Focus on Speculative Accumulation Generators accumulating Hazardous Secondary Materials (HSM) for reclamation and reuse need to satisfy the regulatory requirements set forth in §40CFR 261.1 which states in section (c)(8): A material is “accumulated speculatively” if it is accumulated before being recycled. A material is not accumulated… Read More »Rules Around Speculative Accumulation
Published January 14th, 2021 by Brian Burns We met our Goal Zero Standard – Zero Injuries, Zero fines, Zero Compliance Actions, Zero Insurance Claims WTS was honored by the ACC as the Responsible Care Partner… Read More »2020 RCMS Annual Report
Corporate goals drive sustainability initiatives that include Zero Landfill mandates, yet certain waste materials and by-products don’t have established recycling technologies or intrinsic value to drive this effort. In the case of remediation waste from… Read More »Beneficial Use Determination (BUD) – “Finding Options for Landfill Cover Materials”
When evaluating a new project many factors are involved in determining if you need an air permit or a modification of an existing permit. Following is an attempt to lay out the necessary steps to… Read More »Do I Need An Air Permit?
Is there a special permit that allows for mixed batteries (Alkaline, Nickel Cadmium, Lead Acid, Lithium, etc.) to ship in the same container for Disposal / Recycle? USDOT’s Pipeline and Hazardous Materials Safety administration (PHSMA)… Read More »Mixed Batteries Special Permits
Soil on my property has been identified as being “contaminated”. What do I do now? Contaminated environmental media (soil and groundwater) can take many forms. Is the source oil? Chemical spill? Historic contamination from a… Read More »Soil Remediation
Less String Provisions Details Allows VSQGs and SQGs to exceed waste generation quantities in certain instances (Episodic Generation) An episodic event is an activity that does not normally occur and results in an increase in… Read More »Hazardous Waste Generators Improvements Rule (HWGIR) – Part 3
More Stringent Provisions Details Consolidated the regulations for Hazardous Waste Generators into 40CFR262 Consolidates the regulations for generators into Part 262. Before the rules the regulations were found in different Parts (261.5, 262, 265). More… Read More »Hazardous Waste Generators Improvements Rule (HWGIR) – Part 2
