SoundEarth Hosts First South Sound Forum; Summary of Dangerous Waste and Community Right-to-Know Reporting

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Last Friday, SoundEarth hosted its first-ever South Sound Environmental Managers Forum in Tacoma. The idea behind this series of monthly events is to provide not only short, timely presentations on topics that affect environmental managers and their facilities, but also a place where they can share advice, ideas, concerns, and solutions with their peers away from the facility.

For our first round, we talked about Dangerous Waste and Community Right-to-Know Reporting. Here’s a peak at what we covered:

What is Solid Waste? What is Hazardous Waste?

We clarified RCRA’s definitions and the differences between listed hazardous waste and characteristic hazardous waste. In particular, here are the rules specific to listed waste that you should note:

Mixture Rule: A waste mixture that includes a RCRA-listed hazardous waste is automatically a RCRA-listed hazardous waste and carries the listing with the mixture. The chemical concentrations in the waste are irrelevant.

Derived from Rule: “Once a RCRA-listed hazardous waste, always a RCRA listed hazardous waste.” Waste generated from treatment, storage, or disposal is derived from a RCRA-listed hazardous waste. Ex. If listed waste is incinerated, the ash still carries the listed waste code even if the chemicals were destroyed during incineration.

Contained-in Rule: If you are disposing of soil or groundwater contaminated with a listed dangerous waste, you must manage the entire volume as if it were dangerous waste until it no longer contains the dangerous waste or is de-listed. Under Ecology’s contained-in policy, Ecology may determine that your contaminated soil or groundwater no longer contains a listed dangerous waste or is below risk-based levels.

Washington-Specific Waste Rules and Reporting

The “Dangerous Waste Regulations” are Washington State’s own set of rules that are more stringent than their federal counterparts, so we clarified the definitions of state-only dangerous waste and state-only special waste.

We also summarized what goes into Washington State’s Dangerous Waste Annual Report and who is required to submit one. There have been recent changes to the reporting system and to the requirements of the report. Most importantly, you should know:

  • Every site with an active EPA/State ID Number must submit a dangerous waste annual report to the Department of Ecology
  • Report Due Date: March 1
  • No extensions are given!
  • Submit all reports electronically through TurboWaste
  • 84-page guide for RY2018 available

Emergency Planning and Community Right-to-Know Act

The key purposes of EPCRA are to protect public health, safety, and the environment from chemical hazards; to create a partnership between, state, local agencies, tribal nations, and industry; to plan for emergencies and disasters; and to provide important information for first responders.

There are four reports that fall under EPCRA:

  • Emergency Response Planning
  • Emergency Release Notifications
  • Hazardous Chemical Inventory Reporting (Tier Two)
  • Toxics Release Inventory (TRI) Reporting  

This month, we covered Tier Two reports, their requirements and who is subject to them (tip, they’re also due March 1).

Next month, the South Sound Environmental Managers Forum will cover TRI Reports.

If you’d like more information on any of the above or are interested in receiving a copy of the presentation materials, please This email address is being protected from spambots. You need JavaScript enabled to view it.. Similarly, if you’re in Tacoma or the surrounding areas and work in a capacity similar to an environmental manager, please join us for the next Forum! This email address is being protected from spambots. You need JavaScript enabled to view it. for more information.

Elyssa Dixon, PE Featured in ASCE's "Best Places t...