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Abandoned spill = land disposal unit
If you spill a material and don’t clean it up, the material is considered abandoned, making it a “discarded material” and a “solid waste” under RCRA. [§261.2(a)(2) and (b), 45 FR 33093] If the material would have been a hazardous waste when discarded, the spill location is then considered an unpermitted hazardous waste land disposal unit. [RO 12748] Plus, failure to make proper notification of the spill would violate additional provisions of the regulations, and CERCLA (aka Superfund) liability is always lurking in the background.
Bottom line: clean up your spills! Find more compliance morsels on our website.
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McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with any guidance provided above. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which such guidance may conflict. Any guidance above is general in nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with environmental regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.
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