Find confidence in your compliance approach
There is a reason that McCoy’s RCRA Unraveled is subtitled: Untying the Knots in the Resource Conservation and Recovery Act Regulations. Complying with waste regulations for various process equipment configurations can be complicated:
- An interwoven network of regulations (both state and federal) may be needed to fully describe obligations for a certain situation, which is frustrating.
- Even after reading all potentially applicable regulations, requirements are often still not clear.
- Reference materials such as McCoy’s RCRA Unraveled are very helpful, but often your specific situation is not exactly described. You may need to combine several aspects of other analyses to fit your actual situation.
- Which wastes are separated when and how they are handled can be important.
- Use of solvents (painting operations, for example) and rules pertaining to recycling are particularly complicated.
- Even defending that your nonhazardous waste is really nonhazardous can be difficult. Upstream sector clients encounter a surprising number of issues because waste not in contact with process oil may not be part of the RCRA Oil and Gas exclusion.
- Further, some waste issues have been challenged in the courts (sometimes more than once).
- Leaving out just one part can change the entire outcome.
Have confidence in your compliance approach - use a defined process
For every situation, it is important to feel confident in your regulatory analysis and to check the sources of possible interpretations. JBE has devised a process and format to record the results of your analyses so that once they are completed, they are not repeated within your organization unless regulations or conditions change. Below is an example of a regulatory analysis and the result for a particular spent catalyst waste.
McCoy and Associates – McCoy is one of the best at keeping up with RCRA regulations, court decisions, etc. McCoy and Associates RCRA Unraveled is an excellent starting place in performing detailed regulatory analyses.
RCRA FAXBACK documents interpret the often unclear aspects of RCRA. These can be quite helpful when analyses similar to or matching your situation are available. Search by keyword, title, or RCRA Online Number.