managing hazardous waste€¦ · ing the hazardous waste rules—a handbook for small business....

ADEQ / MANAGING HAZARDOUS WASTE 1

A HANDBOOK

FOR SMALL BUSINESSES

MANAGING

HAZARDOUS WASTE

ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY

2 MANAGING HAZARDOUS WASTE / ADEQ

CONTENTS

INTRODUCTION .......................................................................................................... 1

DECIDING WHETHER HAZARDOUS WASTE REGULATIONS APPLY TO YOU ............................... 2Defining Hazardous Waste ................................................................... 2Identifying Your Waste: Typical Hazardous Wastes Generated by Businesses .... 3Finding Your Generator Category ........................................................... 4How Many Drums Is That? ................................................................... 5What Do You Measure to Determine Your Generator Category? .................... 6

REQUIREMENTS FOR CONDITIONALLY EXEMPT SMALL QUANTITY GENERATORS .......................... 7

REQUIREMENTS FOR SMALL QUANTITY GENERATORS ........................................................... 8Obtaining an EPA Identification Number ................................................. 8Sample RCRA Subtitle C Site Identification Form ....................................... 9

MANAGING HAZARDOUS WASTE ON-SITE .................................................................... 11Accumulating Your Waste ................................................................... 11Treating Your Waste to Meet the Land Disposal Restrictions (LDRs) ............... 12Hazardous Waste Code Chart .............................................................. 13Responding to Emergencies ................................................................. 17Preventing Accidents ......................................................................... 17Waste Minimization: The Key to Better Waste Management ........................ 18

SHIPPING HAZARDOUS WASTE OFF-SITE ....................................................................... 20Selecting a TSDF............................................................................... 20Labeling Waste Shipments ................................................................... 20Selecting a Transporter or TSDF/Recycler ................................................ 21Preparing Hazardous Waste Manifests .................................................... 21Land Disposal Restrictions (LDR) Reporting Requirements .......................... 21Export Notification ............................................................................ 22

SUMMARY OF REQUIREMENTS FOR LARGE QUANTITY GENERATORS ...................................... 23

FINAL TIPS ............................................................................................................ 24Are You Sure? .................................................................................. 24Can You Use the Universal Waste Rule? ................................................. 24

WHERE TO GET MORE HELP ...................................................................................... 25Appendix A: State Hazardous Waste Management Assistance...................... 25Appendix B: EPA and Other Federal Resource Centers ............................... 25Appendix C: Forms/Invoices from the Hazardous Waste Section .................. 26


INTRODUCTION

TIP

Whenever you consult a federal hazard-

ous 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.

TIP

You can look up un-

familiar words or

phrases on a list of

definitions found at

the end of this hand-

book.

This handbook has been prepared by theHazardous Waste Section of the Arizona

Department of Environmental Quality (ADEQ)to help small business owners and operatorsunderstand how to best comply with federalhazardous waste management regulations, aswell as Arizona hazardous waste rules andstatutes. This handbook is intended as an over-view and summary of the regulations and statutesto give you a basic understanding of your respon-sibilities in managing your hazardous wasteactivities. It is not to be used as a substitute forthe actual regulations.

Much of the material in this handbook is re-printed from the Environmental ProtectionAgency’s (EPA) handbook entitled, Understand-ing the Hazardous Waste Rules—A Handbook forSmall Business. EPA’s handbook is augmented bymaterial pertaining to hazardous waste manage-ment requirements peculiar to Arizona rules andstatutes. Arizona incorporates most of the federalhazardous waste regulations by reference;therefore, Arizona’s hazardous waste rules aresimilar and consistent with the federal hazardouswaste regulations.

All of the federal hazardous waste regulations arelocated in Title 40 of the Code of Federal Regu-lations (CFR), Parts 260 to 299 which areincorporated by Arizona Administrative Codes(AAC) R18-8-260 to 280. State regulations arelocated in Arizona Revised Statutes 49-901through 49-944.

