION PLAN PLAN Goals of SPCC/SWPP Training Introduce facility

More information

CHAPTER 62-740 PETROLEUM CONTACT WATER

CHAPTER 62-740 PETROLEUM CONTACT WATER CHAPTER 62-740 PETROLEUM CONTACT WATER 62-740.010 Declaration of Intent (Repealed) 62-740.020 Applicability 62-740.030 Definitions 62-740.040 General 62-740.100 Management Practices for Producers of PCW

More information

Basic Information for Handling Hazardous Wastes

Basic Information for Handling Hazardous Wastes Basic Information for Handling Hazardous Wastes Provided by the Utah Department of Environmental Quality Division of Waste Management and Radiation Control 195 North 1950 West P.O. Box 144880 Salt Lake

More information

Managing Floor Drains and Flammable Traps

Managing Floor Drains and Flammable Traps Managing Floor Drains and Flammable Traps Contents: Problem... 1 Solution... 2 Maintenance... 2 Waste Management Options... 2 For More Information... 4 BMP Chart... 5 This fact sheet discusses recommended

More information

RAILROAD COMMISSION OF TEXAS APPENDIX C LIST OF E&P WASTES: EXEMPT AND NONEXEMPT

RAILROAD COMMISSION OF TEXAS APPENDIX C LIST OF E&P WASTES: EXEMPT AND NONEXEMPT RAILROAD COMMISSION OF TEXAS APPENDIX C LIST OF E&P WASTES: EXEMPT AND NONEXEMPT WASTE MINIMIZATION IN THE OIL FIELD - APPENDIX C NOTES RAILROAD COMMISSION OF TEXAS LIST OF E&P WASTES: EXEMPT AND NON EXEMPT

More information

Managing Hazardous Waste A HANDBOOK FOR SMALL BUSINESS

Managing Hazardous Waste A HANDBOOK FOR SMALL BUSINESS Managing Hazardous Waste A HANDBOOK FOR SMALL BUSINESS TABLE OF CONTENTS INTRODUCTION... 4 DECIDING WHETHER HAZARDOUS WASTE REGULATIONS APPLY TO YOU... 5 Defining Hazardous Waste... 5 Identifying Your

More information

SUBJECT: Effective Date: Procedure Number: Contractor Environmental Management. 09/03/13 emp11 Procedures

SUBJECT: Effective Date: Procedure Number: Contractor Environmental Management. 09/03/13 emp11 Procedures SUBJECT: Effective Date: Procedure Number: Contractor Environmental Management 09/03/13 emp11 Procedures APPLICABILITY/ACCOUNTABILITY: Supersedes: Page Of EMS Procedure-011 1 11 Responsible Authority:

More information

EPA s proposed hazardous waste pharmaceutical regulations

EPA s proposed hazardous waste pharmaceutical regulations EPA s proposed hazardous waste pharmaceutical regulations November 4, 2015 By J. Timothy Ramsey The United States Environmental Protection Agency ( EPA ) published proposed regulations in the Federal Register

More information

4.7.2 Regulatory Framework

4.7.2 Regulatory Framework CHAPTER 4 Environmental Analysis in the environment, can cause various human health effects, including liver injury, irritation of the skin and mucous membranes, and adverse reproductive effects. PCBs

More information

Newport News Shipbuilding Contractor Environmental, Health and Safety Resource Manual Waste Management

Newport News Shipbuilding Contractor Environmental, Health and Safety Resource Manual Waste Management Newport News Shipbuilding Contractor Environmental, Health and Safety Resource Manual Waste Management Newport News Shipbuilding Page 1 WASTE MANAGEMENT 1. Purpose and Scope a. The purpose of this section

More information

NASA Stennis Space Center Environmental Resources Document

NASA Stennis Space Center Environmental Resources Document 16.0 Major Environmental Considerations for Proposed Actions All construction, rocket testing, and operations that may potentially impact environmental media, such as air, water, land, aquatic and biotic

More information

Planning for Polychlorinated Biphenyl (PCB)-Containing Disaster Debris. June 2011

Planning for Polychlorinated Biphenyl (PCB)-Containing Disaster Debris. June 2011 Planning for Polychlorinated Biphenyl (PCB)-Containing Disaster Debris June 2011 Table of Contents INTRODUCTION... 1 PLANNING SUGGESTIONS FOR COMMUNITIES... 3 List of PCB-Containing Disaster Debris Management

More information

SPILL PREVENTION AND RESPONSE PLAN TEMPLATE FOR BUSINESSES IN DAYTON S SOURCE WATER PROTECTION AREA

SPILL PREVENTION AND RESPONSE PLAN TEMPLATE FOR BUSINESSES IN DAYTON S SOURCE WATER PROTECTION AREA SPILL PREVENTION AND RESPONSE PLAN TEMPLATE FOR BUSINESSES IN DAYTON S SOURCE WATER PROTECTION AREA Regulated Substance Management: All Regulated Substances, including chemical wastes, are to be managed

