DPRA conducted a review of hazardous waste regulations, associated Federal Register notices, interpretation letters, and memoranda related to the trivalent chromium exclusion. The purpose of this project was to provide the U.S. Postal Service with information to formulate guidance to support U.S. Postal Service efforts in obtaining coverage under the exclusion on a national basis. DPRA reviewed State and territorial regulatory information pertinent to the trivalent chromium exclusion to determine individual State or territorial requirements regarding the application and use of this exclusion. In addition, DPRA reviewed authorization status of State programs for the exclusion, the delisting rule, and the toxicity characteristic rule.  

The United States Postal Service’s (USPS) Environmental Management and Policy (EMP) Group contracted DPRA to review and update hazardous waste generator information for all USPS facilities across the country subject to the requirements for notification of regulated waste activity under Section 3010 of the Resource Conservation and Recovery Act (RCRA). 

DPRA visited over 200 USPS facilities across the country to collect information pertaining to hazardous waste.  In addition, we coordinated the efforts of two other national contractors in the completion of site visits at more than 500 USPS facilities as part of this project.  Data collection forms for over 700 USPS facilities were uploaded into a web-based hazardous waste data management system at the completion of each site visit.  At the conclusion of all the site visits, DPRA obtained completed Site Survey information from the database and all copies of supporting documentation to verify generator status and facility information. 

DPRA updated each EPA Form 8700-12 (or equivalent State form) with the facility specific information and generator status obtained during the site visits.  DPRA submitted the final, signed forms and cover letters to the appropriate EPA Region or State office in accordance with Federal and/or State requirements. 

DPRA developed a GIS database to display the locations of the USPS districts and identify hazardous waste generator locations in each district.  DPRA also profiled the types of hazardous waste program documents such as permits, plans, and correspondence that USPS might want to make available on-line through a GIS interface. 

DPRA assisted DPRA conducted a quality control review of the National Solid and Hazardous Waste Management Strategy (the “Strategy”) in two phases.   Phase I consisted of three tasks: 1) refining the four initial project approaches; 2) identifying new, innovative initiatives for the Strategy; and 3) identifying and evaluating opportunities for integration of tasks and activities across the Strategy. Phase I culminated in the preparation of a memorandum suitable for USPS internal distribution that presented DPRA’s thoughts on these three areas. Phase II consisted of two tasks: 1) incorporating the EMP group’s comments on DPRA’s memorandum and revising the Strategy accordingly; and 2) preparing an action plan for its implementation