copyright 2004, heritage environmental services, llc – all rights reserved heritage university...

Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved

Heritage UniversityRCRA REVIEW TRAINING

Conducted by:Alfred A. Capuano, Ed.D.,CET

Vice President, Safety & Training


EPA and OSHA

EPA rules are designed to protect human EPA rules are designed to protect human health and the environment, focusing on off-health and the environment, focusing on off-site receptors (env. media and the public) site receptors (env. media and the public) rather than employeesrather than employees

Little consideration of OSHA standards, and Little consideration of OSHA standards, and no cross references to OSHA standardsno cross references to OSHA standards

More coordination between DOT rules and More coordination between DOT rules and EPA rules in the establishment of RCRA regsEPA rules in the establishment of RCRA regs

Bottom Line: Compliance with RCRA rules no Bottom Line: Compliance with RCRA rules no assurance of compliance with OSHA assurance of compliance with OSHA standardsstandards


Hazardous Waste Regulatory Program Overview


Resource Conservation and Recovery Act Resource Conservation and Recovery Act of 1976 (RCRA), As Amended of 1976 (RCRA), As Amended

Waste Inventory/Hazardous Waste Waste Inventory/Hazardous Waste Determination/ Determination of Determination/ Determination of Regulatory Status Regulatory Status

Notification - EPA Identification Numbers Notification - EPA Identification Numbers for Generators, Transporters, and TSD for Generators, Transporters, and TSD FacilitiesFacilities




Permits for Treatment, Storage, and Permits for Treatment, Storage, and Disposal (TSD) Facilities (Permits Disposal (TSD) Facilities (Permits NotNot Required for 90 Day Accumulation in Required for 90 Day Accumulation in Containers/tanks)Containers/tanks)

Standards for Generators, Transporters, Standards for Generators, Transporters, and TSD Facilitiesand TSD Facilities

Treatment Standards for Wastes Before Treatment Standards for Wastes Before Land Disposal, and Minimum Technology Land Disposal, and Minimum Technology Requirements for Land Disposal FacilitiesRequirements for Land Disposal Facilities



Use of manifest for transportationUse of manifest for transportation State regulatory programs - State regulatory programs -

authorizationauthorization Inspections and enforcementInspections and enforcement Requirements for clean-up and Requirements for clean-up and

ultimate responsibility of generator ultimate responsibility of generator for disposition and environmental for disposition and environmental impact of waste -"Cradle to Grave"impact of waste -"Cradle to Grave"


Basic Requirements of Hazardous Waste Generators


Basic Determinations

Questions to be asked and answered on Questions to be asked and answered on an on-going basis.an on-going basis.

Identify Wastestreams (What are all Identify Wastestreams (What are all the wastes at the facility?)the wastes at the facility?)

Hazardous Waste Determination Hazardous Waste Determination (Which of these wastes are hazardous, (Which of these wastes are hazardous, using the regulatory definitions?)using the regulatory definitions?)

Determination of Regulatory Categories Determination of Regulatory Categories (How much and what is done on-site?)(How much and what is done on-site?)


Containers Must Be . . . Containers Must Be . . . In Good ConditionIn Good Condition Compatible With the WasteCompatible With the Waste Labeled or Marked Clearly With the Labeled or Marked Clearly With the

Words "Hazardous Waste"Words "Hazardous Waste" Marked With the Accumulation Start Marked With the Accumulation Start

DateDate

Container Management (Performance and Prescriptive) Standards


Container Management Standards

Kept ClosedKept Closed Managed to Avoid Damage and Managed to Avoid Damage and

ReleasesReleases Incompatible Wastes Are Not to Be Incompatible Wastes Are Not to Be

Placed in the Same Container.Placed in the Same Container. Subpart CC Air Emissions Standards Subpart CC Air Emissions Standards

May ApplyMay Apply


Ignitable/reactive Wastes Must Be 50 Ft. Ignitable/reactive Wastes Must Be 50 Ft. From the Property Line*From the Property Line*

"No Smoking" Signs Must Be Posted*"No Smoking" Signs Must Be Posted* Incompatible Wastes Are to Be Incompatible Wastes Are to Be

Separated or Protected From Each OtherSeparated or Protected From Each Other Emergency Equipment Is to Be Emergency Equipment Is to Be

Available*Available* Adequate Aisle Space (2½ Feet) Is to Be Adequate Aisle Space (2½ Feet) Is to Be

Maintained*Maintained*

Container Accumulation Area Standards


Inspect Container Accumulation Inspect Container Accumulation Areas WeeklyAreas Weekly

