RCRA context to compliance details. Pick your topics!
Managing hazardous waste in full compliance with the Resource Conservation and Recovery Act (RCRA) requires an understanding of requirements that apply at generation, accumulation, storage, transportation, and disposal. Compliance strategies change at each stage and those responsible for hazardous waste management must understand how they are interrelated.
“The books and information in the binder were over and beyond any training course I have taken. They were well put together.” – Jacob Masterson, Waste Masters
The Aarcher Institute’s Hazardous Waste Compliance Manager™ course is designed to provide both beginning and advanced waste generators, handlers, and managers with the tools and understanding needed to master the complexities of RCRA, while avoiding the confusion and faulty interpretations that can lead to regulatory pitfalls. This 5-day course incorporates a series of presentations, in-depth discussions, and practical exercises designed to guide participants towards mastery of RCRA.
DAY 1: Identifying and Characterizing Wastes Accurately: The EPA requires businesses to understand and determine whether or not their waste is hazardous. We start with a basic overview of the history of waste disposal and the legacy of issues created by past practices (legal and illegal). In order to understand how RCRA impacts many facilities, we incorporate a virtual facility into the training. This facility is representative of many RCRA problems that will be discussed throughout the 5 days. Day 1 continues with an understanding of the EPA’s definitions of “Solid Waste” and “Hazardous Waste.” We will provide a process for determining if wastes are hazardous and, if so, what waste code (or codes) apply and how to identify characteristic wastes and listed wastes, how spent solvents are regulated, and how mixtures and treatment residues are regulated. However, we believe that it is critical to understand how to utilize the tools we provide at the outset of the day, including Title 40 Subtitle C of the Code of Federal Regulations and RCRA Unraveled to find the information you need.
DAY 2: Waste Accumulation & Management: Each day will start with a short review of the previous day. Day 2 begins with a quick review of Day 1 and answering any questions held over from the previous day. We will continue Day 2 by helping you understand the rules you have to comply with if you generate hazardous waste by covering key RCRA requirements for both small- and large-quantity generators and provide you with practical guidance on how to comply. Major topics include waste counting, satellite and 90/180-day accumulation, and recordkeeping. You will also learn how the major exclusions and exemptions work and how to manage special types of hazardous waste such as universal wastes, electronic wastes, aerosol cans, and solvent-contaminated wipes.
DAY 3: Transfer & Disposal: After a review of Day 2, we will start Day 3 by reviewing and clarifying complicated aspects of RCRA. For example, we will explain how to treat wastes without a permit and how to determine if recycled material is a “solid waste.” As the EPA is moving toward an electronic manifest system, we’ll review the current paper manifest as well as an update on the EPA’s implementation of the “e-manifest” and the impact on the land disposal restrictions (LDR) and present specific procedures for LDR compliance. You will also gain an understanding of the importance of treatment standards, identifying underlying hazardous constituents (UHCs), and how to fill out the paperwork.
DAY 4: Advanced RCRA Compliance: Day 4 will begin with our review of Day 3 and continue the discussion of advanced RCRA topics beginning with the RCRA air emission standards in Subparts AA, BB, and CC. We’ll also discuss the top ten most common RCRA violations and how to avoid them. Other topics include sampling, used oil management, and the most important things you need to know about hazardous waste tanks, surface impoundments, and waste piles. We will also review what to expect during a RCRA inspection.
DAY 5: Spills & Releases: Day 5 is a half-day program (we adjourn at noon) covering corrective action, the contained-in policy, and remediation waste management. Spills and spill residues are potentially regulated under RCRA and we will discuss how to manage them under the federal program and some state examples. We will also review some considerations when managing debris from demolition projects. We will conclude with a review of the changes that have occurred in recently RCRA preview of how RCRA may change in the next few years.
Annual Training: It’s the Law – Civil penalties are as high as $93,750 per day, per violation. Federal and state hazardous waste regulators require annual training for all facility personnel who affect RCRA compliance, including full-time, part-time, shift, and contract workers [40 CFR 262.34(a) and 265.16].
“This is the best hazardous waste class I’ve ever had. [Instructor] was very thorough and covered a wide variety of information in a relatively short period of time. The slides were concise and to the point and the regulation books were well-used. I would definitely recommend this class.” – Tim McKeone, ConAgra Foods, Inc.
Topics covered include:
- Hazardous Waste Identification and Characterization
- Understanding Legal Responsibilities and the Structure of RCRA
- EPA Enforcement and Avoiding Common Violations
- Hazardous Waste Identification and Characterization
- Hazardous Waste Recycling Exclusions (including requirements and reliefs under EPA’s 2015 Definition of Solid Waste)
- Generator Requirements
- On-Site Storage Options (90/180 day storage, Satellite Storage)
- Used Oil Management
- “Special Hazardous Wastes” (Universal Wastes, Electronic Wastes, Aerosol Cans, and Solvent-contaminated Wipes)
- Emergency/Contingency Plan Preparation
- Treating Hazardous Waste
- Shipping Hazardous Waste
- Hazardous Waste Manifest (e-manifest update)
- Release Reporting
- Land Disposal Restrictions (Treatment Standards and Underlying Hazardous Constituents)
- Air Emissions under Subparts AA, BB, and CC
- Remediation, Demolition, and Spills (Managing Contaminated Media and Debris from Spills and Spill Residues, Demolition Projects)
- RCRA Update
What will I receive?
You will be provided with a course binder, example documents, reference materials, and other tools that will be valuable after the course:
- Aarcher Institute’s “RCRA Desk Reference”
- Code of Federal Regulations 40 CFR Parts 260-265
- McCoy’s RCRA Unraveled
- Aarcher handheld reference guides
Upon successful completion of the workshop, students can earn up to 36 CEUs.