The Waste Management Bureau of the Connecticut Department of Energy and Environmental Protection (DEEP) issued a private manufacturer a Notice of Violation (NOV). To satisfy the conditions of the Hazardous Waste NOV, HRP performed the following activities:
Hazardous Waste Determinations – HRP first reviewed the manufacturing operations to identify the types and quantities of industrial wastes being generated on-site. The identified industrial wastes included: spent solvent, grinding swarf, rags, used oil, filters, and sandblasting dust.
For each identified industrial waste, HRP then performed a hazardous waste determination using the following process:
- Determined if the industrial waste met the definition of a “solid waste”.
- Determined if the industrial waste met any of the regulatory exclusions.
- Determined if the industrial waste met the description of any listed hazardous waste.
- Determined if the industrial waste met the definition of a characteristic hazardous waste using knowledge or testing the waste using EPA-approved methods.
Hazardous Waste Training – HRP prepared a hazardous waste training program to cover the regulatory requirements for a Small Quantity Generator of hazardous waste, the client's emergency response actions, and physical and health hazards of their hazardous wastes. HRP conducted on-site hazardous training seminars for over 50 employees.
The hazardous waste determination results, training program, and training records were submitted to the CT DEEP for review and approval. CT DEEP determined that all of the conditions of the NOV were met.