Federal and state regulations establish requirements for record keeping and reporting for various waste management activities conducted at CSSA. These requirements cover activities including waste generation; waste analysis; waste storage, treatment, and disposal; and spills and releases. The hazardous waste program under RCRA requires "cradle to grave" tracking of hazardous wastes; that is, managing wastes from the point of generation to the point of treatment, storage, or disposal. The following is a brief description of recordkeeping and reporting requirements applicable to CSSA.
Various recordkeeping requirements have been established for many of the waste management activities. State regulations at 30 TAC �335.9 require that generators maintain records of all hazardous waste activities regarding the quantities generated, accumulated, processed, and disposed of on site or shipped off site for storage, processing, or disposal. These records may be maintained in any format, provided they are retrievable and easy to copy. The records must be sufficiently detailed and complete to support any contentions or claims made by the generator pertaining to waste management activities. Waste records are maintained at the CSSA Environmental Office. These requirements are described below for each waste management activity.
The state regulations (30 TAC �335.501 to �335.515) allow self-classification of waste streams by the generator. However, the generator is required to document and maintain all available information necessary to classify the waste stream, as follows:
Records noting the waste description, characteristics, and classification of each waste should be maintained.
The quantity of wastes generated should be recorded.
All records of any test results, waste analyses, or other determinations performed for waste streams generated at CSSA should be maintained (30 TAC �335.70).
CSSA must notify the TNRCC of all waste streams and waste management units at the installation and be listed on the Installation�s NOR.
The generator, in accordance with the state notification requirements, should notify the Executive Director (TCEQ) of waste storage areas as waste management units. Information pertaining to whether the unit is permitted or qualifies for an exemption as a less-than-90 day storage unit should also be submitted. In addition, a listing of the wastes managed in the unit should be provided.
CSSA must maintain records of spills and releases of harmful quantities of oil and hazardous substances on the installation. Records of spills should include written descriptions of spills, corrective actions taken, and plans for preventing recurrence. A detailed description of the recordkeeping requirements pertaining to spills and release of oil and hazardous substances are presented in the SPCCP.
The generators are also required to notify and submit reports to the regulatory agencies regarding various waste management activities. These reporting requirements are described below.
Each generator of hazardous wastes must submit an annual waste summary on the specified TCEQ Form (Annual Waste Summary Form). The instructions for preparation and the mailing address are contained on the form. This form must be submitted to the TCEQ by January 25 of each year [30 TAC �335.9(a)(2) and �335.71(a)].
Monthly waste summaries prepared on TCEQ Form 0500, Waste Shipment Summary, must be submitted to the TCEQ on the 25th of each month for shipments originating for the previous month. This summary is only completed for those wastes shipped out of state [30 TAC �335.13(b)].
Unreturned Manifest Exception reporting is required for unreturned manifests after 45-days for LQG and 60-days for SQG as stated in 40 CFR 262.42.
Releases of oil and hazardous substances in harmful quantities into the environment will require certain notification and reporting. These requirements are described in the CSSA SPCCP.
In the event the ISCP is implemented in response to an emergency situation, CSSA must submit an incident report within 15 days after the incident to the Executive Director.
[1]�Environmental Health Engineering Department, Fifth US Army Medical Laboratory, Report of Engineering-Survey-Industrial Waste and Wastewater Treatment Plant, Camp Stanley Storage Activity, Texas, October, 1971.
[2]�Test Methods for Evaluation of Solid Waste, Physical/Chemical Methods, EPA Publication SW-846.