Inspect Emergency Equipment at Inspect Emergency Equipment at Least Monthly*Least Monthly*

Shipments Are to Be Made Every 90 Shipments Are to Be Made Every 90 Days for Large Quantity GeneratorsDays for Large Quantity Generators

Shipments Are to Be Made Every 180 Shipments Are to Be Made Every 180 Days for Small Quantity GeneratorsDays for Small Quantity Generators

Container Accumulation Area Standards


Compliance Documentation

Contingency PlanContingency Plan Personnel Training Program & Personnel Training Program &

RecordsRecords InspectionsInspections Manifests and LDR FormsManifests and LDR Forms Biennial ReportsBiennial Reports Waste Analyses/DeterminationsWaste Analyses/Determinations Waste Minimization ProgramWaste Minimization Program


EPA’s Definition of Solid Waste (40 CFR 261.2)


Any Material

Disposed of or Abandoned in Lieu of Disposed of or Abandoned in Lieu of DisposalDisposal

Burned, Incinerated or RecycledBurned, Incinerated or Recycled ““Inherently Waste-like”Inherently Waste-like”


Please Note

EPA takes an “all or nothing” approach. EPA takes an “all or nothing” approach. Secondary materials are either Secondary materials are either comprehensively regulated or totally comprehensively regulated or totally unregulated, which ignores laws of unregulated, which ignores laws of chemistry and physics, making no chemistry and physics, making no allowance for severity or degree of allowance for severity or degree of hazard.hazard.

RCRA rules do not address chemical RCRA rules do not address chemical inventory issues, which are addressed inventory issues, which are addressed under EPCRA and OSHA regsunder EPCRA and OSHA regs


““Materials Which Are Not Solid Materials Which Are Not Solid Wastes” Wastes” (40 CFR 261.4(a))(40 CFR 261.4(a))

Domestic Sewage ExclusionDomestic Sewage Exclusion Point Source (NPDES) ExclusionPoint Source (NPDES) Exclusion Secondary Materials That Are Reclaimed Secondary Materials That Are Reclaimed

and Returned to the Original Process(es) and Returned to the Original Process(es) in Which They Were Generated Where in Which They Were Generated Where They Are Reused in the Production They Are Reused in the Production ProcessProcess

Exclusions


““Solid Wastes Which Are Not Solid Wastes Which Are Not Hazardous Wastes” Hazardous Wastes” (40 CFR 261.4(b))(40 CFR 261.4(b))

Household WastesHousehold Wastes Petroleum-Contaminated Media and Petroleum-Contaminated Media and

Debris (D018-D043 Only) From Debris (D018-D043 Only) From Regulated UST ReleasesRegulated UST Releases

Pertinent Exclusions


Samples (40 CFR 261.4(d))Samples (40 CFR 261.4(d)) Treatability Study Samples (40 CFR Treatability Study Samples (40 CFR

261.4(e)&(f))261.4(e)&(f)) CESQG Hazardous Wastes (40 CFR 261.5)CESQG Hazardous Wastes (40 CFR 261.5) Specified Recyclable Materials (40 CFR 261.6)Specified Recyclable Materials (40 CFR 261.6) Residues In Empty Containers (40 CFR 261.7)Residues In Empty Containers (40 CFR 261.7) PCB Wastes Exhibiting the Toxicity PCB Wastes Exhibiting the Toxicity

Characteristic (D018-D043) Regulated Under Characteristic (D018-D043) Regulated Under TSCA (40 CFR 261.8)TSCA (40 CFR 261.8)

Universal Wastes (40 CFR 261.9, Referencing Universal Wastes (40 CFR 261.9, Referencing 40 CFR Part 273)40 CFR Part 273)

Other Pertinent Exclusions


Product or Raw Material Storage Tank Product or Raw Material Storage Tank Residues; Residues in Product or Raw Residues; Residues in Product or Raw Material Transport Vehicles, Vessels Material Transport Vehicles, Vessels or Pipelines; and Residues in or Pipelines; and Residues in Manufacturing Process Units Manufacturing Process Units While While These Units Are in Service (40 CFR These Units Are in Service (40 CFR 261.4(c))261.4(c))

Other Pertinent Exclusions


Solid Waste/Hazardous Waste Determinations (40 CFR 261.3)


Solid Waste Determination

Excluded From Definition of Solid Excluded From Definition of Solid Waste (40 CFR 261.4(a) Waste (40 CFR 261.4(a) oror by Reuse by Reuse or Recycling) or Recycling)