Federal and state rules definethree categories of hazardous

waste generators based upon thequantity of hazardous waste theygenerate in any calendar month:

1. Conditionally exempt smallquantity generators (CESQGs)that generate less than 220 lb(100 kg) in any calendarmonth.

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

3. Large quantity generators (LQGs) that generatemore than 2,200 lb (1,000 kg) or more than2.2 lb (1 kg) of acutely hazardous waste in anycalendar month or 220 lb (100 kg) acute spillresidue.

Each category of generator must comply with thehazardous waste rules specific to that category.This handbook is intended primarily for busi-nesses that generate small quantities of hazardouswaste (SQGs and CESQGs) to help them learnabout regulations that apply.

FOR MORE INFORMATION

If you have questions about any part of this

document or the federal hazardous waste

regulations pertaining to Arizona, call the

Hazardous Waste Inspections & Compliance

Unit at (602) 771-4108 or (800) 234-5677.

Proper management of hazardous waste is important to

safeguard human health and the environment.


DECIDING WHETHER HAZARDOUS

WASTE REGULATIONS APPLY TO YOU

✔ First, determine if you

generate hazardous waste.

✔ Measure the amount of haz-

ardous waste that you

produce per month.

✔ Determine your generator

category to learn the man-

agement requirements that

apply to you.

DEFINING HAZARDOUS WASTE

A waste is any solid, liquid, or contained gaseousmaterial that is discarded by being disposed of,

burned or incinerated,or recycled. (Thereare some exceptionsfor recycled materi-als.) It can be the by-product of a manu-facturing process orsimply a commercialproduct that you usein your business—such as a cleaningfluid or batteryacid—that is beingdisposed. Even

materials that are recyclable or can be reused insome way—such as burning used oil for fuel—may be considered waste. Hazardous waste canbe one of two types:

■ Listed wasteYour waste is considered hazardous if itappears on one of four lists published in 40CFR Part 261 (as incorporated by AAC R18-8-261) and is not otherwise excluded. Currently,more than 400 wastes are listed. Wastes arelisted as hazardous because they are known tobe harmful to human health and the environ-ment when not managed properly.

Acutely hazardouswastes are listedwastes that evenwhen managedproperly areextremely danger-ous. Examples ofacutely hazardouswastes includewastes generatedfrom some pesti-cides that can be

Federal and state hazardous waste management regulations apply to most businesses thatgenerate hazardous waste. To determine if these regulations apply to your business, you mustfirst determine if you even generate hazardous waste.

fatal to humans even in low doses. P listed andF020, F021, F022, F023, F026, and F027 areexamples of acutely hazardous wastes.

■ Characteristic wasteIf your waste does not appear on one of thehazardous waste lists, it still might be consid-ered hazardous if it demonstrates one or moreof the following characteristics:

▲It catches fire under certain conditions. This isknown as an ignitable waste. Examples arepaints and certain degreasers and solvents.

▲It corrodes metals or has a very high or verylow pH. This is known as a corrosive waste.Examples are rust removers, acid or alkalinecleaning fluids, and battery acid.

▲It is unstable and explodes or produces toxicfumes, gases, and vapors when mixed withwater or under other conditions, such as heat orpressure. This is known as a reactive waste.Examples are certain cyanides or sulfide-bearing wastes.

▲It is harmful or fatal when ingested or ab-sorbed, or it leaches toxic chemicals into thesoil or ground water when disposed of on land.This is known as a toxic waste. Examples arewastes that contain high concentrations ofheavy metals, such as cadmium, lead, ormercury.

Additionally, a mixture of hazardous waste withsolid waste (e.g., motor oil, trash, debris) maybecome a hazardous waste.

You can determine if your waste is toxic byhaving it tested using the Toxicity Charac-

teristic Leaching Procedure (TCLP), or bysimply knowing that your waste is hazardous orthat your processes generate hazardous waste(called generator knowledge). However, youmust have written documentation if usinggenerator knowledge for both hazardous andnon-hazardous waste.

TIP

One way to help determine if

your waste exhibits a

characteristic is to check the

Material Safety Data Sheet

(MSDS) that comes with all

products containing hazardous

materials. In addition, your

national trade association or its

local chapter might be able to

help you.


