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Managing Hazardous WasteA HANDBOOK FOR SMALL BUSINESS

Managing Hazardous Waste Handbook 3

TABLE OF CONTENTS

INTRODUCTION ............................................................................................................................................................. 4

DECIDING WHETHER HAZARDOUS WASTE REGULATIONS APPLY TO YOU ................................. 5Defining Hazardous Waste .......................................................................................................................................... 5Identifying Your Waste: Typical Hazardous Wastes Generated by Businesses .................................... 6What Do You Measure to Determine Your Generator Category? ................................................................ 7How Many Drums Is That? .......................................................................................................................................... 7Finding Your Generator Category ............................................................................................................................ 8

OBTAINING AN EPA IDENTIFICATION NUMBER .......................................................................................... 9Sample RCRA Subtitle C Site Identification Form ............................................................................................. 10

REQUIREMENTS FOR CONDITIONALLY EXEMPT SMALL QUANTITY GENERATORS ............... 12

REQUIREMENTS FOR SMALL QUANTITY GENERATORS .......................................................................... 12Accumulating Your Waste ........................................................................................................................................... 12Treating Your Waste to Meet the Land Disposal Restrictions (LDRs) ..................................................... 13Shipping Hazardous Waste Off-Site ........................................................................................................................ 14Selecting a TSDF .............................................................................................................................................................. 14Labeling Waste Shipments .......................................................................................................................................... 14Selecting a Transporter or TSDF/Recycler .......................................................................................................... 14Preparing Hazardous Waste Manifests ................................................................................................................. 14Land Disposal Restrictions (LDR) Reporting Requirements ....................................................................... 23Export Notification ......................................................................................................................................................... 23Waste Minimization: The Key to Better Waste Management ....................................................................... 23

HAZARDOUS WASTE CODE CHART ..................................................................................................................... 16

STEPS TO BASIC HAZARDOUS WASTE MANAGEMENT CHART ............................................................ 20

RESPONDING TO EMERGENCIES .......................................................................................................................... 24Preventing Accidents ..................................................................................................................................................... 24

SUMMARY OF REQUIREMENTS FOR LARGE QUANTITY GENERATORS ......................................... 26

POLLUTION PREVENTION ....................................................................................................................................... 27

FINAL TIPS ........................................................................................................................................................................ 28Are You Sure? .................................................................................................................................................................... 28Can You Use the Universal Waste Rule? ................................................................................................................ 28

DEFINITIONS ................................................................................................................................................................... 29

WHERE TO GET MORE HELP .................................................................................................................................. 30

Appendix C: Forms/Statements ............................................................................................................................... 31Appendix D: Hazardous Waste Generators Checklist ...................................................................................... 34

Managing Hazardous Waste Handbook4

Introduction

This handbook has been prepared by the Hazardous Waste Inspections & Compliance Unit (HWICU) of the Arizona Department of Environmental Quality (ADEQ) to help small business owners and operators understand how to best comply with federal hazardous waste management regula-tions, as well as Arizona hazardous waste rules and stat-utes. This handbook is intended to be an overview and sum-mary of regulations and statutes for a basic understanding of responsibilities for managing hazardous waste. It is not to be used as a substitute for the actual regulations.

Much of the material in this handbook is reprinted from the Environmental Protection Agency’s (EPA) handbook entitled, Managing Your Hazardous Waste - A Guide for Small Business. EPA’s handbook is augmented by material pertaining to hazardous waste management requirements particular to Arizona rules and statutes. Arizona incorpo-rates most of the federal hazardous waste regulations by reference; therefore, Arizona’s hazardous waste rules are similar and consistent with the federal hazardous waste regulations.

All of the federal hazardous waste regulations are locat-ed in Title 40 of the Code of Federal Regulations (CFR), Parts 260 to 280 (www.ecfr.gov) which are incorporated by Arizona Administrative Codes (A.A.C.) R18-8-260 to 280 (www.azsos.gov/public_services/table_of_contents.htm). State regulations are located in the Arizona Revised Statutes §49-901 through §49-944 (www.azleg.state.az.us/ArizonaRevisedStatutes.asp).

Federal and state rules define a generator as any person or site whose processes and actions create hazardous waste. There are three categories of hazardous waste generators based upon the quantity of hazardous waste a facility gen-erates in any calendar month:

1) Conditionally exempt small quantity generators (CESQGs) generate less than 220 pounds (100 kg) in any calendar month.

2) Small quantity generators (SQGs) generate between 220 pounds (100 kg) and 2,200 pounds (1,000 kg) in any calendar month.

3) Large quantity generators (LQGs) generate more than 2,200 pounds (1,000 kg) or more than 2.2 pounds (1 kg) of acute hazardous waste in any calendar month or 220 pounds (100 kg) acute spill residue.

Each category of generator must comply with the hazard-ous waste rules specific to that category. This handbook is intended primarily for businesses that generate small quantities of hazardous waste (SQGs and CESQGs) to help them learn which regulations apply.

For More Information

If you have questions about any part of this document or the federal hazardous waste regulations pertaining to Ar-izona, call the Hazardous Waste Inspections & Compliance Unit at (800) 234-5677.

You can look up unfamiliar words or phrases on a list of definitions found at the end of this handbook or in 40 CFR Part 260.

You can find a pull out flow chart of Steps to Basic Hazardous Waste Management in the center of this handbook.

Whenever you consult a federal hazardous waste regulation to determine the regulations that apply to the waste you are managing, you must also consult the Arizona hazardous waste statutes and rules to determine if any additional and/ or different standards also apply.

TIPS

TIP


DECIDING WHETHER HAZARDOUSWASTE REGULATIONS APPLY TO YOU

Federal and state hazardous waste management regula-tions apply to most businesses that generate hazardous waste. To determine if these regulations apply to your business, you must first determine if you even generate hazardous waste.

What is Hazardous Waste?

Hazardous waste is a special category or subset of regu-lated wastes that business and industries generate. For a material to be a hazardous waste, the material must first be a solid waste. Generators of a solid waste are required to determine whether that material is a hazardous waste. This determination must be made the moment a material becomes a solid waste.

A solid waste is any solid, liquid, or contained gaseous material that is discarded by being disposed of, burned, incinerated, or recycled. There are some exceptions for recycled materials. A solid waste can be the by-product of a manufacturing process or simply a commercial product that you use in your business— such as a cleaning fluid or battery acid—that is being disposed. Even materials that are recyclable or can be reused in some way —such as burning used oil for fuel— may be considered a solid waste. The regulations in 40 CFR §261.3 state that a solid waste that meets any of the following criteria is a hazard-ous waste. Hazardous waste can be one of three types:

Listed waste

Your waste is considered hazardous if it appears on one of four lists, F, K, P, and U, published in 40 CFR Part 261 (as incorporated by A.A.C. R18-8-261) and is not other-wise excluded. Currently, more than 500 wastes are listed. Wastes are listed as hazardous because they are known to be harmful to human health and the environment when not managed properly.

Acute hazardous wastes are listed wastes that even when managed properly are extremely dangerous. Examples of acute hazardous wastes include wastes generated from cyanides, arsenic compounds, and some pesticides that can be fatal to humans even in low doses. P-listed and F020, F021, F022, F023, F026, and F027 are examples of acute hazardous wastes.

Characteristic waste

If your waste does not appear on one of thehazardous waste lists, it still might be considered hazard-ous if it demonstrates one or more of the following charac-teristics (40 CFR Part 261):

1) Ignitable (D001): It catches fire under certain condi-tions. This is known as an ignitable waste. Four prop-erties: a) Liquids with a flash point less than 140°F,

b) Non-Liquids that cause fire and burn vigorously and persistently, c) Ignitable compressed gases, and d) Oxidizers. Examples are paints, certain degreasers, solvents, and persulfates.

2) Corrosive (D002): It corrodes metals or has a very high or very low pH. This is known as a corrosive waste. Two properties: a) Aqueous solutions with a pH less than or equal to 2 or greater than or equal to 12.5, and b) Liquid that corrodes steel at a rate of greater than 0.25 in. per year at 130°F. Examples are rust removers, acid or alkaline cleaning fluids, and battery acid.

3) Reactive (D003): It is unstable and explodes, under-goes violent change without detonating, or produces toxic fumes, gases, and vapors when mixed with water or under other conditions, such as heat or pressure. This is known as a reactive waste (D003). Examples are certain cyanides or sulfide- bearing wastes.

4) Toxic (D004 – D043): It is harmful or fatal when ingest-ed or absorbed, or it leaches toxic chemicals into the soil or ground water when disposed on land. This is known as a toxic waste. Examples are wastes that contain high concentrations of heavy metals, such as cadmium, lead, mercury, or silver. Other examples are wastes that contain high concentrations of benzene, methyl ethyl ketone (MEK), or tetrachloroethylene (PERC).

You can determine if your waste is toxic by having it tested by a state licensed laboratory using the Toxicity Character-istic Leaching Procedure (TCLP), by simply knowing that your waste is hazardous or that your processes generate hazardous waste (called generator knowledge). However, you must have written documentation if using generator knowledge for both hazardous and non-hazardous waste.

Mixture Rule & Derived-from Rule

A “mixture” of hazardous waste with solid waste (e.g., mo-tor oil, trash, debris) may become a hazardous waste. The waste “derived from” the treatment, storage, or disposal of hazardous waste may also be a hazardous waste.

One way to help determine if your waste exhibits a characteristic is to check the Safety Data Sheet (SDS) that comes with all products containing hazardous materials. In addition, your national trade association or its local chapter should be able to help you.

TIPS


Identifying Your Waste

To help you identify some of the waste streams common to your business, consult the table below to find a list of typical hazardous wastes generated by small businesses. Use the EPA Hazardous Waste Codes for Waste Streams Com-monly Generated by Small Quantity Generators list located in the center of this handbook for a more detailed listing of the EPA waste codes associated with these waste streams to determine if your waste is hazardous. Commercial chemical products that are discarded might also become hazardous waste. For a complete listing of hazardous waste codes, con-sult 40 CFR Part 261 (as incorporated by A.A.C. R18-8-261).

If your waste is hazardous, you will need to manage it ac-cording to appropriate federal and state hazardous waste regulations.

First, determine if you generate hazardous waste.

Measure the amount of hazardous waste you produce per month.

Determine your generator category to learn the management requirements that apply to you.

