Lion's office will be closed for the holidays on 12/25 and 26. Online training support is available by email (support@Lion.com) each day from 8:30 AM to 5 PM ET. 
Search

Dealing with RCRA Rejection

Posted on 6/28/2016 by Anthony Cardno

Many of us fear rejection, but mostly in our personal lives. If you ship hazardous waste, you also deal with the prospect of your treatment/storage/disposal facility (TSDF) rejecting your waste shipment. Luckily, the 40 CFR hazardous waste rules provide a specific workflow to be followed when a waste shipment gets rejected. Knowing your responsibilities under RCRA can reduce your anxiety about rejection and help you put in place an effective contingency plan in case of a rejected shipment.

Sometimes, a treatment/storage/disposal facility (TSDF) rejects an incoming shipment of hazardous waste from a generator’s site. If a TSDF rejects a shipment, everyone in the chain—the TSDF, the transporter, and the generator—must follow procedures laid out by the US EPA. EPA’s procedures for rejected shipments ensure that the waste is eventually taken care of properly and that nothing gets lost or forgotten. First, we’ll look at why your TSDF may reject a shipment in the first place.

Why Might a TSDF Reject a Shipment?


A TSDF might reject a shipment of hazardous waste if the type or amount is something it can’t handle. For example, if the TSDF manages hazardous waste in an aqueous wastewater treatment unit and is expecting corrosive (D002) hazardous waste, but it receives reactive (D003) waste that explodes upon contact with water, the facility would have to reject that waste. Maybe the disposal facility has enough landfill space to accept up to 1,000 kg of contaminated soil at a time, but someone sent them 1,000 lbs. of sludge (2,200 kg) that are too much to handle all at once.

Generators, TSDFs, and transporters are supposed to coordinate ahead of time and only send the types of waste a TSDF can accept, but mistakes can happen.

What Happens When a TSDF Rejects a Load?


“[U]pon rejecting waste . . . the [TSDF] facility must consult with the generator prior to forwarding the waste to another facility that can manage the waste. If it is impossible to locate an alternative facility that can receive the waste, the facility may return the rejected waste or residue to the generator. The facility must send the waste to the alternative facility or to the generator within 60 days of the rejection . . . .” [40 CFR 264.72(d) and 265.72(d)]

While making calls and arrangements, the TSDF must either provide secure temporary storage for the waste or ensure the delivering transporter retains custody.

If the TSDF rejects a full shipment of waste before the initial transporter leaves, then the TSDF completes Item 18b of the original manifest by writing in an Alternate Destination Facility. The initial facility retains a copy of the manifest and gives the transporter the remaining copies. The transporter then carries the load to the alternate facility. The “Alternate Facility” can be the initial generator.
If the transporter has left before the TSDF realizes it needs to reject the shipment, or if the TSDF only rejects part of the shipment, then the TSDF needs to create a new manifest before sending the waste to an alternate TSDF or back to the generator.


When a TSDF makes out a new manifest for a rejected load of hazardous waste, it must follow the usual instructions from 40 CFR 262.20, as modified by 40 CFR 264.72 (or 265.72 for interim status TSDFs).

Loading a RCRA hazardous waste shipment for treatment storage disposal

What Happens Next?


After the TSDF rejects a load of hazardous waste, the waste will either travel to a new TSDF or back to the generator. The transporter still has to prevent and respond to releases along the way and sign and maintain copies of the Manifest, but otherwise, there are no new requirements to follow. [40 CFR 263]

If the waste goes to a new facility, the new TSDF will either reject the shipment (starting the whole rigmarole all over again) or accept it. When the Alternate Facility accepts the shipment, it signs the manifest and sends copies back to the initial destination facility, which sends copies back to the original generator. [40 CFR 264.72, 265.72]

If the waste goes back to the generator, then the generator signs the manifest, keeps copies for itself, and shares a copy with the rejecting facility. The generator is then left with the problem of managing extra hazardous waste.

Good News for Generators


There is some good news for generators, though. When a TSDF returns a shipment to the generator’s site, the accumulation time limit for the waste resets. The EPA doesn’t expect generators to count the returned waste towards their generator status calculations for the month.

For large quantity generators (LQGs), this means the 90-day clock starts over once the waste comes back. For small quantity generators (SQGs), the 180-day clock resets. However, SQGs must be careful that the returned waste doesn’t put them over the 6,000 kg on-site limit. If the returned shipment puts them over the on-site limit, then they become an LQG and must comply with more stringent requirements.

RCRA Training in Williamsburg, Charlotte, Orlando, Atlanta, Birmingham, and more!


Build the confidence and skills to manage hazardous waste efficiently and effectively at the nationwide RCRA workshops trusted since 1977. Meet EPA’s annual training requirement for “hazardous waste personnel” and learn the latest requirements and management strategies for RCRA compliance. 

Whether you’re new to the field or need your annual RCRA refresher training, don’t miss the chance to learn alongside new and experienced managers from your area and master the EPA’s complex hazardous waste rules.  See the full schedule and agenda at Lion.com/RCRA-Training.

Tags: hazardous, hazardous waste disposal, RCRA, shipping hazardous waste, waste

Find a Post

Compliance Archives

Lion - Quotes

This course went above my expectations from the moment I walked in the door. The instructor led us through two days packed with useful compliance information.

Rachel Stewart

Environmental Manager

This is a very informative training compared to others. It covers everything I expect to learn and even a lot of new things.

Quatama Jackson

Waste Management Professional

Best instructor ever! I was going to take my DOT training w/a different provider, but based on this presentation, I will also be doing my DOT training w/Lion!

Donna Moot

Hazardous Waste Professional

Very well structured, comprehensive, and comparable to live training seminars I've participated in previously. I will recommend the online course to other colleagues with training requirement needs.

Neil Luciano

EHS Manager

Very witty instructor, made the long times sitting bearable. One of the few training courses I can say I actually enjoyed.

John Hutchinson

Senior EHS Engineer

Lion courses are the standard to which all other workshops should strive for!

Brody Saleen

Registered Environmental Health Specialist

This was the 1st instructor that has made the topic actually enjoyable and easy to follow and understand. Far better than the "other" training providers our company has attended!

Lori Hardy

Process & Resource Administrator

The online course was well thought out and organized, with good interaction between the student and the course.

Larry Ybarra

Material Release Agent

Convenient; I can train when I want, where I want.

Barry Cook

Hazmat Shipping Professional

Attending Lion Technology classes should be mandatory for every facility that ships or stores hazmat.

Genell Drake

Outbound Lead

Download Our Latest Whitepaper

In most cases, injuries that occur at work are work-related and must be recorded to maintain compliance with OSHA regulations. This report shows you the 9 types of injuries you don’t record.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.