Excluded from Definition of Hazardous Excluded from Definition of Hazardous Waste (40 CFR 261.4(b))Waste (40 CFR 261.4(b))


Hazardous Waste Determination

Listed (40 CFR 261, Subpart D)Listed (40 CFR 261, Subpart D) Mixture of Solid Waste and Listed Mixture of Solid Waste and Listed

Hazardous Waste (40 CFR 261.3(a)(2)Hazardous Waste (40 CFR 261.3(a)(2)(iv))(iv))

Solid Waste Derived from T, S, or D of Solid Waste Derived from T, S, or D of Listed Hazardous Waste (40 CFR 261.3(c)Listed Hazardous Waste (40 CFR 261.3(c)(2)(i))(2)(i))

Waste Exhibits any Characteristics of Waste Exhibits any Characteristics of Hazardous Waste (40 CFR 261, Subpart C Hazardous Waste (40 CFR 261, Subpart C - either by testing or knowledge of waste)- either by testing or knowledge of waste)


Lists of Hazardous Wastes(40 CFR Part 261, Subpart D)

Four Lists:Four Lists:

F- listF- list K- listK- list P- listP- list U-listU-list


“Hazardous Wastes from Non-Specific Sources” (40 CFR 261.31)

““F-List”F-List”


F-List (40 CFR 261.31)

Spent Solvents (F001-F005) (Not Spent Solvents (F001-F005) (Not Commercial Products or Commercial Products or Manufacturing Process Wastes) - Manufacturing Process Wastes) - “Solvent Mixture Rule”“Solvent Mixture Rule”

All spent solvent mixtures/blends All spent solvent mixtures/blends containing, containing, before usebefore use, a , a totaltotal of 10% of 10% or more (by volume) of one or more of or more (by volume) of one or more of the solvents listed in F001, F002, the solvents listed in F001, F002, F004 and F005 are now regulated.F004 and F005 are now regulated.


F-List(40 CFR 261.31)

Need to determine if F001, F002, F004 or Need to determine if F001, F002, F004 or F005 solvents are present in Trade Name F005 solvents are present in Trade Name Solvents or solvent blends.Solvents or solvent blends.

Electroplating Wastes (F006, F007, F008, Electroplating Wastes (F006, F007, F008, F009)F009)

Metal Heat-Treating Wastes (F010, F011, Metal Heat-Treating Wastes (F010, F011, F012)F012)

WWT Sludges from Chemical Conversion WWT Sludges from Chemical Conversion Coating of Aluminum (F019)Coating of Aluminum (F019)

MiscellaneousMiscellaneous


“Hazardous Wastes from Specific Sources”

(40 CFR 261.32)

““K-List”K-List”


Process Wastes from Specified Industries

Wood PreservationWood Preservation Inorganic PigmentsInorganic Pigments Organic ChemicalsOrganic Chemicals Inorganic ChemicalsInorganic Chemicals PesticidesPesticides ExplosivesExplosives



Petroleum RefiningPetroleum Refining Iron & SteelIron & Steel Primary CopperPrimary Copper Primary LeadPrimary Lead Primary ZincPrimary Zinc Primary AluminumPrimary Aluminum



FerroalloysFerroalloys Secondary LeadSecondary Lead Veterinary PharmaceuticalsVeterinary Pharmaceuticals Ink FormulationInk Formulation CokingCoking


Commercial Chemical Products Lists

Acute Hazardous (H) Waste Acute Hazardous (H) Waste (40 CFR 261.33(e)) – “P-List” (40 CFR 261.33(e)) – “P-List”

andand

Toxic (T) Wastes Toxic (T) Wastes (40 CFR 261.33(f)) – “U-List”(40 CFR 261.33(f)) – “U-List”


P-List Examples

Mostly Pesticides, Toxic Organics, Mostly Pesticides, Toxic Organics, Pure Cyanides, and Certain Heavy Pure Cyanides, and Certain Heavy Metal CompoundsMetal Compounds

Listings Include Unrinsed Listings Include Unrinsed Containers/Liners and Spill ResiduesContainers/Liners and Spill Residues

Lower Small-Quantity Generator Lower Small-Quantity Generator Exclusion (1 Kilogram/100 Kilograms Exclusion (1 Kilogram/100 Kilograms Spill Residue)Spill Residue)


Mostly Natural and Synthetic OrganicsMostly Natural and Synthetic Organics Listings Include Spill ResiduesListings Include Spill Residues

