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Hazardous Waste Management New England Marina Meeting March 30, 2006. U.S. Environmental Protection Agency (EPA) Region 1 New England. Where to look for Guidance. EPA Office of Compliance Sector Notebook Project.

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hazardous waste management new england marina meeting march 30 2006

Hazardous Waste Management New England Marina MeetingMarch 30, 2006

U.S. Environmental Protection

Agency (EPA)

Region 1 New England

epa office of compliance sector notebook project

Where to look for Guidance

EPA Office of Compliance Sector Notebook Project

“Profile of the Water Transportation Industry”, September 1997, EPA/310-R-97-003

“Profile of the Shipbuilding and Repair Industry”, November 1997,


Shipshape Shores and Waters- A Handbook for Marina Operators and Recreational Boaters, January 2003, EPA-841-B-03-001 www.epa.gov/owow/nps/marinashdbk2003.pdf

rcra components
RCRA Components

Subtitle C - Hazardous Waste

Subtitle D - Solid Waste

Subtitle I – Underground Storage Tanks

Subtitle C – Cradle to Grave Control of Hazardous Wastes

rcra subtitle c goals
RCRA Subtitle C Goals
  • protect human health and environment from hazards posed by waste disposal,
  • To ensure that wastes are managed in a manner that is protective of human health and the environment.
  • To conserve energy and natural resources

via waste recycling and recovery,

  • To reduce or eliminate the amount of waste generated
statutory definition of solid waste
Statutory Definition of SolidWaste

….any garbage, refuse, sludge from a waste treatment plant, water supply plant or air pollution control facility, and other discarded material, including solid, liquid, semisolid, or contained gaseous material...


statutory definition of hazardous waste
Statutory Definition of Hazardous Waste

A “solid waste, or a combination of solid wastes, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may:

1) Cause, or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness or

2) Pose a substantial present or potential hazard to human health or the environment when improperly treated, store transported, or disposed of, or otherwise managed.”

a solid waste is hazardous if it
A Solid waste is hazardous if it:
  • Exhibits any of the characteristics of a hazardous waste
  • Has been named as a hazardous waste and listed as such in the regulations
  • Is a mixture containing a listed hazardous waste and a non-hazardous solid waste
  • Is a waste derived from the treatment, storage, or disposal of a listed waste
characteristic hazardous wastes
Characteristic Hazardous Wastes
  • Ignitability
  • Reactivity
  • Corrosivity
  • Toxicity (via TCLP)
three lists of hazardous wastes
Three Lists of Hazardous Wastes
  • Non-specific Source Wastes
  • Specific Source Wastes
  • Commercial Chemical Products
it is your responsibility

As the Owner/Operator you must know all the waste streams you generate and which ones are Hazardous Wastes and, therefore, regulated.

Do Hazardous Waste Determinations!!

epa federal state regulations
EPA/Federal & State Regulations
  • citation: 40 CFR Parts 260-299
  • authorized states and their regulations

[equivalent or more stringent than feds]

hazardous waste determinations
  • Generator’s responsibility
  • Process knowledge
  • Analysis
  • MSDS
  • Expiration dates
  • Variability of waste streams
  • Cross contamination
waste activity notification and generator classification
Waste Activity Notificationand Generator Classification
  • Large Quantity >1000Kg (2200#) ……………..…LQG

(1 Kg Acutely Toxic Wastes)

  • Small Quantity 100-1000Kg (220-2200#)………..SQG
  • Conditionally Exempt SQG <100Kg (220#)…...CESQG

Amount Generated =Classification with accumulation limits.

