COVID-19 dangerous waste compliance

We expect dangerous waste generators to follow these guidelines:

1. Closely adhere to all federal, state, and local public health and safety guidelines.
2. Comply with the Dangerous Waste Regulations to the best of their ability, as protection of human health and the environment continues to be of essential importance.
3. Report dangerous waste complaints or any imminent threat to human health or the environment, such as a spill or release, to us immediately or to your regional office:
   • Central: 509-575-2490
   • Eastern: 509-329-3400
   • Northwest: 425-649-7000
   • Southwest: 360-407-6300
   • You may also call the Washington Emergency Management Division at 1-800-258-5990.

If your operations are impacted by COVID-19 and compliance is not reasonably practical, facilities with environmental compliance obligations should do all of the following:

• Act responsibly under the circumstances and take all practical steps to minimize the effects and duration of noncompliance caused by COVID-19.
• Identify the specific nature and dates of the noncompliance.
• Document how COVID-19 was the cause of noncompliance and the decisions and actions taken in response. Include your best efforts to comply and steps taken to come into compliance at the earliest opportunity. Provide this documentation to your Ecology regional office if requested.
• Return to compliance as soon as possible.

Please note that these guidelines:

• Do not apply to criminal (knowing and willful) acts.
• Do not apply to Treatment, Storage and Disposal Facilities (TSDFs) or RCRA Corrective Action enforcement.
• Are only related to COVID-19-related impacts.
• Are not regulation and do not change any rules or laws.

Yes. Large and medium quantity generators may request extensions of dangerous waste storage time limits. The dangerous waste regulations (WAC 173-303-172(3) and -200(2)) allow facilities to request extensions for on-site storage due to unforeseen, temporary, and uncontrollable circumstances.

How to request an extension

If your facility is unable to ship dangerous wastes within the required timeframe:

• Contact your regional Ecology office and ask for a dangerous waste compliance specialist.
• Since we issue extensions on a case-by-case basis, please provide the following information to help inform our decision:
  • Number and size of containers approaching the 90- or 180-day accumulation time limit.
  • General description of the waste.
  • Accumulation start date of the waste.
  • Specific location (accumulation area) of the waste.
  • Documentation of efforts made to schedule a waste pickup and explanation why the dangerous waste must remain on site due to unforeseen, temporary, and uncontrollable circumstances.
  • Copy of the most recent weekly inspection log.
  • Name and phone number for the on-site emergency coordinator.

Central accumulation areas (CAAs) must be inspected weekly to check for leaks and deterioration of containers and the containment system caused by corrosion, deterioration, or other factors.

For MQGs and LQGs, there must be at least one employee either on the premises or on call (i.e., available to respond to an emergency by reaching the facility within a short period of time) with the responsibility for coordinating all emergency response measures.

In the event of a facility shutdown, we recommend your emergency coordinator evaluate the appropriate level of on-site presence to ensure human health and safety are protected.

Maybe.

• Your generator category could change since this is determined by how much waste you generate each month.
• If your operation closes and the amount of dangerous waste remaining on site causes you to jump to a higher generator category, you could report this as episodic generation.
• Contact your regional office for assistance.

When satellite accumulation area thresholds are reached and circumstances inhibit you from moving the container(s) to your central accumulation area (CAA) within 3 days, we recommend you:

• Immediately mark the container(s) with the accumulation start date.
• Manage the satellite accumulation area as a central accumulation area.

Note that:

• You may have several CAAs.
• The regulations do not specify a maximum number of CAAs allowed on site.  

While our agency is unable to check the mail as often as normal, please do BOTH of the following:

1. Email scanned copies to turbowaste@ecy.wa.gov.
2. Mail us your paper documents.

This requirement applies to these documents:

• Notifications.
• Annual reports.
• Electronic signature agreements.
• Original documents with wet ink signature(s).

We will verify receipt of documents and remove any TurboWaste submittals or user rights for any missing documents.

Si necesita ayuda con el cumplimiento de residuos peligrosos durante COVID-19, favor de contactarnos Lucie Kubasova al 425-457-0124.

Trong lúc đại dịch COVID-19, nếu qúy vị cần giúp để làm đúng các quy định chất thải nguy hiểm, xin hãy liên hệ chúng tôi tại số 425-457-0124.

如果在COVID-19期間您需要有害廢物合規方面的幫助， 請撥打425-457-0124與我們聯係。

코로나 바이러스사태  기간 동안, 유해 폐기물 법 위반사항에 관해 도움이 필요하면 425-457-0124 으로 연락하세요.