TYPICAL HAZARDOUS WASTES GENERATED BY BUSINESSES

Type of Business How Generated Types of Wastes Waste Codes

Dry Cleaning and Laundry Plants Commercial dry cleaning processes Still residues from solvent distillation, spent filter cartridges, cooked powder residue

D001, D039, F002

Furniture/Wood Manufacturing and Refinishing

Wood cleaning and wax removal, refinishing/ stripping, staining, painting, finishing, brush cleaning, and spray brush cleaning

Ignitable wastes, toxic wastes, solvent wastes, paint wastes

D001, F001- F005

Construction Paint preparation and painting, carpentry and floor work, other specialty con-tracting activities, heavy construction, wrecking and demolition, vehicle and equipment maintenance for construction activities

Ignitable wastes, toxic wastes, solvent wastes, paint wastes, used oil, acids/bases

D001, D002, F001-F005

Laboratories Diagnostic and other laboratory testing Spent solvents, unused re-agents, reaction products, testing samples, contaminated materials

D001, D002, D003, F001- F005, U211

VehicleMaintenance

Degreasing, rust removal, paint prepa-ration, spray booth, spray guns, brush cleaning, paint removal, tank cleanout, installing lead- acid batteries

Acids/bases, solvents, ignitable wastes, toxic wastes, paint wastes, batteries

D001, D002, D006, D008, F001-F005

Printing andAllied Industries

Plate preparation, stencil preparation for screen printing, photo processing, printing, cleanup

Acids/bases, heavy metal wastes, solvents, toxic wastes, ink, unused chemicals

D002, D006, D008, F001- F005, U-Listed

Equipment Repair Degreasing, equipment cleaning, rust removal, paint preparation, painting, paint removal, spray booth, spray guns, and brush cleaning

Acids/bases, toxic wastes, ignitable wastes, paint wastes, solvents

D001, D002, D006, D008, F001-F005

Pesticide End- Users/Application Services Pesticide application and cleanup Used/unused pesticides, solvent wastes, ignitable wastes, contaminated soil (from spills), contaminated rinsewater,empty containers

D001, F001- F005, U129, U136, P094, P123

Educational andVocational Shops

Automobile engine and body repair, metal- working, graphic arts—plate preparation, woodworking

Ignitable wastes, solvent wastes, acids/bases, paint wastes

D001, D002, F001-F005


Many hazardous wastes are liquids and are measured in gallons—not pounds. In order to measure your liquid wastes, you will need to convert from gallons to pounds. To do this, you must know the density of the liquid. A rough guide is 27.5 gallons (half of a 55- gallon drum) of waste with a density similar to water weighs about 220 pounds (100 kg); 275 gallons (five 55-gallon drums) of a waste with a density similar to water weighs about 2,200 pounds (1,000 kg).

WHAT DO YOU MEASURE TO DETERMINE YOUR GENERATOR CATEGORY?

DO MEASURE:

For your monthly total, all quantities of listed and charac-teristic hazardous wastes that are:

• Accumulated on the property for any period of time before disposal or recycling. (Dry cleaners, for exam-ple, must count any residue removed from machines, as well as spent cartridge filters.)

• Packaged and transported away from your business.• Placed directly in a regulated treatment or disposal

unit at your place of business.• Generated as still bottoms or sludges and removed

from product storage tanks.

DO NOT MEASURE:Wastes that:

• Might be left in the bottom of containers that have been thoroughly emptied through conventional means such as pouring or pumping.

• Are left as residue in the bottom of tanks storing prod-ucts, if the residue is not removed from the product tank.

• Are reclaimed continuously on-site without storing prior to reclamation, such as dry cleaning solvents.

• Are managed in an elementary neutralization unit, a totally enclosed treatment unit, or a wastewater treat-ment unit without being stored first. (See definitions at the end of this handbook for an explanation of these types of units.)

• Are discharged directly to publicly owned treatment works (POTWs) without being stored or accumulated first. This discharge to a POTW must comply with the Clean Water Act. POTWs are public utilities, usually owned by the city, county, or state that treat industrial and domestic sewage for disposal.

• Have already been counted once during the calendar month, and are treated on-site or reclaimed in some manner, and used again.

• Are regulated under the universal waste rule or have other special requirements. The federal regulations contain special, limited requirements for managing certain commonly generated wastes. These wastes can be managed following the less burdensome require-ments listed below instead of the usual hazardous waste requirements.

3Used oil—40 CFR Part 279 (as incorporated by ARS 49-801-818). 3Lead-acid batteries that are reclaimed—40 CFR Part 266, Subpart G (as incorporated by A.A.C. R18-8-266). 3Scrap metal that is recycled—40 CFR §261.6 (a)(3) (as incorporated by A.A.C. R18-8-261). 3Universal wastes (e.g., certain batteries, recalled and cancelled pesticides, mercury- containing thermostats, and mercury- containing waste lamps)—40 CFR Part 273 (as incorporated by A.A.C. R18-8-273).

= 55 gallon drum= 440 pounds (water)= 200 kg (water)

*This is for guidance purposes only. Not all chemicals have the same density.

<1/2 drum or<27.5 gallons or<220 pounds or<100 kgPer calendar month

1/2 to 5 drums or27.5 to 275 gallons or220 to 2,200 pounds or100 to 1,000 kgPer calendar month

>5 drums or>275 gallons or>2,200 punds or>1,000 kgPer calendar month

CONDITIONALLY EXEMPT SMALL QUANTITY GENERATOR (CESQG)

HOW MANY DRUMS IS THAT?

KEY:*

SMALL QUANTITY GENERATOR (SQG)

LARGE QUANTITY GENERATOR (LQG)

OR MORE

Substance lbs. per gallon lbs. per drum

Water 8.340 458.7

Lead 94.659 5,206.25

Methylene chloride 11.134 612.37

Acetone 6.605 363.275

This chart shows different weights per gallon and per drum.

TIPS


FINDING YOUR GENERATOR CATEGORY

Once you know that you generate hazardous waste, you need to measure the amount of waste you produce each calendar month. The amount of hazardous waste you generate in a calendar month determines your generator category. For waste management purposes, depending on your type of business and your waste generating activities, you might be regulated under different rules at different times.

If, for example, you generate less than 220 pounds (100 kg) of hazardous waste during the month of June, you would be considered a CESQG and your June waste would be subject to the hazardous waste management requirements for CESQGs.

If in July, you generate between 220 and 2,200 pounds (100 to 1,000 kg) of hazardous waste, your generator status would change and you would be considered an SQG for the rest of the calendar year. Your July waste and facility would then be subject to the management requirements for SQGs.

If in August, you generate greater than 2,200 pounds (1,000 kg) of hazardous waste, your generator status would change again and you would be considered an LQG for the rest of the calendar year. Your August waste and facility would then be subject to the management require-ments for LQGs.

For annual registration fee purposes, your fee is based on the maximum amount generated in any one month of the previous year. Remember to use your monthly genera-tion amounts to determine your registration status, not a monthly average based on your annual total.

In the example above, you are required to register as an LQG since you generated greater than 2,200 pounds of hazardous waste in August. You are an SQG if you have generated 220 pounds (100 kg) or more but less than 2,200 pounds (1000 kg) of hazardous waste in any calen-dar month of the previous year. If this is the case, you are required to pay an annual registration fee of $100. If you have generated less than 220 pounds (100 kg) of hazard-ous waste in each calendar months of the previous year, you are a CESQG and do not have an annual registration fee. See Appendix C.

EPA has established three generator categories, each of which is regulated differently:

CONDITIONALLY EXEMPT SMALL QUANTITY GENERATORS (CESQGS)40 CFR § 261.5You are considered a CESQG if you generate no more than 220 pounds (100 kg) of hazardous waste in any calendar month and do not accumulate over 2,200 pounds (1,000 kg) of total hazardous on-site. You are exempt from hazardous waste management regulations provided that you comply with the basic requirements described in this handbook.

SMALL QUANTITY GENERATORS (SQGS) 40 CFR 262.34(c) &(d)You are considered an SQG if you generate between 220 and 2,200 pounds (100 and 1,000 kg) of hazardous waste in any calendar month and do not accumulate hazardous waste over 13,228 pounds (6,000 kg). SQGs must comply with federal and state requirements for managing hazardous waste described in this handbook.

LARGE QUANTITY GENERATORS (LQGS)40 CFR 262.34(a), (b), & (c)You are considered an LQG if you generate more than 2,200 pounds (1,000 kg) of hazardous waste in any calendar month. LQGs must comply with more extensive hazardous waste rules than those summarized in this handbook.

If the generator facility generates more than 2.2 pounds (1 kg) of acute hazardous waste or 220 pounds (100 kg) acute spill residue in any calendar month or accumulates those amounts on site, all of the acute hazardous waste must be managed according to the regulations applicable to LQGs.

SQGs are invoiced annually for generation fees and LQGs are invoiced quarterly. Arizona requires a hazardous waste generation fee prorated per ton. See Appendix C.

$67.50 per ton

There is no registration fee for CESQGs.

SQGs = $100 annually LQGs = $300 annually

TIPS

GENERATION FEE

ANNUAL REGISTRATION FEE


EPA ID Number

OMB#: 2050-0024; Expires ____________

10. Type of Regulated Waste Activity (at your site)

Mark “Yes” or “No” for all current activities (as of the date submitting the form); complete any additional boxes as instructed.

A. Hazardous Waste Activities; Complete all parts 1-10.

Y N 1. Generator of Hazardous Waste

If “Yes”, mark only one of the following – a, b, or c. Y N 5. Transporter of Hazardous Waste

If “Yes”, mark all that apply.

a. LQG: Generates, in any calendar month, 1,000 kg/mo

(2,200 lbs./mo.) or more of hazardous waste; or

Generates, in any calendar month, or

accumulates at any time, more than 1 kg/mo (2.2

lbs./mo) of acute hazardous waste; or

Generates, in any calendar month, or

accumulates at any time, more than 100 kg/mo

(220 lbs./mo) of acute hazardous spill cleanup

material. a. Transporter b. Transfer Facility (at your site)

Y N 6. Treater, Storer, or Disposer of

Hazardous Waste Note: A hazardous

waste Part B permit is required for these

activities. Y N

7. Recycler of Hazardous Waste

b. SQG: 100 to 1,000 kg/mo (220 – 2,200 lbs./mo) of non-

acute hazardous waste.

c. CESQG: Less than 100 kg/mo (220 lbs./mo) of non-acute

hazardous waste.

Y N 8. Exempt Boiler and/or Industrial Furnace


If “Yes” above, indicate other generator activities in 2-4.

a. Small Quantity On-site Burner

Exemption

Y N 2. Short-Term Generator (generate from a short-term or one-time

event and not from on-going processes). If “Yes”, provide an

explanation in the Comments section.

b. Smelting, Melting, and Refining

Furnace Exemption

Y N 3. United States Importer of Hazardous Waste

Y N 9. Underground Injection Control

Y N 4. Mixed Waste (hazardous and radioactive) Generator

Y N 10. Receives Hazardous Waste from Off-

site

B. Universal Waste Activities; Complete all parts 1-2.

C. Used Oil Activities; Complete all parts 1-4.

Y N

1. Large Quantity Handler of Universal Waste (you

accumulate 5,000 kg or more) [refer to your State

regulations to determine what is regulated]. Indicate

types of universal waste managed at your site. If “Yes”,

mark all that apply. Y N 1. Used Oil Transporter


a. Transporter b. Transfer Facility (at your site)

a. Batteries b. Pesticides c. Mercury containing equipment

d. Lamps e. Other (specify) f. Other (specify)

g. Other (specify)

Y N 2. Used Oil Processor and/or Re-refiner


a. Processor b. Re-refiner Y N 3. Off-Specification Used Oil Burner

Y N 4. Used Oil Fuel Marketer


Y N

2. Destination Facility for Universal Waste

Note: A hazardous waste permit may be required for this

activity.

a. Marketer Who Directs Shipment of Off-

Specification Used Oil to Off-

Specification Used Oil Burner

b. Marketer Who First Claims the Used

Oil Meets the Specifications

EPA Form 8700-12, 8700-13 A/B, 8700-23 (Revised

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OMB# 2050-0024; Expires ____________

SENDCOMPLETEDFORM TO: The Appropriate State or Regional

Office. United States Environmental Protection Agency

RCRA SUBTITLE C SITE IDENTIFICATION FORM

1. Reason for Submittal

MARK ALL BOX(ES) THAT APPLY

Reason for Submittal: To provide an Initial Notification (first time submitting site identification information / to obtain an EPA ID number

for this location) To provide a Subsequent Notification (to update site identification information for this location)

As a component of a First RCRA Hazardous Waste Part A Permit Application

As a component of a Revised RCRA Hazardous Waste Part A Permit Application (Amendment # )

As a component of the Hazardous Waste Report (If marked, see sub-bullet below)

Site was a TSD facility and/or generator of >1,000 kg of hazardous waste, >1 kg of acute hazardous waste, or

>100 kg of acute hazardous waste spill cleanup in one or more months of the report year (or State equivalent

LQG regulations)

2. Site EPA ID Number EPA ID Number3. Site Name

Name:4. Site Location Information Street Address:City, Town, or Village:

County:

State:

Country:

Zip Code:

5. Site Land Type Private County District Federal Tribal Municipal State Other

6. NAICS Code(s) for the Site

(at least 5-digit codes)

A.