IDENTIFYING YOUR WASTE

To help you identify some of the waste streamscommon to your business, consult the tablebelow to find a list of typical hazardous wastesgenerated by small businesses. Use the EPAHazardous Waste Codes for Waste StreamsCommonly Generated by Small Quantity Genera-tors list located in the center of this handbook fora more detailed listing of the EPA waste codesassociated with these waste streams to determine

if your waste is hazardous. Commercial chemicalproducts that are discarded might also becomehazardous waste. For a complete listing ofhazardous waste codes, consult 40 CFR Part 261(as incorporated by R-18-8-261).

If your waste is hazardous, you will need tomanage it according to appropriate federal andstate hazardous waste regulations.

D001, D039,

F002

D001, F001-

F005

D001, D002,

F001-F005

D001, D002,

D003, F001-

F005, U211

D001, D002,

D006, D008,

F001-F005

D002, D006,

D008, F001-

F005

D001, D002,

D006, D008,

F001-F005

D001, F001-

F005, U129,

U136, P094,

P123

D001, D002,

F001-F005

Still residues from solvent

distillation, spent filter car-

tridges, cooked powder residue

Ignitable wastes, toxic wastes,

solvent wastes, paint wastes

Ignitable wastes, toxic wastes,

solvent wastes, paint wastes,

used oil, acids/bases

Spent solvents, unused re-

agents, reaction products,

testing samples, contaminated

materials

Acids/bases, solvents, ignitable

wastes, toxic wastes, paint

wastes, batteries

Acids/bases, heavy metal

wastes, solvents, toxic wastes,

ink

Acids/bases, toxic wastes,

ignitable wastes, paint wastes,

solvents

Used/unused pesticides, solvent

wastes, ignitable wastes,

contaminated soil (from spills),

contaminated rinsewater,

empty containers

Ignitable wastes, solvent

wastes, acids/bases, paint

wastes

Commercial dry cleaning processes

Wood cleaning and wax removal, refinishing/

stripping, staining, painting, finishing, brush

cleaning, and spray brush cleaning

Paint preparation and painting, carpentry

and floor work, other specialty contracting

activities, heavy construction, wrecking and

demolition, vehicle and equipment main-

tenance for construction activities

Diagnostic and other laboratory testing

Degreasing, rust removal, paint preparation,

spray booth, spray guns, brush cleaning,

paint removal, tank cleanout, installing lead-

acid batteries

Plate preparation, stencil preparation for

screen printing, photo processing, printing,

cleanup

Degreasing, equipment cleaning, rust re-

moval, paint preparation, painting, paint

removal, spray booth, spray guns, and brush

cleaning

Pesticide application and cleanup

Automobile engine and body repair, metal-

working, graphic arts—plate preparation,

woodworking

Dry Cleaning and

Laundry Plants

Furniture/Wood

Manufacturing

and Refinishing

Construction

Laboratories

Vehicle

Maintenance

Printing and

Allied Industries

Equipment Repair

Pesticide End-

Users/Application

Services

Educational and

Vocational Shops

Type of Business How Generated Types of Wastes

TYPICAL HAZARDOUS WASTES GENERATED BY BUSINESSES

Waste Codes


Once you know that you generate hazardouswaste, you need to measure the amount of

waste you produce each calendar month. Theamount of hazardous waste you generate in acalendar month determines your generatorcategory.

Many hazardous wastes are liquids and aremeasured in gallons—not pounds. In order tomeasure your liquid wastes, you will need toconvert from gallons to pounds. To do this, youmust know the density of the liquid. A rough

FINDING YOUR

GENERATOR CATEGORYGENERATION FEES

For generation fees, SQGs are invoiced

annually. The fee is $10 per ton unless

the facility has a Certified Pollution Pre-

vention Plan; then it is $5 per ton.

guide is that 30 gallons (about half of a 55-gallondrum) of waste with a density similar to waterweighs about 220 lb (100 kg); 300 gallons of awaste with a density similar to water weighsabout 2,200 lb (1,000 kg).