U-List


Commercial chemical product listings do not apply Commercial chemical product listings do not apply to spent materials or manufacturing process to spent materials or manufacturing process wastes containing listed chemicals. Listings apply wastes containing listed chemicals. Listings apply to technical grade chemicals or formulations to technical grade chemicals or formulations where the listed chemical is the sole active where the listed chemical is the sole active ingredient. The commercial chemical products ingredient. The commercial chemical products listings apply if and when such chemicals are listings apply if and when such chemicals are spilled, discarded or intended to be discarded. spilled, discarded or intended to be discarded. Listings should be consulted prior to disposal of Listings should be consulted prior to disposal of virgin chemical spill residues, off-specification virgin chemical spill residues, off-specification chemical products, manufacturing chemical chemical products, manufacturing chemical intermediates, obsolete chemical inventory, intermediates, obsolete chemical inventory, excess or surplus inventory, or expired chemical excess or surplus inventory, or expired chemical products.products.

Note


Characteristics of Hazardous Waste (40 CFR Part 261, Subpart C)

A focus on acute hazards, A focus on acute hazards, except for the Toxicity except for the Toxicity

CharacteristicCharacteristic


Ignitability (I) D001 (40 CFR 261.21)

Liquid, With Closed Cup Flashpoint Liquid, With Closed Cup Flashpoint <140<140FF

Nonliquid, Capable of Spontaneous Nonliquid, Capable of Spontaneous and Sustained Combustion and Sustained Combustion andand When When Ignited, Burns So Vigorously and Ignited, Burns So Vigorously and Persistently As to Create a Hazard Persistently As to Create a Hazard

DOT Oxidizers and Ignitable DOT Oxidizers and Ignitable Compressed GasesCompressed Gases


Aqueous, pH Aqueous, pH 2 or pH 2 or pH 12.5 12.5 Liquid, Corrodes SAE 1020 Steel > Liquid, Corrodes SAE 1020 Steel >

1/4" Per Year at 1301/4" Per Year at 130FF Federally, no recognition of corrosive Federally, no recognition of corrosive

solidssolids

Corrosivity (C) D002 (40 CFR 261.22)


Reactivity (R) D003 (40 CFR 261.23)

Unstable, Reacts ViolentlyUnstable, Reacts Violently Water‑reactive or Forms Potentially Water‑reactive or Forms Potentially

Explosive Mixtures With WaterExplosive Mixtures With Water Forms Toxic Gases, Vapors, or Fumes Forms Toxic Gases, Vapors, or Fumes

Endangering Health When Mixed With Endangering Health When Mixed With WaterWater

Cyanide or Sulfide Containing Waste Cyanide or Sulfide Containing Waste Which Can Generate Toxic Gases at Which Can Generate Toxic Gases at pH Conditions Between 2 and 12.pH Conditions Between 2 and 12.


EPA Guidance:EPA Guidance:

Reactive Cyanide (SW846-Reactive Cyanide (SW846-9010): 9010):

250 mg HCN/kg Waste250 mg HCN/kg Waste

Reactive Sulfide (SW846-Reactive Sulfide (SW846-9030): 9030):

500 mg H500 mg H22S/kg WasteS/kg Waste

Reactivity (R) D003


Capable of Detonation or Capable of Detonation or Explosive ReactionExplosive Reaction

DOT Explosive Divisions 1.1 to DOT Explosive Divisions 1.1 to 1.3 (Class A or B)1.3 (Class A or B)

Reactivity (R) D003


Toxicity Characteristic Leaching Toxicity Characteristic Leaching Procedure (TCLP) Extract of Procedure (TCLP) Extract of Waste Analyzed for Specified Waste Analyzed for Specified Heavy Metals and Toxic Heavy Metals and Toxic Organics. Zero Headspace Organics. Zero Headspace Extraction (ZHE) Required for Extraction (ZHE) Required for Volatile Organic Constituents.Volatile Organic Constituents.

Toxicity (E) D004-D043 (40 CFR 261.24)


TCLP Extraction Developed to TCLP Extraction Developed to Simulate Effects of Waste Simulate Effects of Waste Mismanagement Upon the Mismanagement Upon the Groundwater in a Municipal Landfill Groundwater in a Municipal Landfill Co-disposal Scenario. Regulatory Co-disposal Scenario. Regulatory Thresholds Are Derived by Multiplying Thresholds Are Derived by Multiplying the Chronic Toxicity Level (Typically the Chronic Toxicity Level (Typically MCLs) by the Dilution Attenuation MCLs) by the Dilution Attenuation Factor (DAF). DAF Is Currently Set at Factor (DAF). DAF Is Currently Set at 100.100.