More information

The Texas A&M University System Environmental, Health & Safety Special Thanks to Koch Industries, Wichita, KS

The Texas A&M University System Environmental, Health & Safety Special Thanks to Koch Industries, Wichita, KS Universal Waste Management Training The Texas A&M University System Environmental, Health & Safety Special Thanks to Koch Industries, Wichita, KS Training Objectives In this training, you will learn: What

More information

Waste Handling & Disposal

Waste Handling & Disposal Objectives Cover Contain Educate Reduce/Minimize Product Substitution Description Improper storage and handling of solid wastes can allow toxic compounds, oils and greases, heavy metals, nutrients, suspended

More information

West Virginia Department of Environmental Protection Industrial Facility Closure Guidance Document. Revised July 2009

West Virginia Department of Environmental Protection Industrial Facility Closure Guidance Document. Revised July 2009 West Virginia Department of Environmental Protection Industrial Facility Closure Guidance Document Revised July 2009 Purpose Facility abandonment is a precursor to the creation of a Superfund site. These

More information

Contingency Plan Template. Hazardous Materials and Waste Management Division (303) 692-3300

Contingency Plan Template. Hazardous Materials and Waste Management Division (303) 692-3300 Contingency Plan Template Hazardous Materials and Waste Management Division (303) 692-3300 October 2008 Contingency Plan A Large Quantity Generator of hazardous waste must have a written contingency plan

More information

Treatment of Hazardous Waste On-Site by Generators

Treatment of Hazardous Waste On-Site by Generators IDEM Indiana Department of Environmental Management Office of Land Quality 100 North Senate Indianapolis, IN 46204 OLQ PH: (317) 232-8941 Guidance Treatment of Hazardous Waste On-Site by Generators The

More information

Exhibit A - Scope of Work

Exhibit A - Scope of Work Exhibit A - Scope of Work The Emergency Response and Hazardous Waste Management program responds to both emergency and non-emergency chemical spills, releases of regulated and/or hazardous materials, and

More information

Chapter 2 Stormwater Pollution Prevention Plan (SWPPP) for Park Operations

Chapter 2 Stormwater Pollution Prevention Plan (SWPPP) for Park Operations SWPPP for Park Operations 2 Chapter 2 Stormwater Pollution Prevention Plan (SWPPP) for Park Operations Bordered by Lake Washington & Lake Sammamish, the City of Bellevue has more than 60 miles of streams,

More information

BUSINESS LICENSE (2014) CHARTER TOWNSHIP OF FLINT 1490 S. DYE ROAD, FLINT Ml 48532 (810) 732-1350 OR FAX (810) 733-6919

BUSINESS LICENSE (2014) CHARTER TOWNSHIP OF FLINT 1490 S. DYE ROAD, FLINT Ml 48532 (810) 732-1350 OR FAX (810) 733-6919 BUSINESS LICENSE (2014) CHARTER TOWNSHIP OF FLINT 1490 S. DYE ROAD, FLINT Ml 48532 (810) 732-1350 OR FAX (810) 733-6919 PLEASE CHECK: NEW BUSINESS FEE: $75.00 YEARLY LICENSE RENEWAL FEE: $45.00 NAME OF

More information

Harvard University. Hazardous Waste Program Overview

Harvard University. Hazardous Waste Program Overview Harvard University Hazardous Waste Program Overview Outline Cradle-to-grave approach Hazardous Waste related laws RCRA inspections at Universities Roles and Responsibilities Sink Disposal Labelling requirements

More information

Fact Sheet: Disposal of Alkaline Batteries

Fact Sheet: Disposal of Alkaline Batteries Fact Sheet: Disposal of Alkaline Batteries August 1994 Disposal of Alkaline Batteries Introduction This fact sheet is intended for users of alkaline batteries. It describes how alkaline batteries should

More information

40 CFR 262.11 Hazardous Waste Determination

40 CFR 262.11 Hazardous Waste Determination 262.11 states, the following: 40 CFR 262.11 Hazardous Waste Determination [which is incorporated into 391 3 11.08(1) of the Georgia Rules for Hazardous Waste Management by reference] A person who generates

More information

Critical Regulations SUMMARY OF. Stormwater Management Regulations (National Pollutant Discharge Elimination System or "NPDES ) 40 CFR 122.

