Every operation and remediation project creates by-products. Understanding how changes to operations and technology will affect they life-cycle of your process is a critical starting point for management of change. Often the waste products generated are ignored or poorly understood until RCRA comes calling.
Subtitle C of RCRA (Title 40 of the Code of Federal Regulation [40 CFR] Sections 261, 262, 264, 265, 266, 273 and 279) established a system for controlling hazardous waste, universal waste, and used oil from generation to disposal. Operators must demonstrate they have adequately determined if the materials can be defined as hazardous waste prior to transporting off site for disposal. If the product is considered hazardous waste, facility operators are further required to verify that the waste is managed, disposed, and/or recycled properly.
BBJ Group professionals review current processes and/or operations associated with the generation of waste materials, relevant facility permits, laboratory analytical results of waste product, and quantities of waste generated.
Active manufacturing operations and legacy remediation projects have the potential to generate wastes that can qualify for a variety of disposal AND reuse options. Based on the information provided, BBJ Group will determine the appropriate management, transport, disposal and recycling practices for the waste material.
Materials which are recycled or reused can often be excluded from consideration as hazardous waste, and also present an opportunity for cost savings, and possibly even revenue, from selling of waste materials to another entity. In addition to ensuring waste materials are handled responsibly, BBJ professionals can identify opportunities for beneficial reuse.
For waste materials subject to RCRA regulations, on-going annual and/or biennial reporting is required, based on generator size and state-specific hazardous waste tracking requirements. Let BBJ professionals keep track of your reporting requirements and help you keep operations compliant and open for business.
Richard Garlitz, P.E.
J. Timothy Bradburne, P.E.