[Volume and Time]

[There are State Variations- see State Regulations]

Depending on Your Classification, There Are Requirements for…..
  • Record keeping
  • Housekeeping
  • Accumulation Time Limits
  • Emergency Preparedness Needs
  • Employee Training
specific container management requirements for
Specific Container Management Requirements for ……

Satellite vs. Non-Satellite Storage Areas

management requirements in container storage areas



Aisle space

Open/Closed Containers

Condition of containers

Ignitable waste special requirements

satellite storage
Satellite Storage…..
  • At or near point of generation
  • Under the control of the operator of the process
  • Less than 55-gallons of wastes – total
  • Labeled “Hazardous Waste” or other words to describe contents
  • Keep containers closed, except when adding or removing
depending on classification container storage area inspections

The owner or operator must inspect areas where containers are stored, at least weekly, looking for leaks and for deterioration caused by corrosion or other factors.

manifesting wastes requirements
Manifesting Wastes Requirements

Key to Cradle to Grave


land disposal restriction notifications
Land Disposal Restriction Notifications
  • Protect human health & environment
  • Minimize reliance on land disposal
  • Determine if wastes generated are restricted from land disposal.
  • Determine the appropriate treatability group (if any) for restricted wastes.
  • Determine if wastes meet treatment standards as generated.
hazardous waste training
  • Initial training
  • Annual refresher training
  • Documentation of training program and employee training records
  • Relevant to job duties performed
  • Training program led by qualified staff
  • document Job titles and Job descriptions

RCRA Training is not OSHA or Emergency Response training. RCRA Training develops understanding of appropriate hazardous waste management practices.

preparedness and prevention

Facilities must be maintained and operated to minimize the possibility of a fire, explosion or release of hazardous waste or hazardous constituents.

contingency plan
  • must be designed to minimize hazards to human health and the environment from fires, explosions, or release of hazardous waste or hazardous waste constituents.
  • must be carried out immediately.
  • describe detailed response actions
  • provide for arrangements with locals
  • designate Emergency Coordinator and alternates
  • identify emergency equipment
  • identify evacuation plans
preparedness and prevention1
  • Alarm system
  • Communication devices
  • Extinguishers
  • Adequate water supply
  • Adequate aisle space
  • In-place arrangements with locals [fire, police, hospitals]
universal waste

Universal wastes are widely generated and widely recycled hazardous wastes. Management standards for these wastes are reduced to facilitate their recycling.

types of universal waste
  • Batteries
  • Mercury containing thermostats
  • Hazardous waste lamps
  • state specific UWs
universal waste requirements
Universal Waste Requirements..
  • Containerized
  • Labeled to describe content
  • Dating
  • Training
  • Record keeping
rcra compliance evaluation inspection outline
RCRA Compliance Evaluation Inspection Outline
  • Unannounced
  • Most are multi-day
  • Physical inspection of waste storage, generation points and processes, tour of operations and property
inspections continued
Inspections - continued

Opening Conferencethe inspector may ask

  • How many employees and shifts
  • What is your generator status
  • For explanation of processes, description of wastes and where generated
  • Where wastes are stored- satellite and 90/180 day
  • Inspector will explain how the physical inspection will proceed
  • Inspector will request availability of documents for records review
inspections continued1
Inspections (continued)…
  • Documents for Record Reviews includes but is not limited to:
    • training documents, contingency plans, shipping documents and LDRs, waste determination documentation, inspection logs, Biennial Reports, emergency preparedness information, import/export documentation
inspections continued2
Inspections (continued)