Toxicity (E) D004-D043


When Does a Solid Waste Become a Hazardous Waste?


When It First Meets the Listing DescriptionWhen It First Meets the Listing Description For Mixtures, When Listed Hazardous For Mixtures, When Listed Hazardous

Waste is First Added to Solid Waste Waste is First Added to Solid Waste (“Mixture Rule” - 40 CFR 261.3(a)(2)(iv))(“Mixture Rule” - 40 CFR 261.3(a)(2)(iv))

When the Waste Exhibits Any of the When the Waste Exhibits Any of the Characteristics of Hazardous WasteCharacteristics of Hazardous Waste

Note:Note: Point of Generation to be Used for Point of Generation to be Used for Regulatory Purposes (before aggregation / Regulatory Purposes (before aggregation / consolidation or treatment)consolidation or treatment)

A Waste Becomes Hazardous….


SludgesSludges Treatment Residues Treatment Residues Spill ResiduesSpill Residues AshAsh Air Emission Control Sludge/DustAir Emission Control Sludge/Dust LeachateLeachate(“Derived From” Rule - 40 CFR (“Derived From” Rule - 40 CFR

261.3(c)(2))261.3(c)(2))

Residues from Treatment, Storage, or Disposal of Listed Hazardous Waste


Regulatory Categories



Conditionally-Exempt Generator or CEG Conditionally-Exempt Generator or CEG (<100 Kg/Mo)(<100 Kg/Mo)

Small Quantity Generator or SQG (100 - Small Quantity Generator or SQG (100 - 1000 Kg/Mo)1000 Kg/Mo)

Generator Who Accumulates On-Site in Generator Who Accumulates On-Site in Containers or Tanks for Less Than 90 Containers or Tanks for Less Than 90 Days (Large Quantity Generator or Days (Large Quantity Generator or LQG)LQG)

Note: These Categories are Mutually Note: These Categories are Mutually Exclusive at Any One Point In Time.Exclusive at Any One Point In Time.



Generator/Shipper (to Off-site TSD)Generator/Shipper (to Off-site TSD) Used Oil Generators, Transporters, Used Oil Generators, Transporters,

Processors/re-refiners, Burners and Processors/re-refiners, Burners and MarketersMarketers

Owner/Operator of Underground Owner/Operator of Underground Petroleum Or Hazardous Substance Petroleum Or Hazardous Substance Storage TankStorage Tank

Commercial TSD FacilityCommercial TSD Facility


Standards For Generators(40 CFR 262)


Accumulation Time(40 CFR 262.34)

Use and Management of Containers Use and Management of Containers (40 CFR 265‑Subpart I and Subparts (40 CFR 265‑Subpart I and Subparts AA, BB, and CC as Applicable)AA, BB, and CC as Applicable)

Tank Systems (40 CFR 265‑Subpart J, Tank Systems (40 CFR 265‑Subpart J, Except 265.197(c) and 265.200 and Except 265.197(c) and 265.200 and Subparts AA, BB, and CC as Subparts AA, BB, and CC as Applicable)Applicable)

Containment Buildings (40 CFR 265 - Containment Buildings (40 CFR 265 - Subpart DD)Subpart DD)


Accumulation Time

Accumulation Start Date Marking (90 Accumulation Start Date Marking (90 Day Limit ‑30 Day Extension Possible)Day Limit ‑30 Day Extension Possible)

‑‑ Satellite Accumulation (40 CFR Satellite Accumulation (40 CFR 262.34(c)) 262.34(c))

(Excess Accumulation Date Starts 90 (Excess Accumulation Date Starts 90 Day Period)Day Period)

Hazardous Waste Marking/LabelingHazardous Waste Marking/Labeling


Accumulation Time

Preparedness and Prevention (40 CFR Preparedness and Prevention (40 CFR 265‑Subpart C)265‑Subpart C)

Contingency Plan and Emergency Contingency Plan and Emergency Procedures (40 CFR 265‑Subpart D)Procedures (40 CFR 265‑Subpart D)

Personnel Training (40 CFR 265.16)Personnel Training (40 CFR 265.16)


Accumulation Time

Closure Performance Standards (40 Closure Performance Standards (40 CFR 265.111 and 265.114)CFR 265.111 and 265.114)

-- Control of Post-Closure Control of Post-Closure ReleasesReleases

-- Removal and Proper Disposal Removal and Proper Disposal of All Hazardous Wastes, of All Hazardous Wastes, Residues and Contaminated Residues and Contaminated SoilSoil


Note

Satellite Accumulation Provisions at Satellite Accumulation Provisions at 40 CFR 262.34(c).40 CFR 262.34(c).