Critical Regulations SUMMARY OF. Stormwater Management Regulations (National Pollutant Discharge Elimination System or NPDES ) 40 CFR 122. SUMMARY OF Critical Regulations Stormwater Management Regulations (National Pollutant Discharge Elimination System or "NPDES ) 40 CFR 122.26 Spill Prevention, Control, and Countermeasures Rule (SPCC) 40

More information

Before beginning any construction or demolition activities at your construction site,

Before beginning any construction or demolition activities at your construction site, VII. Hazardous Substances (Superfund Liability) Requirements for Construction Activities Before beginning any construction or demolition activities at your construction site, you should evaluate the site

More information

UNIFIED FACILITIES GUIDE SPECIFICATIONS

UNIFIED FACILITIES GUIDE SPECIFICATIONS USACE / NAVFAC / AFCEC / NASA UFGS-02 81 00 (February 2010) ----------------------------- Preparing Activity: USACE Superseding UFGS-02 81 00 (April 2006) UNIFIED FACILITIES GUIDE SPECIFICATIONS References

More information

V. ENVIRONMENTAL IMPACT ANALYSIS E. Hazardous Materials

V. ENVIRONMENTAL IMPACT ANALYSIS E. Hazardous Materials E. HAZARDOUS MATERIALS An Environmental Site Assessment Phase I Update was performed on the subject properties by California Environmental Inc. in March 2000 1. This report is included in Appendix E of

More information

Training Module. Treatment, Storage and Disposal Facilities (40 CFR Parts 264/265, Subpart A-E) Introduction to

Training Module. Treatment, Storage and Disposal Facilities (40 CFR Parts 264/265, Subpart A-E) Introduction to Training Module Introduction to Solid Waste and Emergency Response (5305W) EPA530-K-05-017 Treatment, Storage and Disposal Facilities (40 CFR Parts 264/265, Subpart A-E) United States Environmental Protection

More information

Identifying Your Hazardous Waste

Identifying Your Hazardous Waste Division of Materials and Waste Management August 2015 Identifying Your Hazardous Waste As a business owner, it is important to know if you generate hazardous waste. Under Ohio EPA s rules, all wastes

More information

Hazardous Waste Generator Regulations. A User-Friendly Reference Document

Hazardous Waste Generator Regulations. A User-Friendly Reference Document Hazardous Waste Generator Regulations A User-Friendly Reference Document Version 6: August 2012 1 Table of Contents General Hazardous Waste Generator Resources... 10 CESQG Requirements... 11 Applicability...

More information

ROGUE VALLEY BUSINESS HAZARDOUS WASTE COLLECTION EVENT. FRIDAY, MAY 6, 2016 at Rogue Transfer Station at 8001 Table Rock Rd.

ROGUE VALLEY BUSINESS HAZARDOUS WASTE COLLECTION EVENT. FRIDAY, MAY 6, 2016 at Rogue Transfer Station at 8001 Table Rock Rd. ROGUE VALLEY BUSINESS HAZARDOUS WASTE COLLECTION EVENT for Oregon Businesses Producing Small Amounts of Hazardous Waste FRIDAY, MAY 6, 2016 at Rogue Transfer Station at 8001 Table Rock Rd. What s Happening?

More information

The Lamp Recycling Outreach Project

The Lamp Recycling Outreach Project Training Module (1-hour version) for Generators and Handlers Of Fluorescent and Mercury-Containing Lamps (and Ballasts) (Training required by the Universal Waste Rule) Prepared by: The Lamp Recycling Outreach

More information

Mechanical Systems Competency 1.20

Mechanical Systems Competency 1.20 Competency 1.20 Mechanical systems personnel shall demonstrate a working level knowledge of the safety and health fundamentals of mechanical systems and/or components. 1. Supporting Knowledge and Skills

More information

Hobart and William Smith Colleges. Environmental, Health and Safety Program

Hobart and William Smith Colleges. Environmental, Health and Safety Program Hobart and William Smith Colleges Geneva, New York Environmental, Health and Safety Program Copies of the EHS Program: 1. Human Resources Office 2. Office of the President (Provost) 3. Campus Safety Office

More information

Florida Department of Environmental Protection

Florida Department of Environmental Protection Florida Department of Environmental Protection Background Mobile vehicle and equipment washing involves washing at a location where vehicles are based (such as a trucking company, warehouse, bus station,

More information

Do you perform clearing, grading, or excavation activities?

Do you perform clearing, grading, or excavation activities? Federal Environmental Requirements for Construction What Do You Need to Consider? Do you perform clearing, grading, or excavation activities? Do you build roads, golf courses, playing fields, homes, or

More information

Environmental Compliance Consultation: DOE PCB Questions and Answers Part I

Environmental Compliance Consultation: DOE PCB Questions and Answers Part I Environmental Compliance Consultation: DOE PCB Questions and Answers Part I Office of Environmental Policy and Guidance, RCRA/CERCLA Division DOE/EH-413-0003 (June 2000) Summary This Environmental Compliance

More information