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TSDF Checklist Revisions for FY11 Todd L. Hardt DOECAP Operations Team

TSDF Checklist Revisions for FY11 Todd L. Hardt DOECAP Operations Team. ASP 2010 Workshop September 20-24, 2010 Seattle, Washington. FY11 TSDF Checklist Revisions. Waste Operations Checklist 3 LOI 3.3.2 states ;

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TSDF Checklist Revisions for FY11 Todd L. Hardt DOECAP Operations Team

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  1. TSDF Checklist Revisions for FY11Todd L. HardtDOECAP Operations Team ASP 2010 Workshop September 20-24, 2010 Seattle, Washington

  2. FY11 TSDF Checklist Revisions • Waste Operations Checklist 3 LOI 3.3.2 states; “For any mixed wastes stored greater than one (1) year, the facility can demonstrate that storage is solely for the purpose of accumulation of such quantities to facilitate proper recovery, treatment and disposal.” 40CFR268.50 Comment: 40 CFR 268.50 applies to non-mixed waste also.  Recommendation:The first few words should be changed to, “For any hazardous waste stored greater than one (1) year, ….”

  3. FY11 TSDF Checklist Revisions • Waste Operations Checklist 3 LOI 3.5.2 states; “Wastes are treated to established standards (e.g., LDR standards) or receiving facility acceptance criteria.” 40 CFR 268.40 Comment: There are also alternative standards at 40 CFR 268.45 and 268.49.  Recommendation: Change the regulatory reference to the more all encompassing citation“40 CFR 268”.

  4. FY11 TSDF Checklist Revisions • Waste Operations Checklist 3 LOI 3.6.1 states; “The facility has a Waste Analysis Plan (WAP) that documents the characterization of all site generated waste.” 40 CFR 262.11 Comment: 40 CFR 262.11 is titled “Hazardous Waste Determinations” for generators.  Generators are not required to have WAPs unless they are treating to meet an LDR standard. The WAP requirement is at 40 CFR 268.7. ”. Recommendation: Rewrite the LOI as “The facility has A Waste Analysis Plan that documents the characterization of all site generated waste treated to meet an LDR treatment standard.” 40 CFR 268.7

  5. FY11 TSDF Checklist Revisions • Waste Operations Checklist 3 LOI 3.7.2 states; “A procedure is in place that defines significant discrepancies and actions that should be taken” 40 CFR 264.71 Comment: There is no requirement to have a “procedure” to define significant discrepancies or the actions that should take place. The regulation at  40CFR264 defines these. Recommendation: Delete this LOI from the checklist.

  6. FY11 TSDF Checklist Revisions • Waste Operations Checklist 3 LOI 3.7.3 states; “Manifest discrepancies are documented and resolved with the generator within 15 days of receipt of waste.” 40 CFR 264.72 Comment: If not resolved within 15 days there is no violation unless the TSDF does not submit a manifest discrepancy report. Recommendation: Revise LOI to; “Manifest discrepancies are documented and resolved with the generator within 15 days of receipt of waste. If the discrepancy is not resolved within 15 days after receiving the waste, the facility submits a letter to the EPA and/or State describing the discrepancy and attempts to reconcile it and a copy of the manifest or shipping paper at issue” 40 CFR 261472

  7. FY11 TSDF Checklist Revisions • Waste Operations Checklist 3 LOI 3.7.4 states; “Facility has a program in place to track and ensure the outgoing manifests are returned within 35 days of the date the waste was accepted by the transporter.” 40 CFR 262.42 Comment: It is confusing that the checklist jumps from receiving manifests to outgoing manifests and skips the requirement to return a copy of the generator’s manifest within 30 days. Recommendation: Insert a LOI between 3.7.3 and 3.7.4 stating; “Facility has a program in place to return a copy of the generator’s manifest within 30 days of delivery.” 40 CFR 264.71

  8. FY11 TSDF Checklist Revisions • Industrial and Chemical Safety, Checklist 6 LOI 3.1.4 states; “ Chemical container labeling is adequate to convey hazard information. MSDSs are complete and readily available?” 29 CFR 1910.1450 (f)(3)(v) Comment: Container labeling and MSDS availability are two separate issues and should be addressed as such. Recommendation: Make two LOIs – one addressing labeling as referenced in 29CFR1910.122 (f) and one addressing MSDS as referenced in 29 CFR 1910.1450 (f)(3)(v)

  9. FY11 TSDF Checklist Revisions • Regulatory Citation Changes • Checklist 3, LOI 3.1.2; - Change 40CFR264.4 (e) and (f) to 40CFR261.4 (e) and (f) • Checklist 4, LOI 2.11; • Change 40CFR761.125, 40CFR271.61 to 40CFR761.125, 40CFR761.61 • Checklist 6, LOI 2.1.1; • Remove reference 19 CFR 1910.151 as it is incorrect

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