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

CONDITIONALLY EXEMPT SMALL QUANTITY

GENERATORS (CESQGS)

You are considered a CESQG if you generate nomore than 220 lb (100 kg) of hazardous waste inany calendar month and do not accumulate over2,200 lb (1,000 kg). You are exempt from hazard-ous waste management regulations provided thatyou comply with the basic requirements de-scribed on page 7.

SMALL QUANTITY GENERATORS (SQGS)

You are considered an SQG if you generatebetween 220 and 2,200 lb (100 and 1,000 kg) ofhazardous waste in any calendar month and donot accumulate over 13,228 lb (6,000 kg). SQGsmust comply with federal and state requirementsfor managing hazardous waste described in thishandbook.

LARGE QUANTITY GENERATORS (LQGS)

You are considered an LQG if you generate morethan 2,200 lb (1,000 kg) of hazardous waste inany calendar month. LQGs must comply withmore extensive hazardous waste rules than thosesummarized in this handbook. See page 23 for anoverview.

Note: If any generator generates or accumulatesmore than 2.2 lb (1 kg) of acutely hazardouswaste in a calendar month or 220 lb (100 kg)acute spill residue, all of the acutely hazardouswaste must be managed according to the regula-tions applicable to LQGs.

WHAT IS YOUR GENERATOR CATEGORY?

For waste management purposes, depending on

your type of business, you might be regulated un-

der different rules at different times. If, for ex-

ample, you generate less than 220 lb (100 kg) of

hazardous waste during the month of June, you

would be considered a CESQG for June 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 lb

(100 to 1,000 kg) of hazardous waste, your gen-

erator status would change, and you would be

considered an SQG for July. Your July waste and

facility would then be subject to the management

requirements for SQGs.

For annual registration fee purposes, your fee is

based on the maximum amount generated in any

one month of the previous year. Use your monthly

generation amounts to determine your registra-

tion status, not your annual generation total. You

are an SQG if you have generated 220 lb (100 kg)

or more but less than 2,200 lb (1000 kg) of haz-

ardous waste in any calendar month of the previ-

ous year. If this is the case, you are required to

pay an annual registration fee of $100. If you have

generated less than 220 lb (100 kg) of hazardous

waste in any calendar month of the previous year,

you are a CESQG and do not have an annual reg-

istration fee. See Appendix C, Hazardous Waste

Facility Annual Report for CESQGs.


HOW MANY DRUMS IS THAT?

KEY:

= 55 gal drum

= 440 lb (water)

= 200 kg (water)

1/2 to 5 drums or

27 to 275 gal or

220 to 2,200 lb or

100 to 1,000 kg

<1/2 drum or

<27 gal or

<220 lb or

<100 kg

LARGE QUANTITY GENERATOR

(LQG)

>5 drums or

>275 gal or

>2,200 lb or

>1,000

SMALL QUANTITY GENERATOR (SQG)

CONDITIONALLY EXEMPT SMALL

QUANTITY GENERATOR (CESQG)

➔

SUBSTANCE

Note: This page is for guidance purposes

only. Not all chemicals have the same

density. This chart shows different

weights per gallon and per drum.

TIP

Water

Lead

Methylene

chloride

Acetone

LB PER DRUM

458.7

5,206.25

612.37

363.275

LB PER GAL

8.340

94.659

11.134

6.605

Per calendar month

Per calendar month

Per calendar month

➔ or more


WHAT DO YOU MEASURE

TO DETERMINE YOUR GENERATOR CATEGORY?

DO MEASURE:

For your monthly total, all quantities of listedand characteristic hazardous wastes that are:

✔ Accumulated on the property for any period oftime before disposal or recycling. (Dry clean-ers, for example, must count any residueremoved from machines, as well as spentcartridge filters.)

✔ Packaged and transported away from yourbusiness.

✔ Placed directly in a regulated treatment ordisposal unit at your place of business.

✔ Generated as still bottoms or sludges andremoved from product storage tanks.

