Page 106 - Pipeline Pigging Technology

Environmental considerations and risk assessment

classification of wastes and hazardous waste;
cradle-to-grave manifest system, record keeping, and reporting require-
ments;
standards for generators, transporters, and facilities which treat, store,
or dispose of hazardous waste;
enforcement of the standards through a permitting program and civil
penalty policies; and
the authorization of state programs to operate in lieu of the federal
programmes.

Subtitle D of RCRA addresses the disposal of non-hazardous solid waste.
This part of RCRA generally is enforced by individual states. Other than
publishing criteria for sanitary landfills and maintaining an inventory of open
permitted dumps, EPA has little to do with the regulation of non-hazardous
solid waste disposal.
RCRA was amended in 1984, and the scope of the act was widely
broadened. Additional restrictions on land disposal, small quantity genera-
tors, burning and blending of wastes, underground storage tanks, interim
status facilities, inspections, and civil suits were addressed in the 1984
amendments. The new law added 72 provisions to RCRA and was designed
to fill in the gaps or apparent regulatory loopholes of the 1976 version.
Impacts on the pipeline industry: Of all the environmental laws passed to
date, RCRA probably has had the most lasting effect on the pipeline industry.
This rating is because, with very few exceptions, pipeline facilities fall under
the classification of generators of hazardous wastes; as such, these facilities
are subject to the generator standards' provisions of RCRA. Under RCRA, a
generator is any entity whose act or process produces a hazardous waste, or
whose act first causes a hazardous waste to become subject to regulation.
Although it is not unlawful to generate hazardous waste, a generator is
required to fulfil a number of requirements, including making an effort to
reduce the quantity of hazardous waste generated. In addition to the require-
ment that the generator reduce the amount of waste, the generator must have
an EPA identification number and must assure that wastes are shipped in
proper containers, accurately labelled, and accompanied with proper plac-
ards for use by the transporter. Generators further are required to ship the
wastes off-site within 90 days after the initial date of accumulation. If they do
not do so, they must have a storage permit.
Generators also must comply with applicable storage standards for con-
tainers; conduct proper operating, maintenance, and inspection procedures;

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