C.

B.

D.

7. Site Mailing Address Street or P.O. Box:City, Town, or Village:State:

Country:

Zip Code:

8. Site Contact Person First Name:

MI: Last:

Title: Street or P.O. Box:City, Town or Village:

State:

Country:

Zip Code:

Email:Phone:

Ext.:

Fax:

9. Legal Owner and Operator of the Site A. Name of Site’s Legal Owner:

Date Became Owner:

Owner Type: Private County District Federal Tribal Municipal State Other

Street or P.O. Box:City, Town, or Village:

Phone:

State:

Country:

Zip Code:

B. Name of Site’s Operator:

Date Became Operator:

Operator Type: Private County District Federal Tribal Municipal State Other

EPA Form 8700-12, 8700-13 A/B, 8700-23 (Revised

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OBTAINING AN EPA IDENTIFICATION NUMBER

If your business is an SQG, LQG, treatment, storage or disposal facility (TSDF), or transporter of hazardous waste, you must obtain and use an EPA Identification (ID) Num-ber. CESQGs are not required to obtain an EPA ID number, but it is recommended. The EPA and all states use these 12-character numbers to monitor and track hazardous waste activities. You will need to use your EPA ID number when you send waste off-site to be managed. Follow these steps to obtain an EPA ID number:

GET THE FORM

Visit the ADEQ’s Web site at http://www.epa.gov/osw/in-foresources/data/form8700/8700-12.pdf

Call ADEQ at (800) 234-5677 or write to: ADEQ, GIS & IT Unit, 1110 W. Washington St., Phoenix, Arizona, 85007, and request a copy of EPA Form 8700-12 Notification of Regulated Waste Activity. You will be sent a booklet that contains a form with instructions. A sample copy of a noti-fication form is shown on Pages 10 and 11.

COMPLETE THE FORM

Fill in the form as shown in the example. To complete Item 11 of the form, you will need to identify your hazardous waste by its EPA Hazardous Waste Code. A list of common hazardous wastes and their waste codes can be found in the center of this document. For a complete list of waste codes, you should consult 40 CFR Part 261 (as incorporat-ed by A.A.C. R18-8-261). Complete one copy of the form for each business site where you generate or handle hazard-ous waste. Each site will receive its own EPA ID number. Make sure you sign the certification in Item 14.

SEND THE FORM

Send the completed form with the original signature to the ADEQ Hazardous Waste Notification Coordinator, 1110 W. Washington St., Phoenix, Arizona, 85007. This address will also be listed in the information booklet that you will receive with the form.

MOVING AND CHANGE OF OWNERSHIP

ADEQ records the information on the form and assigns an EPA ID number to the site identified on your form. The EPA ID number stays with the property even when ownership changes.

• If you move your business, you must notify ADEQ to deactivate the old EPA ID number and submit a new form for your new location.

• If another business previously handled hazardous waste at your new location and obtained an EPA ID number, you will be assigned the same number after you have notified ADEQ that you have moved to this location. Otherwise, ADEQ will assign you a new iden-tification number.

• A revised 8700-12 must be submitted to ADEQ if own-ership changes, generator status changes, or the type of waste generated changes.

DEACTIVATING AN EPA ID

To deactivate an EPA ID number, submit on company letterhead the facility name, ID number, reason for deactivation, and the date of deactivation, and mail to ADEQ at the address below.

TIPS

EPA ID Number OMB#: 2050-0024; Expires ____________

12. Notification of Hazardous Secondary Material (HSM) Activity

Y N Are you notifying under 40 CFR 260.42 that you will begin managing, are managing, or will stop managing hazardous secondary material under 40 CFR 261.2(a)(2)(ii), 40 CFR 261.4(a)(23), (24), or (25)?

If “Yes”, you must fill out the Addendum to the Site Identification Form: Notification for Managing Hazardous Secondary Material.

13. Comments

14. Certification. I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Basedon my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significantpenalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. For the RCRA Hazardous Waste Part A Permit Application, all owner(s) and operator(s) must sign (see 40 CFR 270.10(b) and 270.11).

Signature of legal owner, operator, or an authorized representative

Name and Official Title (type or print) Date Signed (mm/dd/yyyy)

EPA Form 8700-12, 8700-13 A/B, 8700-23 (Revised Page 4 of

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12/2011)


D. Eligible Academic Entities with Laboratories—Notification for opting into or withdrawing from managing laboratory hazardous wastes pursuant to 40 CFR Part 262 Subpart K

You can ONLY Opt into Subpart K if:

you are at least one of the following: a college or university; a teaching hospital that is owned by or has a formal affiliationagreement with a college or university; or a non-profit research institute that is owned by or has a formal affiliation agreement with a college or university; AND

you have checked with your State to determine if 40 CFR Part 262 Subpart K is effective in your state

Y N 1. Opting into or currently operating under 40 CFR Part 262 Subpart K for the management of hazardous wastes in laboratories See the item-by-item instructions for definitions of types of eligible academic entities. Mark all that apply:

a. College or University

b. Teaching Hospital that is owned by or has a formal written affiliation agreement with a college or university

c. Non-profit Institute that is owned by or has a formal written affiliation agreement with a college or university

Y N 2. Withdrawing from 40 CFR Part 262 Subpart K for the management of hazardous wastes in laboratories

11. Description of Hazardous Waste

A. Waste Codes for Federally Regulated Hazardous Wastes. Please list the waste codes of the Federal hazardous wastes handled at your site. List them in the order they are presented in the regulations (e.g., D001, D003, F007, U112). Use an additional page if more spaces are needed.

B. Waste Codes for State-Regulated (i.e., non-Federal) Hazardous Wastes. Please list the waste codes of the State-Regulated hazardous wastes handled at your site. List them in the order they are presented in the regulations. Use an additional page if more spaces are needed.


12/31/2014

12/2011)



10. Type of Regulated Waste Activity (at your site) Mark “Yes” or “No” for all current activities (as of the date submitting the form); complete any additional boxes as instructed.

A. Hazardous Waste Activities; Complete all parts 1-10.

Y N 1. Generator of Hazardous Waste If “Yes”, mark only one of the following – a, b, or c.

Y N 5. Transporter of Hazardous Waste If “Yes”, mark all that apply.

a. LQG: Generates, in any calendar month, 1,000 kg/mo (2,200 lbs./mo.) or more of hazardous waste; orGenerates, in any calendar month, or accumulates at any time, more than 1 kg/mo (2.2 lbs./mo) of acute hazardous waste; orGenerates, in any calendar month, oraccumulates at any time, more than 100 kg/mo (220 lbs./mo) of acute hazardous spill cleanup material.

a. Transporter

b. Transfer Facility (at your site)

Y N 6. Treater, Storer, or Disposer of Hazardous Waste Note: A hazardous waste Part B permit is required for these activities.

Y N 7. Recycler of Hazardous Waste b. SQG: 100 to 1,000 kg/mo (220 – 2,200 lbs./mo) of non-

acute hazardous waste. c. CESQG: Less than 100 kg/mo (220 lbs./mo) of non-acute

hazardous waste. Y N 8. Exempt Boiler and/or Industrial Furnace


If “Yes” above, indicate other generator activities in 2-4. a. Small Quantity On-site Burner

Exemption

Y N 2. Short-Term Generator (generate from a short-term or one-time event and not from on-going processes). If “Yes”, provide an explanation in the Comments section.

b. Smelting, Melting, and Refining Furnace Exemption

Y N 3. United States Importer of Hazardous Waste Y N 9. Underground Injection Control

Y N 4. Mixed Waste (hazardous and radioactive) Generator Y N 10. Receives Hazardous Waste from Off-

site

B. Universal Waste Activities; Complete all parts 1-2. C. Used Oil Activities; Complete all parts 1-4.

Y N 1. Large Quantity Handler of Universal Waste (you accumulate 5,000 kg or more) [refer to your State regulations to determine what is regulated]. Indicate types of universal waste managed at your site. If “Yes”, mark all that apply.

Y N 1. Used Oil Transporter If “Yes”, mark all that apply.

a. Transporter

b. Transfer Facility (at your site)

a. Batteries

b. Pesticides

c. Mercury containing equipment

d. Lamps

e. Other (specify)

f. Other (specify)

g. Other (specify)

Y N 2. Used Oil Processor and/or Re-refiner If “Yes”, mark all that apply.

a. Processor

b. Re-refiner

Y N 3. Off-Specification Used Oil Burner

Y N 4. Used Oil Fuel Marketer If “Yes”, mark all that apply.

Y N 2. Destination Facility for Universal Waste Note: A hazardous waste permit may be required for this activity.

a. Marketer Who Directs Shipment of Off-Specification Used Oil to Off-Specification Used Oil Burner

b. Marketer Who First Claims the Used Oil Meets the Specifications


12/31/2014

12/2011)

OMB# 2050-0024; Expires ____________

SENDCOMPLETEDFORM TO: The Appropriate State or Regional Office.

United States Environmental Protection AgencyRCRA SUBTITLE C SITE IDENTIFICATION FORM

1. Reason for Submittal

MARK ALL BOX(ES) THAT

APPLY

Reason for Submittal: To provide an Initial Notification (first time submitting site identification information / to obtain an EPA ID number

for this location) To provide a Subsequent Notification (to update site identification information for this location) As a component of a First RCRA Hazardous Waste Part A Permit Application As a component of a Revised RCRA Hazardous Waste Part A Permit Application (Amendment # )

As a component of the Hazardous Waste Report (If marked, see sub-bullet below)

Site was a TSD facility and/or generator of >1,000 kg of hazardous waste, >1 kg of acute hazardous waste, or >100 kg of acute hazardous waste spill cleanup in one or more months of the report year (or State equivalent LQG regulations)

2. Site EPA ID Number EPA ID Number

3. Site Name Name:

4. Site Location Information

Street Address:

City, Town, or Village: County:

State: Country: Zip Code:

5. Site Land Type Private County District Federal Tribal Municipal State Other

6. NAICS Code(s) for the Site

(at least 5-digit codes)

A. C.

B. D.

7. Site Mailing Address

Street or P.O. Box:

City, Town, or Village:


8. Site Contact Person

First Name: MI: Last:

Title:

Street or P.O. Box:

City, Town or Village:


Email:

Phone: Ext.: Fax:

9. Legal Owner and Operator of the Site

A. Name of Site’s Legal Owner: Date Became Owner:

Owner Type: Private County District Federal Tribal Municipal State Other

Street or P.O. Box:

City, Town, or Village: Phone:


B. Name of Site’s Operator: Date Became Operator:

Operator Type: Private County District Federal Tribal Municipal State Other


12/31/2014

12/2011)

SITE IDENTIFICATION FORM Page 1 – This is the page where the owner and site information are entered along with the EPA ID number.