DO NOT MEASURE:

Wastes that:

✔ Might be left in the bottom of containers thathave been thoroughly emptied through conven-tional means such as pouring or pumping.

✔ Are left as residue in the bottom of tanksstoring products, if the residue is not removedfrom the product tank.

✔ Are reclaimed continuously on-site withoutstoring prior to reclamation, such as drycleaning solvents.

✔ Are managed in an elementary neutralizationunit, a totally enclosed treatment unit, or awastewater treatment facility without beingstored first. (See definitions at the end of thishandbook for an explanation of thesetypes of units.)

✔ Are discharged directly to publicly ownedtreatment works (POTWs) without beingstored or accumulated first. This discharge to aPOTW must comply with the Clean Water Act.POTWs are public utilities, usually owned bythe city, county, or state that treat industrial anddomestic sewage for disposal.

✔ Have already been counted once during thecalendar month, and are treated on-site orreclaimed in some manner, and used again.

✔ Are regulated under the universal waste rule orhave other special requirements. The federalregulations contain special, limited require-ments for managing certain commonly gener-ated wastes. These wastes can be managedfollowing the less burdensome requirementslisted below instead of the usual hazardouswaste requirements.

Used oil—40 CFR Part 279 (as incorporatedby ARS 49-801-818).

Lead-acid batteries that are reclaimed—40CFR Part 266, Subpart G (as incorporated byR-18-8-266).

Scrap metal that is recycled—40 CFR 261.6(a)(3) (as incorporated by R-18-8-261).

Universal wastes (e.g., certain batteries,recalled and cancelled pesticides, mercury-containing thermostats, and mercury-containing waste lamps)—40 CFR Part 273(as incorporated by R-18-8-273).

Don't mix incompatible wastes.


If you generate no more than 220 lb (100 kg) of hazardous waste in any month, you are aconditionally exempt small quantity generator (CESQG). You must comply with three basic wastemanagement requirements to remain exempt from the full hazardous waste regulations that applyto generators of larger quantities (SQGs and LQGs). Note: There are different quantity limits foracutely hazardous waste.

First, you must identify all hazardouswaste that you generate and keep documenta-

tion of your waste determination. Second, youmay not store more than 2,200 lb (1,000 kg) ofhazardous waste on-site at any time. Finally, youmust ensure delivery of your hazardous waste toan off site treatment or disposal facility that isone of the following:

■ An Arizona- or federally-regulated hazardouswaste management treatment, storage, or disposalfacility (TSDF).

■ A facility permitted, licensed, or registered byArizona to manage municipal or industrialsolid waste.

■ A facility that uses, reuses, or legitimatelyrecycles the waste (or treats the waste prior touse, reuse, or recycling).

■ A universal waste handler or destinationfacility subject to the universal waste require-ments of 40 CFR Part 273 (as incorporated byR18-8-273) if your waste is universal waste.Universal wastes are wastes such as certainbatteries, recalled and banned pesticides, ormercury-containing thermostats. Note: InArizona, mercury-containing waste lamps areconsidered universal waste and should bemanaged in accordance with R18-8-273.

■ Or, if you treat or dispose of your hazardouswaste on-site, your facility also must also meetthe above definitions.

✔ Identify your hazardous waste.

✔ Comply with storage quantity limits.

✔ Ensure proper treatment and disposal

of your waste.

REQUIREMENTS FOR CONDITIONALLY

EXEMPT SMALL QUANTITY GENERATORS

Good housekeeping procedures can save money.TIP

CESQGs with EPA identifica-

tion numbers must complete

a Facility Annual Report

yearly. See Appendix C.

CESQGs


ADEQ records the information on the form andassigns an EPA ID number to the site identifiedon your form. The EPA ID number stays with theproperty when ownership changes. If you moveyour business, you must notify ADEQ of yournew location and submit a new form. If anotherbusiness previously handled hazardous waste atthis location and obtained an EPA ID number,you will be assigned the same number after youhave notified ADEQ that you have moved to thislocation. Otherwise, ADEQ will assign you anew identification number. You must alsodeactivate the old EPA ID number. To deactivatean EPA ID number, submit on company letter-head the facility name, ID number, reason fordeactivation, and the date of deactivation, andmail to ADEQ at the above address.