Small Quantity Generator Provisions Small Quantity Generator Provisions at 40 CFR 262.34(d).at 40 CFR 262.34(d).


Preparedness and Prevention(40 CFR Part 265, Subpart C)


Preparedness and Prevention

Maintain and Operate the Facility So As to Maintain and Operate the Facility So As to Minimize the Possibility of Fire, Explosion or Minimize the Possibility of Fire, Explosion or Unplanned Release (265.31)Unplanned Release (265.31)

Provision of Certain Required Equipment Provision of Certain Required Equipment (265.32) :(265.32) : Internal Communications or alarm systemInternal Communications or alarm system Telephone or two-way radioTelephone or two-way radio Portable fire extinguishers, fire control Portable fire extinguishers, fire control

equipment, spill control and equipment, spill control and decontamination equipmentdecontamination equipment

Water at adequate volume and pressureWater at adequate volume and pressure



Testing and Maintenance of Testing and Maintenance of Equipment (265.33)Equipment (265.33)

Aisle Space Required to Allow Aisle Space Required to Allow Emergency Response (265.35)Emergency Response (265.35)



Arrangements With Local Authorities Must Arrangements With Local Authorities Must be Attempted, as Appropriate(265.37):be Attempted, as Appropriate(265.37): Police, Fire, and Emergency Response Police, Fire, and Emergency Response

TeamsTeams Agreements Designating Primary Fire and Agreements Designating Primary Fire and

Police AuthoritiesPolice Authorities Agreements With State Emergency Agreements With State Emergency

Response Teams, Emergency Response Response Teams, Emergency Response Contractors, and Equipment SuppliersContractors, and Equipment Suppliers

Local HospitalsLocal Hospitals


Contingency Plans(40 CFR Part 265, Subpart D)


Contents

Actions of Facility Personnel in Actions of Facility Personnel in Response to HW EmergenciesResponse to HW Emergencies

Arrangements Made With Local Arrangements Made With Local AuthoritiesAuthorities

List of Emergency CoordinatorsList of Emergency Coordinators Emergency Equipment ListEmergency Equipment List Evacuation PlanEvacuation Plan


Personnel Training(40 CFR 265.16)


Personnel Training

Who Gets Trained?Who Gets Trained? What Should the Training Consist of What Should the Training Consist of

and Accomplish?and Accomplish? Who Performs the Training?Who Performs the Training? How Often Is Training Performed?How Often Is Training Performed? What Constitutes Appropriate What Constitutes Appropriate

Documentation?Documentation?


Note

Compliance With RCRA HWM Training Compliance With RCRA HWM Training Requirements Is Not Adequate Requirements Is Not Adequate Training for OSHA Hazard Training for OSHA Hazard Communication Standard or DOT Communication Standard or DOT Subpart H, 49CFR 172.700 Subpart H, 49CFR 172.700 Compliance, and May Not Be Compliance, and May Not Be Adequate for Compliance With the Adequate for Compliance With the OSHA Hazardous Waste and OSHA Hazardous Waste and Emergency Response Operations Emergency Response Operations Standard.Standard.


Requirements for 100-1000 Kg/Month Small Quantity Generators

(40 CFR 262.34(d))


Requirements

Notify and Obtain U.S. EPA ID NumberNotify and Obtain U.S. EPA ID Number Accumulate No More Than 6,000 Kg Accumulate No More Than 6,000 Kg

On-Site for Up to 180 Days (270 Days On-Site for Up to 180 Days (270 Days If TSD Over 200 Miles Away)If TSD Over 200 Miles Away)

Mark Each Container With the Words Mark Each Container With the Words “Hazardous Waste” and Accumulation “Hazardous Waste” and Accumulation Start DateStart Date


Requirements

Follow Container or Tank Follow Container or Tank Accumulation Requirements Accumulation Requirements

Preparedness and Prevention Preparedness and Prevention RequirementsRequirements

Emergency Planning and Notification Emergency Planning and Notification of Releasesof Releases


Requirements

Utilize Planning and Notification of Utilize Planning and Notification of ReleasesReleases