Page 2 – This is the page where Hazardous Waste Activities, Uni-versal Waste Activities and Used Oil Activities are entered. The EPA ID number needs to be entered on the upper left side of the form.



12. Notification of Hazardous Secondary Material (HSM) Activity

Y N Are you notifying under 40 CFR 260.42 that you will begin managing, are managing, or will stop managing hazardous secondary material under 40 CFR 261.2(a)(2)(ii), 40 CFR 261.4(a)(23), (24), or (25)?

If “Yes”, you must fill out the Addendum to the Site Identification Form: Notification for Managing Hazardous Secondary Material.

13. Comments

14. Certification. I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Basedon my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significantpenalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. For the RCRA Hazardous Waste Part A Permit Application, all owner(s) and operator(s) must sign (see 40 CFR 270.10(b) and 270.11).

Signature of legal owner, operator, or an authorized representative

Name and Official Title (type or print) Date Signed (mm/dd/yyyy)


12/31/2014

12/2011)


D. Eligible Academic Entities with Laboratories—Notification for opting into or withdrawing from managing laboratory hazardous wastes pursuant to 40 CFR Part 262 Subpart K

You can ONLY Opt into Subpart K if:

you are at least one of the following: a college or university; a teaching hospital that is owned by or has a formal affiliationagreement with a college or university; or a non-profit research institute that is owned by or has a formal affiliation agreement with a college or university; AND

you have checked with your State to determine if 40 CFR Part 262 Subpart K is effective in your state

Y N 1. Opting into or currently operating under 40 CFR Part 262 Subpart K for the management of hazardous wastes in laboratories See the item-by-item instructions for definitions of types of eligible academic entities. Mark all that apply:

a. College or University

b. Teaching Hospital that is owned by or has a formal written affiliation agreement with a college or university

c. Non-profit Institute that is owned by or has a formal written affiliation agreement with a college or university

Y N 2. Withdrawing from 40 CFR Part 262 Subpart K for the management of hazardous wastes in laboratories

11. Description of Hazardous Waste

A. Waste Codes for Federally Regulated Hazardous Wastes. Please list the waste codes of the Federal hazardous wastes handled at your site. List them in the order they are presented in the regulations (e.g., D001, D003, F007, U112). Use an additional page if more spaces are needed.

B. Waste Codes for State-Regulated (i.e., non-Federal) Hazardous Wastes. Please list the waste codes of the State-Regulated hazardous wastes handled at your site. List them in the order they are presented in the regulations. Use an additional page if more spaces are needed.


12/31/2014

12/2011)

Page 3 – This is the page where Eligible Academic Entities with Laboratories are identified. Descriptions of Hazardous Waste and the Hazardous Waste Codes are also entered here. The EPA ID number needs to be entered on the upper left side of the form.

Page 4 – This is the page where Hazardous Secondary Material is entered along with the signature of the site owner or authorized representative. The EPA ID num-ber needs to be entered on the upper left side of the form.


REQUIREMENTS FOR CONDITIONALLYEXEMPT SMALL QUANTITY GENERATORS If you generate no more than 220 pounds (100 kg) of haz-ardous waste in any month, you are a conditionally exempt small quantity generator (CESQG). You must comply with three basic waste management requirements to remain ex-empt from the full hazardous waste regulations that apply to generators of larger quantities (SQGs and LQGs).

First, you must identify all hazardous waste that you gener-ate and keep documentation of your waste determinations.

Second, you may not store more than 2,200 pounds (1,000 kg) total of hazardous waste, 2.2 pounds (1 kg) of acute hazardous waste, and 220 pounds (100 kg) of acute haz-ardous residue, debris, or soil on-site at any time.

Finally, you must ensure delivery of your hazardous waste to an off-site treatment or disposal facility that is one of the following:

• An Arizona- or federally-regulated hazardous waste treatment, storage, or disposal facility (TSDF).

• A facility permitted, licensed, or registered by Arizona to manage municipal or industrial solid waste.

• A facility that uses, reuses, or legitimately recycles the waste (or treats the waste prior to use, reuse, or recycling).

• A universal waste handler or destination facility subject to the universal waste requirements of 40 CFR Part 273 (as incorporated by A.A.C R18-8-273) if your waste is universal waste. Universal wastes are wastes such as certain batteries, recalled and banned pesti-cides, or mercury-containing thermostats, and mercu-ry-containing waste lamps.

• Or, if you treat or dispose your hazardous waste on-site, your facility must also meet the above definitions.

REQUIREMENTS FOR SMALL QUANTITY GENERATORS

Most small businesses accumulate some hazardous waste on-site for a short period of time and then ship it off-site to a treatment, storage, or disposal facility (TSDF). You will need to use your EPA ID number when you send waste off-site to be managed.

ACCUMULATING YOUR WASTE

Accumulating hazardous waste on-site can pose a threat to human health and the environment, so you may only keep it for a short time without a permit. Before shipping the waste for disposal or recycling, you are responsible for its safe management which includes safe storage, safe treat-ment, preventing accidents, and responding to emergen-cies in accordance with federal and Arizona regulations.

SQGs can accumulate no more than 13,228 pounds (6,000 kg) of hazardous waste on-site for up to 180 days without a permit. You can accumulate this amount of waste for up to 270 days if you must transport it more than 200 miles away for recovery, treatment, or disposal. Limited exten-sions may be granted by the ADEQ director. If you exceed these limits, you may be considered a TSDF and may be required to obtain a hazardous waste permit.

SQGs must ensure their hazardous waste is properly stored (ex: tanks or containers, such as 55-gallon drums). Your storage tanks and containers must be managed according to the following summarized requirements. For detailed information, refer to 40 CFR 262.34(d) and 40 CFR 265 Subpart I & J.

There are different quantity limits for acute hazardous waste. If you generate more than 2.2 pounds (1 kg.) then you are not considered a CESQG. See page 6 Finding You Genrator Category for more information.

CESQGs are not required to obtain an EPA identification number, but it is highly recommended.

CESQGs with EPA identification numbers must complete a Registration Form/Facility Annual Report yearly. See Appendix C.

TIPS

Accumulate wastes according to limits established for SQGs.

Follow the storage and handling procedures required by federal and Arizona rules for SQGs.

Ensure to train employees so that they are thoroughly familiar with proper waste handling and emergency procedures.

Follow requirements for emergency equipment testing and maintenance, access to communications or alarms, aisle space, and posting emergency information as required by federal and Arizona rules.


TREATING YOUR WASTE TO MEET THE LANDDISPOSAL RESTRICTIONS (LDRs)

Most hazardous wastes may not be disposed on land un-less they meet treatment standards. The Land Disposal Re-strictions (LDR) program requires that the waste is treated to reduce the hazardous constituents to levels set by EPA, or that the waste is treated using a specific technology. It is your responsibility to ensure that your waste is treated to meet LDR treatment standards before it is disposed on land. (See page 14 for a description of required LDR notic-es.) Most SQGs probably will have their designated TSDF do this treatment. If you choose to treat your waste your-self to meet LDR treatment standards, there are additional requirements, including waste analysis plans, notifications, and certifications. To learn about these requirements call the EPA RCRA Hotline (800) 424-9346, the ADEQ Inspec-tions & Compliance Unit (800) 234-5677, or consult 40 CFR Part 268 (as incorporated by A.A.C. R18-8-268).

Special storage requirements apply to liquid hazardous wastes containing polychlorinated biphenyls (PCBs).

TIPFor storage containers, you must:• Label each container with the words “HAZARDOUS

WASTE,” and mark each container with the date waste was first added.

• Use a container made of, or lined with, a material that is compatible with the hazardous waste to be stored. (This will prevent the waste from reacting with or corroding the container.)

• Keep all containers holding hazardous waste closed during storage, except when adding or removing waste. Do not open, handle, or store (stack) containers in a way that might rupture them, cause them to leak, or otherwise fail.

• Inspect areas where containers are stored at least weekly. Look for leaks and for deterioration caused by corrosion or other factors.

• Maintain the containers in good condition. If a contain-er leaks, put the hazardous waste in another container, or contain it in some other way that complies with EPA and state regulations.

• Do not mix incompatible wastes or materials unless precautions are taken to prevent certain hazards.

For tanks, you must:

• Label each tank with the words “HAZARDOUS WASTE.”• Store only waste that will not cause the tank or the

inner liner of the tank to rupture, leak, corrode, or fail.• Equip tanks that have an automatic waste feed with a

waste feed cutoff system or a bypass system for use in the event of a leak or over- flow.

• Inspect discharge control and monitoring equipment and the level of waste in uncovered tanks at least once each operating day. Inspect the tanks and surrounding areas for leaks or other problems (such as corrosion) once each operating day.

• Use the National Fire Protection Association (NFPA) buffer zone requirements for covered tanks contain-ing ignitable or reactive wastes. These requirements specify distances considered to be safe buffer zones for various ignitable or reactive wastes. You can reach the NFPA at (617) 770-3000.

• Do not mix incompatible wastes or materials unless precautions are taken to prevent certain hazards.

• Do not place ignitable or reactive wastes in tanks un-less certain precautions are taken.

• Provide at least two feet (60 centimeters) of freeboard (space at the top of each tank) in uncovered tanks, unless the tank is equipped with a containment struc-ture, a drainage control system, or a standby tank with adequate capacity.


PREPARING HAZARDOUS WASTE MANIFESTS

A hazardous waste manifest must accompany all hazardous waste that is shipped off-site. A hazardous waste manifest is a multipart form designed to track hazardous waste from generation to disposal. It will help you track your waste during shipment and ensure it arrives at the proper des-tination. If you send waste to a recycling facility, you may be able to use a tolling agreement instead of a manifest. A tolling agreement is a closed-loop arrangement whereby a generator contracts with a recycling company to reclaim its hazardous waste and return it as a recycled product, there-by avoiding disposal. A copy of the contract must be kept on file for three years after the contract has ended.

Various versions of hazardous waste manifest forms are available.

• Some states require their own manifest form. Arizona uses the federal form (Uniform Hazardous Waste Man-ifest, EPA form 8700-22). If the state to which you are shipping your waste requires its own manifest, use that state’s form. To obtain manifest forms, contact the haz-ardous waste management agency of the recipient state, your transporter, or the TSDF that you intend to use.

• If the state to which you are shipping does not require its own manifest, you can use the federal form. Copies are available from some transporters, TSDFs, and some commercial printers.

SHIPPING HAZARDOUS WASTE OFF-SITE

When shipping waste off-site, SQGs must follow certain procedures that are designed to ensure safe transport and proper management of the waste.

LABELING WASTE SHIPMENTS

• Package, label and mark your shipment, and placard the vehicle in which your waste is shipped as specified in Department of Transportation (DOT) regulations.