Close-Out Conference

  • Ask for additional information.
  • Review areas of concern from walk- through and record review.
  • Explain potential follow up.
  • Give facility representatives an opportunity to comment or ask questions.
post inspection
  • Information Requests
  • Possible Case Development Inspections
  • Inspection Report
  • Several months possible
common marina wastes
Common Marina Wastes
  • Paint and paint related wastes
  • Aerosol cans
  • Chemical stripping wastes
  • Abrasive stripping wastes
  • Equipment cleaning wastes
  • Machine Shop wastes
  • Engine Repair wastes
  • Waste Oils, gear and lube oils
common marina wastes1
Common Marina Wastes
  • Transmission fluid
  • Waste fuel
  • Welding wastes
  • Fiberglass fabrication (solvents, resins, gelcoat wastes)
  • Leftover raw materials/ Off-spec products
  • Acids and alkalis
  • Metal finishing wastes
common marina wastes2
Common Marina Wastes
  • Pb/acid batteries
  • Bilge water/bilge sludges
  • Engine test tank waters
  • Parts washer waste
  • Rags
  • Adhesive wastes
common marina wastes3
Common Marina Wastes
  • Electronics wastes
  • Pesticides and herbicides
  • Compressed gas cylinders
  • Filters- fuel, oil, paint booth
  • Antifreeze (benzene)
  • Dust collection system residues
common areas of observed violations
Common Areas of Observed Violations
  • Hazardous Waste Determinations
  • Main Hazardous Waste Accumulation Area and/or Satellite Accumulation Area Container Mismanagement
    • Open Containers
    • Aisle space
    • Secondary Containment
  • Unmarked/Unlabeled Containers
  • Incompatible Storage
  • No or Inadequate Land Disposal Restriction (LDR) Notices
common areas of observed violations continued
Common Areas of Observed Violations (continued)
  • No or incomplete Hazardous Waste Manifests
  • Inadequate Emergency Preparedness and Inadequate/Outdated Contingency Plan
  • No or Inadequate Hazardous Waste Training
  • No or inadequate In-house Inspections
  • Storage > 180 Days, >90 Days w/o Permit
hw determination violations
HW Determination Violations

What we find...

  • Mischaracterized or uncharacterized wastes; or
  • Materials that are unused and pending disposal not characterized

What we want...

  • All wastes/materials characterized as soon as they are generated or when they are not going to be used
hw determination violations continued
HW Determination Violations (continued)


Certain wastes have adverse affect on human health and/or the environment - that's why they're regulated.


open containers violations
Open Containers Violations

What we find...

  • Containers with no cover, no bung, or open funnel in bung

What we want...

  • All containers of hazardous waste closed unless materials are being added or removed


  • Materials can be easily spilled from an open container. Volatile materials may escape.
unmarked unlabeled container violations
Unmarked/Unlabeled Container Violations

What we find...

  • Hazardous waste containers that have missing information/no information or are not dated

What we want...

  • Containers with labels that say the words "Hazardous Waste" and a description of the waste and the date when the waste started to accumulate (and sometimes more).
unmarked unlabeled containers continued
Unmarked/Unlabeled Containers (continued)


  • A properly labeled container assures that everyone, including workers and emergency responders, knows that there is a hazardous waste in the container and exactly what the waste is. Helps avoid mismanagement.
unmarked unlabeled containers continued1
Unmarked/Unlabeled Containers (continued)
  • Has caused wastes to be commingled
  • Results in no one knowing what the container holds, for example:

-person who knew has left the company

-person who knows is on vacation when inspector arrives

  • Can increase need for laboratory waste stream analysis for waste determinations
satellite accumulation violations
Satellite Accumulation Violations

What we find...

  • Hazardous waste drums being stored far from the place where the wastes are generated
  • ...not under anyone's control
  • ...more than 55-gallons

What we want...

  • At or near the point of generation and under the control of the operator, no more than 55-gallons, and container meets management requirements
satellite accumulation violations continued
Satellite Accumulation Violations (continued)


  • We don't want people walking long distances with uncontrolled quantities of hazardous waste
  • We want someone watching over these containers.
  • We don't want a lot of material hanging around.
incompatible waste storage violations
Incompatible Waste Storage Violations

What we find...

  • Incompatible materials stored next to each other, or stacked on top on one another.

What we want...

  • Incompatible materials separated by a berm, dike, wall or other physical barrier.


  • KABOOM!!!
hazardous waste training violations
Hazardous Waste Training Violations
  • Common Issue!
  • Annual training conducted once and lapses
  • Training is not relevant to duties performed
  • Documentation is not maintained
  • No plan on who should be trained and what they should be trained on
  • Job descriptions not available or…
hazardous waste training violations continued
Hazardous Waste Training Violations (continued)
  • Available, but no longer applicable for employee - For example:

- personnel have rotated and job description no longer fits, or

- job duties have changed and no longer match the job description

Note: A bad training program will lead to poor waste management!

ldr notices copies violations
LDR Notices/Copies Violations

What we find…

  • Notices not completed at all or incomplete
  • Copies are not maintained or available at the facility

What we want…

  • Copies of all fully completed notices maintained for 5 years.


