RCRA Permitting If your site generates large volumes of HW which require costly transportation and disposal from off-site TSDFs, particularly if your facility is in a remote location and seeking more in-house control and self-sufficiency, it may be worth considering a RCRA Permit. A RCRA Permit affords the site the ability to store and treat HW in permitted waste management units that are not limited by the stringent ENU, WTU, and TETU provisions and limited scope of generator treatment options. RCRA Permits are issued for 5 to 10 years depending on the authorized state agency. The full timeline for RCRA Permit issuance ranges from 1-2 years for non-thermal treatment and 2-3+ years for thermal treatment, such as energy recovery or incineration, so plan accordingly. If you’d like to discuss generator treatment or RCRA permitting, consider reaching out to our team of experts at +1.800.229.6655 or via email at:
f HW recycled without prior storage or accumulation in an on-site process • Note, EPA and state agencies have historically interpreted storage as 24 to 72 hours, though the actual timeframe is not codified The Universal Waste (UW) rules also allow for certain types of activities which may be considered treatment (e.g., disassembly and removal of electrolyte from batteries, puncturing and draining aerosol cans), but UW is not counted towards the monthly generator total or subject to generator recordkeeping and reporting. Aside from WAP conditions for LDR treatment, there are no federal recordkeeping and reporting requirements specific to generator treatment that are distinct from standard generator requirements. Waste characterization, on-site accumulation, and monthly generator status determinations still apply, unless treatment satisfies the aforementioned exemptions and removes HW characteristics from the treated streams. Hazardous waste treatment byproducts and residuals which are characterized or listed HW and shipped off-site must be manifested and LDR notifications apply (e.g., small quantity HW burner produces HW ash, sorbent addition to containers to reduce free liquids does not remove HW determination, chemical precipitation to remove HW toxic metals as a separable solid). It is recommended to document any exempt and permissible treatment in the generator’s Personnel Training Plan, Contingency/Preparedness & Prevention Plan, and Waste Minimization Plan, as applicable. Note, the EPA Site ID form (Form 8700-12) requests notification of treatment, but this does not apply to exempt treatment. It is recommended to retain records of on-site treated mass/volume akin to standard HW generation records. Always consult state agency resources as certain states have more stringent recordkeeping and reporting requirements for generator treatment.
Generator Treatment: Regina DiLavore - regina.dilavore@trinityconsultants.com
RCRA Permitting: Branden Barry – bbarry@trinityconsultants.com
RELATED TRAINING
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