Follow DOT Requirements Re: Follow DOT Requirements Re: Packaging, Labeling and MarkingPackaging, Labeling and Marking

Use Uniform Hazardous Waste Use Uniform Hazardous Waste ManifestManifest

Limited Exception Reporting Limited Exception Reporting Requirements if Return Copy Not Requirements if Return Copy Not Received Within 60 Days of ShipmentReceived Within 60 Days of Shipment


Satellite Accumulation(40 CFR 262.34(c))


Satellite Accumulation Points

Areas “At or Near Any Point of Areas “At or Near Any Point of Generation Where Wastes Initially Generation Where Wastes Initially Accumulate, Which Is Under the Control Accumulate, Which Is Under the Control of the Operator of the Process of the Operator of the Process Generating the Waste".Generating the Waste".

Satellite Accumulation Points Are Not Satellite Accumulation Points Are Not Subject to the 90-day Accumulation Subject to the 90-day Accumulation Standards That Apply to Central Standards That Apply to Central Accumulation/Storage Areas.Accumulation/Storage Areas.


Satellite Requirements

Wastes Must Be Placed in Containers Wastes Must Be Placed in Containers That Are in Good Condition.That Are in Good Condition.

Wastes Must Be Compatible With the Wastes Must Be Compatible With the Containers.Containers.

Containers Must Always Be Closed, Containers Must Always Be Closed, Unless Wastes Are Being Added or Unless Wastes Are Being Added or Removed.Removed.


Satellite Requirements

Containers Must Be Marked With the Containers Must Be Marked With the Accumulation Start Date When "Excess Accumulation Start Date When "Excess Accumulation" Begins (When the Accumulation" Begins (When the Container Is Filled to Capacity).Container Is Filled to Capacity).

Full Containers Must Be Moved to 90-day Full Containers Must Be Moved to 90-day Accumulation Area Within 3 Days After Accumulation Area Within 3 Days After Being Filled to Capacity.Being Filled to Capacity.


A Practical Approach to Land Disposal Restrictions (40 CFR 268)


General Outline

Land Disposal Restrictions (LDR) are Land Disposal Restrictions (LDR) are found at 40 CFR Part 268. found at 40 CFR Part 268.

LDR regulations developed to reduce LDR regulations developed to reduce the toxicity and/or mobility of the toxicity and/or mobility of hazardous waste constituents that are hazardous waste constituents that are land disposed.land disposed.

Majority of hazardous wastes do not Majority of hazardous wastes do not meet treatment standards as meet treatment standards as generatedgenerated


General Outline

Hazardous wastes must meet LDR Hazardous wastes must meet LDR treatment standards before they can treatment standards before they can be land disposed. Treatment be land disposed. Treatment standards are based on Best standards are based on Best Demonstrated Available Technology, Demonstrated Available Technology, or BDAT. Technology-based rather or BDAT. Technology-based rather than health- or risk-based. LDR than health- or risk-based. LDR treatment standards attach at the treatment standards attach at the point of point of initialinitial generation. generation.


General Outline

Definition of "wastewater" under LDR Definition of "wastewater" under LDR regulations is a waste that contains regulations is a waste that contains less than 1% total suspended solids less than 1% total suspended solids andand less than 1% total organic less than 1% total organic carbon.carbon.

Subcategories further categorize Subcategories further categorize certain hazardous wastes. Not all certain hazardous wastes. Not all waste codes have subcategories.waste codes have subcategories.


General Outline

Three types of treatment standardsThree types of treatment standards:: Total Waste Standards (totals analysis);Total Waste Standards (totals analysis); Waste Extract Standards (TCLP Waste Extract Standards (TCLP

analysis); oranalysis); or Specified Technology Standards Specified Technology Standards

(specify a treatment technology by five (specify a treatment technology by five letter code, rather than constituent letter code, rather than constituent concentration).concentration).


General Outline

Concentration-based Universal Concentration-based Universal Treatment Standards (UTS) specify a Treatment Standards (UTS) specify a single numerical treatment standard single numerical treatment standard for each organic, metal and cyanide for each organic, metal and cyanide constituent, regardless of the type of constituent, regardless of the type of waste, that must be met prior to land waste, that must be met prior to land disposal.disposal.


