Category: RCRAA

The Thin Green Line

January 06, 2012   nlrgreen   No comments

Green Line

Programs like office paper, glass and can recycling are often implemented by a business’s  ”green team’ or as part of a corporate sustainability program. These programs help not only the environment but also provide a tangible aspect to a businesses green image and environmental responsibility. A corporate officer or employee can easily see the recycling bins and see what they have accomplished. However a company may not be subject to EPA fines if  the program is improperly managed or liable for incorrect storage of these items.* Would a EPA auditor say “Hey those aluminum cans and paper for shredding have no accumulation date.” or “What is your procedure to guard against environmental breach of those Snapple bottles?”. Most likely not. So when does environmental responsibility become a environmental requirement? Answer: When a company generates used lamps, batteries, ewaste, ballasts or mercury devices.

While used fluorescent lamps are taken away to the proper storage containers in the back of a  facility may not be in your face “look at us we recycle” it is still environmentally friendly and most importantly is the LAW.  Simple things such as having a universal waste recycling program, trained staff or properly stored containers with accumulation dates can help companies be compliant and reduce their liability. All of these things can be accomplished without a environmental health and safety officer or being a draw on budgets. The below are a few simple steps to successful universal waste recycling:

1) Learn & Educate-Understand your state’s regulations and specifics on universal waste
• What is Universal Waste? • RCRA Requirements • My State’s Regs
2) Assess Your Company- Take a general look at what universal waste your company produces and how often. See if you are a small or large generator3) Plan the Program- Based on the amount of waste generated see if a national mail-back program or bulk pick-up service is needed. Also look at factors beyond quantities such as ease of management, your facilities locations, or specific needs of your industry.

4) Implement & Monitor- Once you have selected the proper program be sure to implement it company-wide, educate employees, monitor progress, keep recycling records/certificates and evaluate the program yearly.

5) Have Questions or Need Assistance? Get Help-Call 877.822.4733 to discuss your company’s specific needs, implement a new program or to enhance a current one.
*depending on what state your company is in this may not be true. Check your local laws and regulations.

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The Council Addresses PCBs in Schools (Gotham Gazette)

December 20, 2011   nlrgreen   1 Comment

by Jane C Timm
In what advocates say is the most sweeping legislation in the country to tackle PCB-contamination problems, two City Council bills unanimously passed yesterday will inform parents and school employees of contamination in schools and add transparency to the clean-up process.

PCB, or polychlorinated biphenyl, is a chemical that was widely used as a coolant and dielectric before it was banned it in 1979 for its toxicity.

The first bill 563 requires the Department of Education to notify parents and employees of PCB testing results or if the school uses T12 fluorescents, an outdated type of lamp that often leaks PCB. A second bill 566 asks for detailed reports from the DOE on their progress and plan eradicating PCB from schools.

Councilman Vincent Ignizio spearheaded the effort after he learned of a T12 fluorescent that was leaking PCB onto a carpet where grade-school children sat. “That’s where this started,” he said.

Nearly 800 city schools — built between the 1950s and late 1970s — are likely contaminated. PCB can hurt cognitive development in children, studies show. It also has been linked to cancer and a variety of other illnesses. Exposure to the chemical is particularly dangerous to young girls, who carry the chemicals in their bodies for years and pass them on to their offspring, as well as pregnant women, whose unborn children can be harmed by the exposure.

“Parents deserve to know what type of environment their children are learning in and school employees should be able to walk into their buildings with knowledge, not fear,” Council Speaker Christine Quinn.

via The Council Addresses PCBs in Schools (Gotham Gazette, Dec 20, 2011).

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Waste & Recycling News – EPA fines Iowa company for hazardous waste violations

September 27, 2011   nlrgreen   No comments

Sept. 27 — A steel castings facility in Iowa has agreed to pay a $54,786 civil penalty and clean up residual used oil as part of a settlement with the U.S. EPA over violations of federal hazardous waste regulations.

Sivyer Steel Corporation of Bettendorf, Iowa, committed several violations of the federal Resource Conservation and Recovery Act, including operating a hazardous waste facility without a permit, the EPA said. The agency inspected the facility in March 2010 and noted the violations, including failure to comply with hazardous waste generator requirements.

The company must act within 30 days to show that its used oil containers and universal waste lamp containers are properly maintained and labeled.

via Waste & Recycling News – EPA fines Iowa company for hazardous waste violations.

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Yonkers launches fluorescent bulb recycling

May 25, 2011   nlrgreen   No comments

Under the terms of an enforcement agreement with the United States Environmental Protection Agency (EPA), the City of Yonkers has initiated a program to recycle fluorescent light bulbs, as well as light ballasts and electronic waste, known as E-waste. Fluorescent bulbs contain mercury, which can be released if the bulbs are broken. By collecting and recycling these bulbs from city residents, Yonkers will be helping to reduce the release of mercury to the environment.

In 2008, EPA inspected various buildings belonging to Yonkers and requested documentation regarding the city’s spent bulb recycling efforts. After the city did not adequately respond, EPA cited the city for violating the Resource Conservation and Recovery Act, the federal law governing the treatment, storage, and disposal of hazardous waste.

Agency regulations require that spent mercury and other toxic metal-containing bulbs from business, industry and government be handled as hazardous waste, which means they must be disposed of in specially licensed facilities. As an alternative, they can be handled under simpler universal waste rules to encourage their recycling.

Under the terms of the settlement, Yonkers will begin collecting spent fluorescent bulbs, light ballasts and e-waste from Yonkers residents. The city will widely publicize the program.

via American Recycler, May 2011 | Yonkers launches fluorescent bulb recycling.

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What is RCRA?

March 29, 2011   admin   No comments

Enacted in 1976, The Resource Conservation and Recovery Act (RCRA) addresses how to safely manage and dispose of the large volumes of industrial and municipal waste generated nationwide. EPA’s Office of Solid Waste (OSW) administrates the program. The goals of the program include: protecting the community from the inherit hazards of waste disposal, using recycling and recovery to conserve energy, try to eliminate or reduce waste, and the clean up of any improperly disposed of or spilled waste.

The Resource Conservation and Recovery Act (RCRA) requires generators of solid wastes containing toxic constituents (such as mercury) to test representative samples of their waste before disposal to decide whether the waste is hazardous. According to RCRA, generators of used fluorescent lamps are responsible for determining whether their lamp wastes are hazardous. If you do not test used fluorescent lamps and prove them non-hazardous, assume they are hazardous and dispose of them accordingly. Using a specific type of fluorescent lamp, i.e. a “low mercury” or “environmentally friendly,” does not satisfy the requirements. Most importantly, these lamps do not eliminate your liability. They still contain mercury and according to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), you can still be subject to superfund demands.

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