  • It is important that all parties that manage the hazardous waste know that it must be treated before disposal.
hazardous waste manifest violations
Hazardous Waste Manifest Violations

What we find…

  • Photocopies maintained in lieu of actual records
  • Completed signed copy not maintained (most important manifest document!)

What we want…

  • Copies of manifests maintained for 3 years.
  • Copies of exception reports maintained.


  • This is the cradle to grave tracking system that ensures that hazardous wastes safely reach a designated facility.
contingency plan violations
Contingency Plan Violations

What we find...

  • No contingency plan
  • Information in plan is old, incorrect telephone numbers or procedures; and
  • Copies not sent to the appropriate parties.
  • People listed in the plan have left
  • Local officials have not been sent copies of the plan
  • Emergency equipment descriptions and locations are missing or outdated
  • Plan does not address required incidents, for example:

- spills - explosions

- fires - releases

contingency plan violations continued
Contingency Plan Violations (continued)

What we want...

  • Name and telephone number of facility person in charge of emergency response (plus back-up)
  • Telephone numbers of local authorities (e.g., fire, hospital, police, DEP, NRC), response contractor
  • Procedures on what to do in the case of a fire, flood, leak, spill, and for loading/unloading waste at your facility
  • Lists, locations, and capability of emergency equipment;
  • have it readily available and send copies to all local authorities
  • Evacuation plan and evacuation routes
contingency plan violations continued1
Contingency Plan Violations (continued)


  • It should be clear to all affected employees and anyone responding to an emergency what types of materials are at the facility, what to do, where to go, and who to call.
weekly daily inspection violations
Weekly/Daily Inspection Violations

What we find…

  • No weekly/daily inspections/missed inspections
  • Not all areas inspected
  • Inspections/corrective actions not documented
weekly daily inspection violations continued
Weekly/Daily Inspection Violations (continued)

What we want…

  • Inspections of satellite and main accumulation areas

- weekly for containers

- Daily for tanks

  • Inspections of tanks- container management standards, leaking? or deterioration?
  • Paper documentation for each area including comments and corrective actions taken
  • Minimum for most states, except for MA

****(It’s ok to document a problem.)

weekly daily inspection violations continued1
Weekly/Daily Inspection Violations (continued)


  • It’s important to conduct a regular check to ensure that all management requirements are met and that no leaking or deterioration has occurred.
storage for greater than 90 or 180 days
Storage for Greater than 90 or 180-Days

What we find…

  • Forgotten drums
  • Non-compliant satellites
  • Just didn’t ship

What we want…

  • Wastes regularly moved off-site in less than 90- days or 180-days.


  • We don’t want large quantities of hazardous waste accumulating for long periods of time without additional precautions of a permit (i.e., closure plans and financial assurance).
epa enforcement
EPA Enforcement

Goals of Enforcement

  • Environmental Protection
  • Correction of Violations
  • Deterrence
  • Fairness – level playing field
  • Punishment
enforcement response
Enforcement Response

Informal Actions


  • No penalties associated
  • List violations
  • Schedules for Return to Compliance
enforcement response1
Enforcement Response

Formal Administrative Orders

  • Penalty Actions ($32,500/day/violation)
  • Require Corrective Actions
  • Requires Return to Compliance
  • SEPs
enforcement response2
Enforcement Response

Civil Judicial Actions

  • Referrals to DOJ
  • Lawsuit in Federal District Court
  • Can take several years to complete
enforcement response3
Enforcement Response

Criminal Actions

  • Knowing, willful, or negligent acts
  • Fines, imprisonment for individuals
enforcement response4
Enforcement Response

RCRA cases can range from $10K to multi-million dollars in penalties and require extensive corrective measures


Susann Nachmann 617-918-1871

Richard Piligian 617-918-1757