The treatment, generation, storage, transportation and disposal of hazardous and solid waste are regulated by the Resource Conservation and Recovery Act (RCRA). Environmental Protection Agency (EPA) is given the authority to conduct evaluation and compliance inspections of facilities producing hazardous materials and waste under RCRA subtitle C-section 3007. The EPA inspector ensures that firm producing hazardous waste material is regulating, and ensuring compliance with the regulations of RCRA.
The EPA inspector before coming to the site visit normally reviews the facility records and files. On visiting the site, the inspector asks for the firm’s environmental coordinator or person in charge. The inspector reviews the firm’s processes, the types of hazardous materials produced and how the waste produced in the firm is managed. The inspector can review various records of the firm like contingency plans, material purchasing records, training records, annual reports, Operation records, Emergency response plans and procedures, firm’s process information, self-monitoring records, engineering assessments and manifests etc. The inspector can also take the copy of all these records and may check the past as well as the current records.
The inspector has all the authority to collect samples of waste materials, wastewater discharges and air emissions etc. The samples will be tested to verify the compliance as per RCRA rule. The inspector can also take the photographs of the firm’s operations, and other activities like treatment and disposal of waste, storage methods, devices used for controlling air pollution.
On finding the violation of any requirement of RCRA subtitle, for any past or current violation, the EPA can pass an order seeking a penalty of up to $37,500 per day per violation. The EPA may seek compliance within a specified time period or immediately. A Civil action may also be initiated against the firm. EPA may also ask for “relief” i.e. issuing a permanent or temporary order to stop the activity.
Requirements for “Transporter” of Hazardous Waste
Hazardous waste transporters may transport the hazardous waste from the generator’s facility to another site that can treat, recycle, dispose or store the waste. They can transport the waste by air, water, rail or highway. A person cannot transport the hazardous waste unless the person is issued a valid registration by the Department of Toxic Substances control (DTSC). All hazardous waste transporters must have EAP identification identity which is used to track the waste handler and waste from its original point of generation to the final destination.
The person transporting hazardous waste must have the ability to provide a fast and adequate response to protect human health and the environment in case damages result during transportation. The waste that is to be transported will only be accepted when a Uniform Hazardous Waste Manifest is completed and signed by the transporter and the generator. The transporter should keep this manifest with him while transporting the waste.
The waste needs to be delivered to the authorized facilities only and if the waste cannot be delivered to the mentioned site, the transporter should contact the generator and get the manifest revised according to the generator’s instructions. The transporter needs to keep the copies of these manifests for three years from the date the waste was transported.
The vehicles used for the transportation of hazardous waste should be in sound and good condition and must have a trademark of the firm that should be visible from 50 feet during the daylight, on each side of the vehicle. Waste subjected to wind dispersal needs to be transported in closed and covered containers. Thus, the transporter of Hazardous waste needs to follow all these requirements mentioned above.
Works Cited
Allegri, Theodore. Handling and Management of Hazardous Materials and Waste. New York: Springer Science and Business media, 2012.
epa.gov. RCRA Corrective Action Enforcement Authorities. 5 Jan 2016. <http://www.epa.gov/enforcement/rcra-corrective-action-enforcement-authorities>.