• Prepare a hazardous waste manifest to accompany your shipment.

• Include an LDR notice and certification with each waste shipment.

• Ensure the proper management of any hazardous waste you ship (even when it is no longer in your possession).

SQGs must properly package, label and mark all hazard-ous waste shipments, and placard the vehicles in which these wastes are shipped following DOT regulations. Most small businesses use a commercial transporter to ship hazardous waste. These transporters can advise you on specific requirements for placarding, labeling, mark-ing, and packaging; however, you remain responsible for compliance. For additional information, consult DOT regulations (49 CFR Parts 172 and 173), or call the DOT hazardous materials information line at (202) 366-4488. In Arizona, you can also contact ADOT Hazardous Materi-als, at (602) 712-4407.

Federal and Arizona regulations allow you to transport your own hazardous waste to a designated TSDF provided that you comply with DOT rules and register with ADEQ as a hazardous waste transporter. Some states, however, do not allow this practice. Call DOT and the state hazardous waste management agency to which you are shipping the waste regarding applicable regulations.

SELECTING A TSDF

It is important to choose your transporter and your TSDF carefully since you remain responsible for the proper man-agement of your hazardous waste even after it has left your site and has been processed by your TSDF.

SQGs may send their waste only to a regulated TSDF or recycler. Most regulated TSDFs and recyclers will have a permit from the state or EPA. Some, however, may oper-ate under other regulations that do not require a permit. Check with the appropriate state authorities to be sure the facility you select has any necessary permits. All TSDFs and recyclers must have EPA ID numbers.

FOR HELP IN CHOOSING A TRANSPORTER OR TSDF, CHECK WITH THE FOLLOWING SOURCES:

• References from business colleagues who have used a specific hazardous waste transporter or TSDF.

• Trade associations for your industry that might keep a file on companies that handle hazardous waste.

• The Better Business Bureau or Chamber of Commerce in the TSDF’s area, which might have a record of any complaints registered against a transporter or a facility.

• ADEQ can tell you whether the transporter or TSDF has a U.S. EPA ID number and a permit, if required.

TIP

TIPEPA WASTE CODES: Ensure to include all hazardous waste codes applicable to the waste being manifested.


HAZARDOUS WASTE CODE CHART

PULL OUT AND POST FOR QUICK REFERENCE

M AN

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STEPS TO BASIC HAZARDOUS WASTE

MANAGEMENT


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.3(c

)(2)(i

))

Dete

rmin

e G

ener

ator

Sta

tus

Solid

Was

te o

r H

azar

dous

W

aste

rul

es d

o no

t app

ly

*E

nsur

e do

cum

enta

tion

and

reco

rd m

aint

enan

ce

GE

NE

RA

TO

R C

LA

SS

CO

MP

AR

ISO

N C

HA

RT

Con

ditio

nally

Exe

mpt

Sm

all

Qua

ntity

Gen

erat

or

Smal

l Qua

ntity

Gen

erat

or

Lar

ge Q

uant

ity G

ener

ator

Mon

thly

Gen

erat

ion

Rat

e ≤

100

kg (2

20 lb

s.) -

or-

≤

1 kg

(2.2

lbs.)

of A

cute

was

te -

or -

≤ 10

0 kg

(220

lbs.)

resi

due,

deb

ris, s

oil

> 10

0 kg

(220

lbs.)

- a

nd -

≤

1000

kg

(2,2

00 lb

s.)

> 10

00 k

g (2

,200

lbs.)

-o

r -

> 1

kg (2

.2 lb

s.) o

f Acu

te w

aste

Max

imum

Am

ount

Sto

red

≤ 10

00 k

g (2

,200

lbs.)

of t

otal

(acu

te +

no

n-ac

ute

was

te) -

or

- ≤

1 kg

Acu

te w

aste

(2.2

lbs.)

- or

- ≤

100

kg (2

20 lb

s.) A

cute

resi

due,

deb

ris,

soil

≤ 60

00 k

g (~

13,2

28 lb

s.) to

tal (

acut

e +

non

acut

e w

aste

) - o

r -

≤ 1

kg (2

.2 lb

s.) A

cute

was

te -

or -

≤

100

kg (2

20 lb

s.) A

cute

resi

due,

deb

ris, s

oil

No

Am

ount

Lim

it

- but

- <

20,0

00 k

g (~

44,1

00 lb

s.) fo

r F00

6 ~2

roll-

offs

15

yds.

each

; ~1

stan

dard

44,

000

lb.

truck

load

Stor

age

Tim

e Li

mit

No

Tim

e Li

mit

≤ 18

0 da

ys

≤ 27

0 da

ys if

gre

ater

than

200

mile

s to

treat

men

t, st

orag

e, d

ispo

sal f

acili

ty (T

SDF)

30

day

ext

ensi

on w

ith p

rior A

DEQ

app

rova

l

≤ 90

day

s ≤

180

days

for F

006

sludg

e w

hen

with

in 2

00

mile

s to

TSD

F

30 d

ay e

xten

sion

with

prio

r AD

EQ a

ppro

val

AD

EQ

Reg

istra

tion

and

Gen

erat

ion

Fees

N

ot R

equi

red

No

Fees

$100

Ann

ual F

ee

$67.

50 G

ener

atio

n Fe

e pe

r ton

(* N

o m

ore

than

$20

0,00

0/ge

nera

tor/y

r./si

te/h

azar

dous

w

aste

gen

erat

ed)

$300

Ann

ual F

ee

$67.

50 G

ener

atio

n Fe

e pe

r ton

(* N

o m

ore

than

$20

0,00

0/ge

nera

tor/y

r./si

te/h

azar

dous

W

aste

gen

erat

ed)

EPA

ID N

umbe

r N

ot R

equi

red,

but

reco

mm

ende

d R

equi

red

(301

0; 8

700-

12 fo

rm)

Req

uire

d p

er 4

0 CF

R §

262

.12

(301

0; 8

700-

12 fo

rm)

Faci

lity

Ann

ual

Rep

ort

Not

requ

ired

AD

EQ F

acili

ty R

egis

tratio

n Fo

rm fo

r Haz

ardo

us

Was

te is

the

Faci

lity

Ann

ual R

epor

t (FA

R)

Req

uire

d Fe

dera

l Lon

g Fo

rm [A

AC

R18

-8

262.

H] E

PA F

orm

870

0-13

due

Mar

ch 1

st o

f the

cu

rren

t yea

r for

gen

erat

or w

aste

act

ivity

for t

he

prev

ious

yea

r

RC

RA

Sub

title

C

Site

iden

tific

atio

n fo

rm re

quire

d fo

r any

faci

lity

whe

n in

itial

ly re

gist

erin

g w

ith A

DEQ

or t

o up

date

cha

nge

to in

itial

form

(870

0-12

)

Con

tinge

ncy

Plan

N

ot R

equi

red

Bas

ic In

form

atio

n po

sted

by

Phon

e Fu

ll Pl

an R

equi

red

(40

CFR

§26

5 Su

bpar

t D)

Pers

onne

l Tra

inin

g N

ot R

equi

red

Bas

ic T

rain

ing

(40

CFR

§26

2.34

(d)(

5)(ii

i))

Req

uire

d (4

0 C

FR §

265.

16)

Prep

ared

ness

and

Pr

even

tion

Not

Req

uire

d R

equi

red

(40

CFR

§26

5 Su

bpar

t C)

Req

uire

d (4

0 C

FR §

265

Subp

art C

)

Man

ifest

N

ot R

equi

red

Req

uire

d [A

AC

R18

-8-2

62.F

& I]

R

equi

red

[AA

C R

18-8

-262

.F &

I]

Exce

ptio

n R

epor

t N

ot R

equi

red

Req

uire

d af

ter 6

0 D

ays

(40

CFR

§26

2.42

(b))

R

equi

red

afte

r 45

Day

s (4

0 CF

R §

262.

42(a

)(2))

Sate

llite

Con

tain

ers

Allo

wed

A

llow

ed (4

0 C

FR §

262.

34 (c

)(1)

) A

llow

ed (4

0 C

FR §

262.

34 (c

)(1)

)

Stor

age

Req

uire

men

ts

Lim

ited

requ

irem

ents

. Ide

ntify

all

ha

zard

ous w

aste

s; c

ompl

y w

ith q

uant

ity

limits

; shi

p to

app

rove

d so

lid o

r haz

ardo

us

was

te fa

cilit

y; d

o no

t dis

char

ge to

soil/

w

ater

/air.

Com

ply

with

the

tech

nica

l sta

ndar

ds u

nder

40

CFR

§2

65 S

ubpa

rt I

for c

onta

iner

s, ex

cept

265

.176

(50

foot

setb

ack

for i

gnita

bles

) and

265

.178

(air

em

issi

ons)

. Com

ply

with

redu

ced

Subp

art J

re

quire

men

ts fo

r ta

nks.

Com

ply

with

the

tech

nica

l sta

ndar

ds u

nder

40

CFR

Sub

part

I fo

r con

tain

ers i

nclu

ding

air

em

issi

on st

anda

rds.

Com

ply

with

full

Subp

art J

requ

irem

ents

for t

anks

.

Gen

eral

Ref

eren

ce

40 C

FR §

261.

5 40

CFR

§26

2.34

(d)&

(e)

40 C

FR §

262.

34(a

)&(b

)

*Thi

s gra

ph is

onl

y fo

r bas

ic in

form

ation

al p

urpo

ses o

nly.

Ple

ase

refe

r to

the

corr

espo

ndin

g fe

dera

l and

stat

e re

gula

tions

for a

com

plet

e lis

t of r

equi

rem

ents

.

Mat

eria

l

Ste

ps

to B

asic

Haz

ard

ou

s W

aste

Man

agem

ent

Exc

lude

d?

From

a S

olid

Was

te -

(40

CFR

§ 2

61.4

(a))

NO

No

Yes

No

CESQ

G SQ

G LQ

G

Jani

ce K

. Bre

wer

, Gov

erno

r •He

nry

R. D

arw

in, D

irect

or


STEPS TO BASIC HAZARDOUS WASTE

MANAGEMENT


AD

EQ

/ M AN

AG

ING

H AZA

RD

OU

S W AST

E

1 5

C

Perc

hlor

icA

cid

Phos

phor

icA

cid

Pota

ssiu

m H

ydro

xide

So

dium

Hyd

roxi

de

Sulfu

ricA

cid

DR

YC

LEAN

ING

FILT

RATI

ON

RES

IDU

ESC

ooke

d po

wde

r res

idue

(per

-ch

loro

ethy

lene

plan

ts o

nly)

, stil

l re

sidu

es, a

nd sp

ent c

artri

dge

filte

rs c

onta

inin

g pe

rchl

oro-

ethy

lene

or v

alcl

ene

are

haza

rd-

ous a

nd h

ave

the

was

te c

ode

F002

. Stil

l re

sidu

es c

onta

inin

g pe

trole

um so

lven

ts w

ith a

fla

shpo

int l

ess t

han

140 °

F ar

e co

nsid

ered

ha

zard

ous a

nd h

ave

the

was

te c

ode

D00

1.