General Outline

There is One Table at 40 CFR 268.40 There is One Table at 40 CFR 268.40 That Specifies All Treatment Standards That Specifies All Treatment Standards for the Various Hazardous Wastesfor the Various Hazardous Wastes Waste Code, Description/Subcategory, Waste Code, Description/Subcategory,

Regulated Hazardous Constituents, Regulated Hazardous Constituents, and Wastewater/Non-Wastewater and Wastewater/Non-Wastewater Treatment StandardsTreatment Standards

One Treatment Standard for One Treatment Standard for Wastewater and One for Non-Wastewater and One for Non-Wastewater for Each Waste CodeWastewater for Each Waste Code


Generator Requirements


Eight Elements for LDR Compliance

Determine, at the Point of Generation, Determine, at the Point of Generation, All Applicable Codes, the Category All Applicable Codes, the Category (WW or Non-WW), and the (WW or Non-WW), and the Subcategory (If Any) for Each Subcategory (If Any) for Each Restricted Waste.Restricted Waste.

Determine Which Treatment Determine Which Treatment Standard(s) Apply to Each Restricted Standard(s) Apply to Each Restricted WasteWaste



Identify Underlying Hazardous Identify Underlying Hazardous Constituents (Where Required).Constituents (Where Required).

Determine, Through Specified Determine, Through Specified Analytical Techniques or Knowledge Analytical Techniques or Knowledge of the Waste, Whether the Treatment of the Waste, Whether the Treatment Standard Has Been Achieved.Standard Has Been Achieved.

Comply With Time Limitations.Comply With Time Limitations.



Comply with prohibitions on evaporation Comply with prohibitions on evaporation and dilution.and dilution.

Prepare notifications and/or Prepare notifications and/or certifications required for onsite or certifications required for onsite or offsite waste management.offsite waste management.

Comply with recordkeeping Comply with recordkeeping requirements to maintain all LDR requirements to maintain all LDR documentation.documentation.


EPA/DOT Regulatory Requirements


Select Appropriate Shipping Select Appropriate Shipping Description and Determine If RQ Is Description and Determine If RQ Is Being Shipped in a Single ContainerBeing Shipped in a Single Container

Perform LDR determinations Perform LDR determinations Comply With DOT Requirements for Comply With DOT Requirements for

Packaging, Labeling and MarkingPackaging, Labeling and Marking

Generators Shipping Hazardous Wastes Off-Site


Verify That Transporter and Verify That Transporter and Designated TSD Facility Have Valid Designated TSD Facility Have Valid EPA Identification Numbers and EPA Identification Numbers and Relevant PermitsRelevant Permits



Prepare a Uniform Hazardous Waste Prepare a Uniform Hazardous Waste Manifest (EPA Form 8700-22), Utilizing Manifest (EPA Form 8700-22), Utilizing Appropriate Form per Acquisition Appropriate Form per Acquisition Hierarchy. Prepare the Appropriate Hierarchy. Prepare the Appropriate Notice(s) for Restricted Waste Notice(s) for Restricted Waste Shipments to Treatment Facilities. Shipments to Treatment Facilities. Prepare the Appropriate Certification(s) Prepare the Appropriate Certification(s) for Restricted Waste Shipments to Land for Restricted Waste Shipments to Land Disposal Facilities.Disposal Facilities.



Offer the Transporter Appropriate Placards.Offer the Transporter Appropriate Placards. Sign and Date Manifest, Certifying Sign and Date Manifest, Certifying

Shipment Meets EPA and DOT Pre-Shipment Meets EPA and DOT Pre-transportation Requirements. Signature transportation Requirements. Signature also Certifies that a Waste Minimization also Certifies that a Waste Minimization Program is in Place, and that the Method of Program is in Place, and that the Method of T, S, or D Selected is Environmentally T, S, or D Selected is Environmentally Appropriate.Appropriate.



Obtain Signature of Transporter and Obtain Signature of Transporter and Date of AcceptanceDate of Acceptance

Retain One Copy of the Signed Retain One Copy of the Signed Manifest and Give the Remaining Manifest and Give the Remaining Copies to the TransporterCopies to the Transporter



Monitor the Manifest Tracking System.Monitor the Manifest Tracking System. Submit Exception Reports, as Submit Exception Reports, as

Appropriate.Appropriate. Prepare and Submit Biennial Reports Prepare and Submit Biennial Reports

Including a Description of Waste Including a Description of Waste Minimization Efforts and Achievements.Minimization Efforts and Achievements.

Keep Copies of Manifests, Land Disposal Keep Copies of Manifests, Land Disposal Restriction Notices/ Certifications, Restriction Notices/ Certifications, Biennial Reports, Any Exception Reports, Biennial Reports, Any Exception Reports, and Waste Analyses/Determinations.and Waste Analyses/Determinations.


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