documentation of employee training,
coordination with local emergency authorities as documented in the facility contingency plan, and
management of used oil spills and leaks.
Initially, Hart & Hickman successfully negotiated an extension for responding to the deficiencies. We assisted the facility with development of an employee training program, developed employee documentation training forms, and recommended the facility reduce the number of personnel handling hazardous waste thereby reducing the cost of employee training. H&H also coordinated with local emergency authorities and established a system which meets the facility’s contingency plan.
Hart & Hickman re-characterized the process liquids (primarily varsol and kerosene) that were previously considered characteristically hazardous waste (D001) due to flammability and the presence of metals. The re-characterization indicated the waste stream was not characteristically hazardous. H&H then closed the tank system in accordance with RCRA regulations so the tank could be utilized for “used oil storage”. We worked with the client to establish a recycling program, which lessened the recordkeeping and testing burden compared to non-hazardous disposal, and provides more flexibility for dealing with the waste if it happens to test positive for the D001 characteristic in the future.