HEA

VYM

ETAL

S/IN

OR

GAN

ICS

This

list

can

be

used

as

agu

ide

fors

mal

l qu

antit

y ge

nera

tors

tode

term

ine

whi

ch o

fth

eir w

aste

s, if

any,

are

haza

rdou

s, a

nd to

dete

rmin

e th

eEP

A w

aste

cod

es a

ssoc

iate

d w

ithea

ch w

aste

. Iti

s no

tint

ende

d to

prov

ide

aco

mpr

ehen

sive

list

ofa

llw

aste

cod

es a

nd

was

te s

trea

ms

that

smal

l bus

ines

ses

coul

d ge

nera

te. E

xcep

t for

the

pest

icid

e an

d w

ood

pres

ervi

ng c

ateg

orie

s, th

is li

st d

oes

not

incl

ude

was

te c

odes

forc

omm

erci

al

chem

ical

pro

duct

s th

atar

e ha

zard

ous

whe

n

disc

arde

d un

used

. The

sew

aste

s, a

s w

ella

sal

loth

ers

notl

iste

d he

re, c

an b

efo

und

inTi

tle40

of40

CFR

Par

t 261

.Ify

ou h

ave

any

ques

tions

, con

tact

AD

EQat

(800

)234

-567

7,th

eR

CR

A H

otlin

eat

(800

)424

-934

6or

TDD

(800

)533

-767

2fr

omot

her l

ocat

ions

.

Ald

icar

b*P0

70A

mitr

ole

U01

11,

2-D

ichl

orop

rope

neU

084

Hep

tach

lor*

P059

Lind

ane

U12

9M

ethy

l Par

athi

on*

P071

Para

thio

n*P0

89Ph

orat

e*P0

94

REA

CTI

VES

Rea

ctiv

e w

aste

s inc

lude

mat

eria

ls o

r m

ixtu

res t

hat a

re u

nsta

ble,

reac

t vi

olen

tly w

ith o

rfor

m e

xplo

sive

m

ixtu

res w

ith w

ater

, gen

erat

e to

xic

gase

s or v

apor

s whe

n m

ixed

with

wat

er (o

r whe

n ex

pose

d to

pH

con

ditio

ns b

etw

een

2 an

d 12

.5 in

th

e ca

se o

f cya

nide

or s

ulfid

e-be

arin

g w

aste

s), o

r ar

e ca

pabl

e of

det

onat

ion

or e

xplo

sive

reac

tion

whe

n he

ated

or su

bjec

t to

shoc

k (f

or a

com

plet

e de

scrip

tion

of re

activ

e w

aste

s, se

e 40

CFR

261.

23).

Unl

ess o

ther

wis

e sp

ecifi

ed, a

ll re

activ

ew

aste

s hav

e th

e w

aste

cod

e D

003.

The

follo

win

gH

eavy

met

als a

nd o

ther

inor

gani

c w

aste

mat

eria

ls a

re c

onsi

dere

dH

Gha

zard

ous i

f the

ext

ract

from

a re

pres

enta

tive

sam

ple

of th

e w

aste

mat

eria

ls a

re c

omm

only

con

side

red

to b

e re

activ

e:

has a

ny o

f the

spec

ific

cons

titue

nt c

once

ntra

tions

as s

how

n in

40

DC

FR 2

62.2

4,Ta

ble

1. M

ater

ials

may

incl

ude

dust

s, so

lutio

ns, w

aste

-

Ace

tylC

hlor

ide

Chr

omic

Aci

dC

yani

des

Hyp

ochl

orite

sO

rgan

ic P

erox

ides

Perc

hlor

ates

Perm

anga

nate

sSu

lfide

s

wat

er tr

eatm

ent s

ludg

es, p

aint

was

tes,

and

was

te in

ks.T

he fo

llow

ing

are

com

mon

hea

vy m

etal

s/in

orga

nics

:SP

ENT

PLAT

ING

AN

DC

YAN

IDE

WAS

TES

Spen

t pla

ting

was

tes c

onta

in c

lean

ing

solu

tions

and

pla

ting

solu

tions

Ars

enic

D00

4B

ariu

mD

005

Cad

miu

mD

006

Chr

omiu

mD

007

Lead

D00

8M

ercu

ryD

009

Sele

nium

D01

0Si

lver

D01

1

with

cau

stic

s, so

lven

ts, h

eavy

met

als,

and

cyan

ides

. Cya

nide

was

tes

may

als

o be

gen

erat

ed fr

om h

eat t

reat

men

t ope

ratio

ns, p

igm

ent

prod

uctio

n, a

nd m

anuf

actu

ring

of a

nti-c

akin

g ag

ents

. Pla

ting

was

tes

gene

rally

hav

e th

e w

aste

cod

es F

006-

F009

, with

F00

7 an

dF0

09co

ntai

ning

cy

anid

e. C

yani

de h

eat t

reat

ing

was

tes g

ener

ally

hav

e th

e w

aste

cod

esF0

10-F

012

(see

40

CFR

261

.31

for a

mor

e co

mpl

ete

desc

riptio

n of

pla

ting

was

tes)

.

INK

SLUD

GES

CO

NTA

ININ

G C

HRO

MIU

M A

ND

LEAD

This

cat

egor

y in

clud

es so

lven

t was

hes a

nd sl

udge

s, ca

ustic

was

hes

and

slud

ges,

and

wat

er w

ashe

s and

slud

ges f

rom

cle

anin

g tu

bs a

nd

equi

pmen

t use

d in

the

form

ulat

ion

of in

k fr

om p

igm

ents

, drie

rs,

soap

s, an

d st

abili

zers

con

tain

ing

chro

miu

m a

nd le

ad.A

ll in

k sl

udge

s ha

ve th

e w

aste

cod

e K0

86.

WO

OD

PRE

SERV

ING

AG

ENTS

The

was

tew

ater

trea

tmen

t slu

dges

from

was

tew

ater

trea

tmen

t ope

ra-

tions

are

cons

ider

ed h

azar

dous

. Bot

tom

sedi

men

t slu

dges

from

the

treat

men

t of w

aste

wat

er p

roce

sses

that

use

cre

osot

e an

d pe

ntac

hlo-

roph

enol

hav

e th

e w

aste

cod

e K

001.

In a

dditi

on, u

nles

s oth

erw

ise

indi

cate

d, sp

ecifi

c w

ood

pres

ervi

ng c

ompo

unds

are

:

Chr

omat

ed C

oppe

rArs

enat

eD

004

Cre

osot

eU

051

Pent

achl

orop

heno

lF0

27


HAZARDOUS WASTE CODE CHART



You must fill in all parts of a manifest and sign it. Infor-mation requested includes: name of transporter, EPA ID number, quantity of waste, hazardous waste codes, and a description of the waste based on DOT requirements, such as proper shipping name and hazard class. Call the DOT information line for more information on DOT waste description requirements. Arizona requires the EPA Waste Codes, (D001 – D043, F-, K-, P-, or U-listed), to be listed in Column I.

The transporter is required to sign the completed manifest when the shipment is accepted for transport. The facility operator at the designated TSDF also signs the form when the shipment is received and sends a copy of it back to you. You must keep this copy on file for three years. (It might be a good practice, however, to keep it for as long as you are in business.) Arizona also requires the generator and transporter to send a copy of the manifest to ADEQ, GIS & IT Unit, 1110 W. Washington St., 4415A-1, Phoenix, AZ, 85007. All TSDFs located in Arizona are also required to send copies to ADEQ.

Arizona requires generators to submit manifests for hazardous waste shipments only. The generator copy, also known as the “Destination Facility to Generator Copy,” that is submitted to ADEQ must be legible and have three signa-tures: the generator, the transporter, and the TSDF.

Any SQG that does not receive a signed copy of the mani-fest from the designated TSDF must submit a legible copy of the manifest to ADEQ together with a written notice indicating that a signed copy was not received from the TSDF. This is known as an exception report and must be submitted to ADEQ within 60 days following the end of the month of shipment of the waste.

If errors are found on your manifest, you will be notified by ADEQ. You must correct the manifest and pay a $20 per manifest resubmittal fee.

LAND DISPOSAL RESTRICTIONS(LDR) REPORTING REQUIREMENTS

Regardless of where the waste is being sent, for each ship-ment of waste subject to LDRs, you must send the receiving TSDF or recycler an LDR notice. This notice must provide information about your waste, such as the EPA hazardous waste code and the LDR treatment standard. The purpose of this notice is to let the TSDF know that the waste must meet treatment standards before it is land disposed. There is no required form for this notice, but your TSDF may provide a form for you to use. A certification may also be required in specific situations. Call the EPA RCRA Hotline at (800) 424-9346, the ADEQ Inspections and Compliance Unit at (800) 234-5677, and consult 40 CFR Part 268 for help with LDR notification and certification requirements.

EXPORT NOTIFICATION:

If you choose to export your hazardous waste, you must notify EPA 60 days before the intended date of shipment to obtain written consent. EPA’s Acknowledgment of Consent document must accompany the shipment at all times. For more information on how to obtain the consent to export hazardous waste, contact the EPA RCRA Hotline at (800) 424-9346.

TIP

WASTE MINIMIZATION: THE KEY TO BETTER WASTE MANAGEMENTThe easiest and most cost-effective way of managing any waste is not to generate it in the first place. You can decrease the amount of hazardous waste your business produces by developing a few good housekeeping habits. Good housekeeping procedures generally save business-es money, and they prevent accidents and waste. To help reduce the amount of waste you generate, try the following practices at your business.

• Do not mix wastes. Do not mix non-hazardous waste with hazardous waste. Once you mix non-hazardous waste with hazardous waste, you may increase the amount of hazardous waste created, as the whole batch may become hazardous. Mixing waste can also make recycling very difficult, if not impossible. A typical example of mixing wastes would be putting nonhazardous cleaning agents in a container of used hazardous solvents.

• Recycle and reuse manufacturing materials. Many companies routinely put useful components back into productive use rather than disposing them. Items such as oil, solvents, acids, and metals are commonly recy-cled and used again. In addition, some companies have taken waste minimization actions, such as using fewer solvents to do the same job, using solvents that are less toxic, or switching to a detergent solution.

• Change materials, processes, or both. Businesses can save money and increase efficiency by replacing a material or a process with another that produces less waste. For example, you could use plastic blast media for paint stripping of metal parts rather than conven-tional solvent stripping.

• Safely store hazardous products and containers. You can avoid creating more hazardous waste by prevent-ing spills or leaks. Store hazardous product and waste containers in secure areas, and inspect them frequent-ly for leaks. When leaks or spills occur, materials used to clean them up also become hazardous waste.


RESPONDING TO EMERGENCIES

You must be prepared for an emergency at your facility. One way is to develop a contingency plan. A contingency plan usually answers a set of “what if” questions. For ex-ample: “What if there is a fire in the area where hazardous waste is stored?” or “What if I spill hazardous waste or one of my hazardous waste containers leak?” Although EPA does not require SQGs to develop a written contingency plan, in case of a fire, explosion, or release of hazardous waste or hazardous waste constituents, having such a plan would provide an organized and coordinated course of action. EPA does require SQGs to establish basic safety guidelines and response procedures to follow in the event of an emergency.

Worksheets 1 and 2 (see Page 25) can help you set up these procedures. The information on Worksheet 1 must be post-ed near your phones. You must ensure that employees are familiar with these procedures. Keep information current.

IF YOU THINK YOU HAVE AN EMERGENCY, IMMEDIATELY CALL THE NATIONAL RESPONSE CENTER AT (800) 424-8802 AND ADEQ AT (800) 234-5677.

In the event of a fire, explosion, or other release of hazardous waste that could threaten human health outside the facility, or if you think that a spill has reached surface water, call the National Response Center to report the emergency. The Response Center will evaluate the situation and help you make appropriate emergency decisions. In many cases, you will find that the problem you faced was not a true emergency, but it is better to call if you are not sure. Stiff penalties exist for failing to report emergencies.

Clean up spills and leaks quickly to avoid larger problems.

TIP

It is good practice never to mix wastes. Mixing wastes can create an unsafe work environment and lead to complex and expensive cleanups and disposal.

TIP

PREVENTING ACCIDENTS

Whenever you store hazardous waste on-site, you must minimize the potential risks from fires, explosions, or other accidents.

All SQGs that store hazardous waste on-site must be equipped with the following, unless none of the hazards posed by the waste handled at the facility could require a particular kind of equipment specified below:

• An internal communications or alarm system capable of providing immediate emergency instruction (voice or signal) to all personnel.

• A device, such as a telephone (immediately available at the scene of operations) or a hand- held, two-way radio, capable of summoning emergency assistance from local police and fire departments or emergency response teams.

• Portable fire extinguishers, fire control devices (in-cluding special extinguishing equipment, such as that using foam, inert gas, or dry chemicals), spill control materials, and decontamination supplies.

• Water at adequate volume and pressure to supply water hose streams, foam-producing equipment, auto-matic sprinklers, or water spray systems.

You must test and maintain all equipment to ensure proper operation. You must allow sufficient aisle space to permit the unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of facility operation. You must at-tempt to secure arrangements with fire departments, police, emergency response teams, equipment suppliers, and local hospitals, as appropriate, to provide services in the event of an emergency. You must ensure that personnel handling hazardous waste have immediate access to an alarm or emergency communications device.

Photo by: Wikimedia Commons; Simeon87

Managing Hazardous Waste Handbook 2522 MANAGING HAZARDOUS WASTE / ADEQ

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WORKSHEET 1 REQUIRED. Fill in and post this information next to your telephone.

EMERGENCY RESPONSE INFORMATIONEMERGENCY COORDINATOR

Name:

SPILL CONTROL MATERIALSLocation(s):

Telephone:

FIRE EXTINGUISHERLocation(s):

FIRE ALARM (IF PRESENT)Location(s):

FIRE DEPARTMENTTelephone:

✃ WORKSHEET 2 Fill in shaded area and post this information next to your telephone. Make

sure all employees read and are familiar with its contents.

EMERGENCY RESPONSE PROCEDURESIn the event of a spill:

Contain the flow of hazardous waste to the extent possible, and as soon as is possible, clean up the hazardous waste and any contaminated materials or soil.

In the event of a fire:

Call the fire department and, if safe, attempt to put out the fire using a fire extinguisher.

In the event of a fire, explosion, or other release that could threaten human health outside the facility, or if you know that the spill has reached surface water:Call the National Response Center at its24-hour number (800) 424-8802 and ADEQ at its 24-hour number (800) 234-5677 or (602) 771-2330. Provide the following information:

Our company name:_ _

_ _

Our address:_ _

_ _

Our U.S. EPA ID number: _

Date of accident:

Time of accident:

Type of accident (e.g., spill or fire):

Quantity of hazardous waste involved:

Extent of injuries, if any:

Estimated quantity and disposition of recovered materials, if any:


SUMMARY OF REQUIREMENTS FOR LQGS If you are a large quantity generator (LQG) [generating more than 2,200 pounds (1,000 kg), 2.2 pounds (1 kg) of acute hazardous waste, or 220 pounds (100 kg) of acute spill res-idue in any calendar month], you must comply with the full set of hazardous waste regulations. If you accumulate more than 13,228 pounds (6,000 kg) of hazardous waste, 2.2 pounds (1 kg) of acute hazardous waste or 220 pounds (100 kg) of acute spill residue, debris, or soil, you must comply with the full set of hazardous waste regulations. This table summarizes the federal and state LQG requirements. This is only a summary and does not include all of the LQG require-ments. For more details, call the EPA RCRA Hotline, ADEQ Inspections & Compliance Unit, or see 40 CFR Part 262.

LQG REQUIREMENTS SUMMARY

Hazardous waste determination (40 CFR 262.10)Generator category determination [40 CFR 262.10 (b) and 261.5 (b) & (c)]

Identify and document all hazardous wastes you generate. Measure the amount of hazardous waste you generate per calendar month to determine your generator category (e.g., LQG).

EPA ID numbers (40 CFR 262.12)

Obtain a copy of EPA Form 8700-12, fill out the form, and send it to the contact listed with the form. An EPA ID number will be returned to you for your location. See Page 7.

Prepare hazardous waste for shipment off-site (40 CFR 262.30–262.33)

Package, label, mark, and placard wastes following DOT requirements. Ship waste using hazardous waste transporter.

The manifest (40 CFR 262.20–262.23, 262.42)

Ship waste to a hazardous waste treatment, storage, disposal, or recycling facility. Ship hazardous waste off-site using the manifest system (EPA Form 8700-22) or state equivalent. Send copy to ADEQ.

Managing hazardous waste on-site (40 CFR 262.34)

Accumulate waste for no more than 90 days without a permit. Accumulate waste in: Containers / drip pads / tanks / containment buildings, and comply with specified technical standards for each unit type. Comply with preparedness and prevention requirements. Prepare written contingency plan. Train employees in hazardous waste management and emergency response.

Recordkeeping, registration, fees, andannual report(40 CFR 262.40–262.41) Arizona requires an annual report

Retain specified records for three years. Register with ADEQ and pay annual fee of $300. Arizona requires a hazardous waste generation fee of $67.50 for each ton generated, beginning at 1 ton and prorated per additional ton. LQGs are invoiced quarterly. Submit annual reports by March 1 of each year covering generator activities for the previous year.

Comply with land disposal restrictions (40 CFR 268)

Ensure that wastes meet treatment standards prior to land disposal. Send notifications and certifications to TSDF as required. Maintain waste analysis plan if treating on-site.

Export/import requirements(40 CFR 262 Subparts E & F)

Ensure that wastes meet treatment standards prior to land disposal. Send notifications and certifications to TSDF as required. Maintain waste analysis plan if treating on-site.

Registration = $300 annuallyHazardous waste generation = $67.50 per ton (prorated)

Submit annual reports by March 1 of each year covering generator activities for the previous year

LQG FEES


POLLUTION PREVENTION (P2)

Pollution Prevention (P2) is defined as “source reduction” under EPA’s

P2 Act that was established in 1990. Source reduction refers to practices that reduce the amount of hazardous sub-stance, pollutant, or contami-

nant entering any waste stream or otherwise released into the

environment prior to recycling, treatment, or disposal and reduces

hazards to the public health and the environment associ-ated with the releases of such substances. Arizona’s state P2 policy was adopted in 1991 and includes recycling of wastes or secondary material and reuse as well as activi-ties such as modifying production processes to eliminate or substitute less toxic substances, implementing conser-vative techniques and reusing materials in lieu of placing them into the waste streams. P2 STATUTEThe Arizona P2 Plan Program can be found in the Arizona Revised Statutes (A.R.S.) § 49-961 through 973.

REQUIRED FILING THRESHOLDSA person who owns or operates a facility that meets the reporting requirements prescribed by A.R.S. § 49-962 shall prepare and implement a P2 plan that addresses a reduc-tion in the use of toxic substances and the generation of hazardous wastes. [Ref: A.R.S. § 49-963.A] A P2 Plan shall be prepared and implemented if any one of the following thresholds is met:

• During the preceding calendar year, the owner or op-erator was required to file an annual toxic chemical re-lease (EPA Toxic Release Inventory (TRI)) form (Form A or Form R) for the facility. [Ref: A.R.S. § 49-962.1]

• During the preceding calendar year, the facility gen-erated an average of 2.2 pounds (1 kg) per month of acute hazardous waste or an average of 2,200 pounds (1000 kg) per month of hazardous waste in a calendar year, exclusive of an episodic, accidental or reme-diation related release or occurrence. [Ref: A.R.S. § 49-962.2]

• A facility that uses in excess of ten thousand pounds in a calendar year of a toxic substance as defined in A.R.S. § 49-961 shall file a P2 plan by December 31 of the following year. [Ref: A.R.S. § 49-963.D]

• Please visit the U.S. EPA: Toxics Release Inventory (TRI) site for a list of toxic substances (chemicals and chemical categories) at: http://www2.epa.gov/tox-ics-release-inventory-tri-program/tri-listed-chemicals.

EXEMPTIONS TO THE P2 PLANIf any of the following exemptions are met, a P2 Plan is not required, even if the facility meets the threshold require-ments. The department welcomes voluntary submittal of a P2 Plan.

• The facility is located on tribal land.• The facility is a household hazardous waste collection

facility.• The facility is primarily engaged in receiving waste

from off-site and has a permit or plan approved under A.R.S. § 49 for storing, treating or disposing of solid, special, or hazardous waste.

• All of the toxic substances used are for metallurgical or mining purposes (smelting, refining) per A.R.S. § 27-901.9.

• The facility is required to file solely due to the storage, supply, application or use of a pesticide as defined in A.R.S. § 3-361 for agricultural application and is subject to the pesticide reporting or record keeping requirements, pursuant to A.R.S. §49-305 or rules adopted pursuant to A.R.S. § 3-363.

• The facility’s industry is issued an agricultural general permit pursuant to A.R.S. § 49-947.

• The facility caused a one-time, unexpected, event that generates a hazardous waste or an acute hazardous waste from an unused hazardous substance and;

3The unused hazardous substance cannot be lawfully used due to changes in statute, or rule and; 3A toxic data report has been filed for the event as prescribed in A.R.S. § 49-962 and; 3The toxic data report is required solely as a result of the one-time generation event.

ADEQ’s Pollution Prevention Analysis and Plan Guidance Manual and editable plan forms can be downloaded at: http://www.azdeq.gov/function/forms/appswaste.html#p2

ADEQ staff can assist you with completing a P2 Plan, P2 Plan amendments, and/or annual progress reports; identi-fying P2 opportunities; or answering questions about the requirements. To contact the P2 Program, call (800)234-5677 or visit ADEQ’s P2 Website at http://www.azdeq.gov/environ/waste/p2/index.html.


ARE YOU SURE?

• Have you done a hazardous waste determination?

• Have you kept the records of test results, waste analysis, or other determination?

• Have you marked your containers of hazardous waste with the words "HAZARDOUS WASTE?"

• Have you included the accumulation start date?

• Do you keep your containers closed at all times, except when adding or removing waste?

• Are you operating and maintaining your facility in a manner to minimize the possibility of hazards through abatement of potential fire, explosions, safety hazards, and potential releases?

• Are you providing adequate maintenance and repair of your equipment and structures so you are in compliance with state and local fire, electrical and building codes, and safety codes?

• Are you controlling, containing, cleaning up, and properly disposing any and all releases of hazardous waste?

• Have you developed a contingency plan or are you maintaining and posting the required emergency contact information next to your telephone?

• Are you filing your annual report and paying your registration and generation fees?

The above are issues that inspectors typi-cally find when conducting facility inspec-tions—don’t be caught in violation.

CAN YOU USE THE UNIVERSAL WASTE RULE?

Do you have hazardous wastes that can be managed under the universal waste rule? Items such as waste batteries, certain hazardous waste pesticides, mercury-containing thermostats, and mercury- containing waste lamps fall under the universal waste regulations.

Small and large businesses that generate hazardous waste that are in the universal waste categories listed above can use the more streamlined requirements under the univer-sal waste rule. It eases the regulatory burden on business-es that generate these wastes. Specifically, it has stream-lined requirements for: notification, labeling, marking, prohibitions, accumulation time limits, employee training, response to releases, off-site shipments, tracking, exports, and transportation.

For example, the rule extends the amount of time that businesses can accumulate these materials on site allowing storage for up to 1 year from the accumulation start date. It also allows companies to transport them with a common carrier, instead of a hazardous waste transporter, and no longer requires companies to obtain a hazardous waste manifest.

For additional assistance, contact the ADEQ Hazardous Waste Inspections & Compliance Unit at (800) 234-5677.

FINAL TIPS


DEFINITIONSAccumulate – To generate and store an amount of hazardous waste over a period of time. A generator may accumulate hazard-ous waste for a short period of time before shipping it off-site. The waste must be accumulated in either tanks or containers; it may not be accumulated in surface impoundments.

Acute Hazardous Waste – Waste that is listed and even when managed properly is extremely dangerous. Any hazardous waste with an EPA waste code beginning with the letter "P" or any of the following "F" codes: F020, F021, F022, F023, F026, and F027.

By-product – A material that is not one of the primary products of a production process. Examples of by-products are process residues, such as slags or distillation column bottoms.

Commercial Chemical Product – A chemical substance that is manufactured or formulated for commercial or manufacturing use.

Container – Any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled.

Elementary Neutralization Unit – A tank, tank system, contain-er, transport vehicle, or vessel (including ships) that is designed to contain and neutralize corrosive waste.

Management, Hazardous Waste – Systematic control of the collection, source separation, storage, transportation, processing, treatment, recovery, or disposal of hazardous waste.

Manifest, Uniform Hazardous Waste – The “cradle-to-grave” paperwork must accompany a shipment of hazardous waste as it moves from the generator to the transporter and eventually to the hazardous waste management facility.

Reclaimed Material – Material that is regenerated or processed to recover a usable product. Examples are the recovery of lead values from spent batteries and the regeneration of spent solvents.

Recovered Material – A material or by-product that has been re-covered or diverted from solid waste. Does not include materials or by-products generated from, and commonly used within, an original manufacturing process.

Recycled Material – A material that is used, reused, or reclaimed.

Reused Material – A material that is employed as an ingredient in an industrial process to make a product, or as an effective sub-stitute for a commercial product.

Spent Material – Any material that has been used and, as a result of contamination, can no longer serve the purpose for which it was produced without first processing it.

Sludge – Any solid, semi-solid, or liquid waste generated from a municipal, commercial, or industrial wastewater treatment plant, water supply treatment plant, or air pollution control facility, ex-clusive of the treated effluent from a wastewater treatment plant.

Still Bottom – Residue or by-product of a distillation process, such as solvent recycling.

Tank – A stationary device designed to contain an accumulation of hazardous waste that is constructed primarily of nonearthen materials (e.g., wood, concrete, steel, plastic).

Totally Enclosed Treatment Facility – A facility for the treat-ment of hazardous waste that is directly connected to an industri-al production process and that is constructed and operated so as to prevent the release of hazardous waste into the environment during treatment. An example is a pipe in which waste acid is neutralized.

Toxicity Characteristic Leaching Procedure (TCLP) – A testing procedure used to determine whether a waste is hazardous. The procedure identifies waste that might leach hazardous constitu-ents into groundwater if improperly managed.

Treatment, Hazardous Waste – Any method, technique, or pro-cess, including neutralization, designed to change the physical, chemical, or biological character or composition of any hazardous waste so as to neutralize such hazardous waste, or so as to render such hazardous waste nonhazardous/less hazardous, or so as to recovery energy or material resources from the hazardous waste; safer to transport, store or dispose of; or amenable for recovery, amenable to storage, or reduced in volume.

Universal Waste – Any of the following hazardous wastes that are managed under the universal waste requirements of 40 CFR Part 273: batteries, pesticides, mercury-containing equipment, and lamps. Some States may have State-specific universal wastes defined as well.

Waste Code, Hazardous Waste – The number (or code) assigned by the EPA to each hazardous waste listed in 40 CFR Part 261, Subpart D and to each characteristic identified in 40 CFR Part 261, Subpart C. The codes consist of one letter (D, F, P, U, or K) and three numbers.

Waste Minimization – The reduction, to the extent feasible, of hazardous waste that is generated or subsequently treated, stored, or disposed. It includes any source reduction or recy-cling activity undertaken by a generator that results in: (1) the reduction of total volume or quantity of hazardous waste; (2) the reduction of toxicity of hazardous waste; or (3) both, as long as the reduction is consistent with the goal of minimizing present and future threats to human health and the environment.

Wastewater Treatment Unit – A tank or tank system that is sub-ject to regulation under either Section 402 or 307(b) of the Clean Water Act, and that treats or stores an influent wastewater that is hazardous waste, or that treats or stores a wastewater treatment sludge that is hazardous.


WHERE TO GET MORE HELP

Your business may also be regulated by other sections of the Code of Federal Regulations (CFR). You may want to investigate the following CFRs:

• Handling PCBs (40 CFR Part 761)

• Toxic Release Inventory (TRI) Reporting (40 CFR Part 372)

• Domestic Sewage Waste Disposal Reporting (40 CFR Part 403)

• Shipping Hazardous Materials/DOT Regulations (49 CFR Parts 171-180)

STATE HAZARDOUS WASTE MANAGEMENT ASSISTANCE

For information regarding outreach events or further assis-tance in understanding the hazardous waste rules applica-ble to you, or your compliance with them, contact:

Hazardous WasteInspections & Compliance UnitArizona Dept. of Environmental Quality1110 W. Washington St. Phoenix, AZ 85007(800) 234-5677

For information regarding outreach events or further as-sistance with understanding ADEQ’s Pollution Prevention Program, contact:

Pollution Prevention Program Arizona Dept. of Environmental Quality1110 W. Washington St. Phoenix, AZ 85007(800) 234-5677

To obtain the regulations, statutes, and rules referred to in this publication, contact the following or check out the websites listed.

Code of Federal Regulations:Contact the Government Printing Office, (202) 512-1800; www.ecfr.gov

Arizona Revised Statues: Contact the Arizona State Bar Association, (602) 252-4804;http:// www.azleg.state.az.us/ars/49/title49.htm

Arizona Administrative Code (AAC):Contact the Secretary of State, (602) 542-4086,http:// www.sos.state.az.us/public_services/ Table_of_contents.htm

EPA AND OTHER FEDERAL RESOURCE CENTERS

EPA Region 9/Hazardous Waste Management Division75 Hawthorne StreetSan Francisco, CA 94105Phone: (415) 947-8708Library: (415) 744-1510 www.epa.gov/region09/

RCRA/Superfund/LUST Hotline1725 Jefferson Davis HighwayArlington, VA 22202Phone: (800) 424-9346 or TDD (800) 553-7672Fax: (703) 486-3333Answers questions on matters related to solid waste, hazard-ous waste, and underground storage tanks. Also can be used to find and order EPA publications.

Small Business Ombudsman Clearinghouse/HotlineU.S. EPA/Small Business Ombudsman (1230C)401 M Street SW Washington, DC 20460Phone: (800) 368-5888Fax: (703) 305-6462Helps private citizens, small businesses, and smaller commu-nities with questions on all program aspects within EPA.

Pollution Prevention Information Clearinghouse (PPIC) PPIC-EPA401 M Street SW (3404) Washington, DC 20460Phone: (202) 566-0799Fax: (202) 566-0794E-mail: [email protected] a library and an electronic bulletin board (accessi-ble by any PC equipped with a modem) dedicated to infor-mation on pollution prevention.


APPENDIX A: FORMS/STATEMENTS

HAZARDOUS WASTE FACILITY REGISTRATION FORMS & FACILITY ANNUAL REPORT (FAR)

Registration Forms are mailed annually to CESQGs with EPA ID numbers, SQGs, LQGs, TSDFs, resource recovery facilities, and transporters. It will cover your registration for the current year, but is based on the highest amount of hazardous waste you generated in any one month of the previous year. This form acts as the Facility Annual Report (FAR) for CESQGs and SQGs. LQGs must submit a separate form, EPA Form 8700-13 Hazardous Waste Report, to ADEQ as the FAR and must report their hazardous waste activities through EPA’s electronic software. These forms are due by March 1 of each year.

GENERATION FORMS Generation Forms are mailed to SQGs annually and to LQGs quarterly. It covers the amount of hazardous waste you generated in the pre-ceding year for SQGs or the preceding three months for LQGs.


APPENDIX A: FORMS/STATEMENTS (Cont.)

REGISTRATION/GENERATION FEE STATEMENTS

Once completed Registration & Generation Forms are received, ADEQ will generate and mail a statement to the owner or operator of the facility. The total amount due could include other fees owed to ADEQ and should be paid by the Payment Due Date, or the bal-ance will be subject to interest.


APPENDIX A: FORMS/STATEMENTS (Cont.)

REGISTRATION/GENERATION FEE INVOICES

Managing Hazardous Waste Handbook34ADEQ / MANAGING HAZARDOUS WASTE 5

WORKSHEET 3

These questions are geared toward the federal requirements for SQGs but may be helpful for other hazardous waste generators. Use them to help prepare for a visit from a federal, state, or local agency.YES NO❐ ❐ 1. Do you have documentation on the amount and kinds of hazardous waste

that you generate and how you determined that they are hazardous?

❐ ❐ 2. Do you have a U.S. EPA ID number?

❐ ❐ 3. Do you ship wastes off-site?

❐ ❐ 4. If so, do you know the names of the transporter and the designated TSDFthat you use?

❐ ❐ 5. Do you have copies of completed manifests used to ship your hazardouswastes over the past three years? Have you sent copies with all threesignatures to ADEQ?

❐ ❐ 6. Are the manifests filled out correctly?

❐ ❐ 7. Have the manifests been signed by the designated TSDF and transporter?

❐ ❐ 8. If you have not received your signed copy of the manifest from the TSDF,have you filed an exception report?

❐ ❐ 9. Is your hazardous waste stored in proper containers or tanks?

❐ ❐ 10. Are the containers or tanks properly dated and/or marked?

❐ ❐ 11. Have you complied with the management requirements described in this document?

❐ ❐ 12. Have you designated an emergency coordinator?

❐ ❐ 13. Have you posted emergency telephone numbers and the location ofemergency equipment? Is your Emergency Coordinator's name correct?

❐ ❐ 14. Are your employees thoroughly familiar with proper waste handling andemergency procedures?

❐ ❐ 15. Do you understand when you need to contact the National ResponseCenter and ADEQ?

❐ ❐ 16. Do you store your waste for no more than 180 days, or 270 days if youship your waste more than 200 miles?

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APPENDIX B: HAZARDOUS WASTE GENERATORS CHECKLIST

www.azdeq.gov Revised: September 2014

Publication Number: TM-03-01

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