A revised 8700-12 must be submitted to ADEQ ifownership changes, generator status changes, orthe type of waste generated changes.

✔ Call ADEQ to determine if you need

an EPA ID number.

✔ If you do, obtain a copy of EPA

Form 8700-12.

✔ Fill in the form completely.

✔ Send the form to the ADEQ

Notification Coordinator.

REQUIREMENTS FOR SMALL QUANTITY GENERATORS

OBTAINING AN EPA IDENTIFICATION NUMBER

If your business generates between 220 lb(100 kg) and 2,200 lb (1,000 kg) of hazardous

waste in any calendar month, you are a smallquantity generator (SQG), and must obtain anduse an EPA Identification (ID) Number. EPA andall states use these 12-character numbers tomonitor and track hazardous waste activities.You will need to use your identification numberwhen you send waste off-site to be managed.

To obtain an EPA ID number:

■ Visit the EPA Web site http://www.epa.gov/epaoswer/hazwaste/data/form8700/8700-12.pdfor ADEQ's Web site at www.adeq.state.az.us,click on environmental programs>wasteprograms>haz waste>permits unit>permitsdocuments download>EPA form 8700-12.

■ Call ADEQ at (602) 771-4147 or write toADEQ, Hazardous Waste Section, FacilityAssistance Unit, 1110 W. Washington St.,Phoenix, Arizona, 85007, and request a copy ofEPA Form 8700-12, Rev 5/2002, Notificationof Regulated Waste Activity. You will be sent abooklet that contains a form with instructions.A sample copy of a completed notificationform is shown on pages 9 and 10.

■ Fill in the form as shown in the example. Tocomplete Item IX of the form, you will need toidentify your hazardous waste by its EPAHazardous Waste Code. A list of commonhazardous wastes and their waste codes can befound in the center of this document; for acomplete list of waste codes, you shouldconsult 40 CFR Part 261 (as incorporated byR18-8-261). Complete one copy of the formfor each business site where you generate orhandle hazardous waste. Each site will receiveits own EPA ID number. Make sure you signthe certification in Item X.

■ Send the completed form to the ADEQ hazard-ous waste contact. This address is listed in theinformation booklet that you will receive withthe form.

Treat your hazardous materials with care so they

don't become hazardous waste.

SQGs


Most small businesses accumulate some hazardous waste on-site for a short period of time andthen ship it off-site to a treatment, storage, or disposal facility (TSDF).

ACCUMULATING YOUR WASTE

Accumulating hazardous waste on-site canpose a threat to human health and the

environment, so you may only keep it for a shorttime without a permit. Before shipping the wastefor disposal or recycling, you are responsible forits safe management, which includes safestorage, safe treatment, preventing accidents,and responding to emergencies in accordancewith federal and Arizona regulations.

SQGs can accumulate no more than 13,228 lb(6,000 kg) of hazardous waste on-site for up to180 days without a permit. You can accumulatethis amount of waste for up to 270 days if youmust transport it more than 200 miles away forrecovery, treatment, or disposal. Limited exten-sions may be granted by the ADEQ director. Ifyou exceed these limits, you may be considereda TSDF and may be required to obtain anoperating permit. Special storage requirementsapply to liquid hazardous wastes containingpolychlorinated biphenyls (PCBs).

SQGs must accumulate waste in tanks or con-tainers, such as 55-gallon drums. Your storagetanks and containers must be managed accordingto the following summarized requirements.

For containers, you must:

■ Label each container with the words HAZARD-OUS WASTE, and mark each container with thedate waste was first added.

■ Use a container made of, or lined with, amaterial that is compatible with the hazardouswaste to be stored. (This will prevent the wastefrom reacting with or corroding the container.)

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

■ Inspect areas where containers are stored atleast weekly. Look for leaks and for deteriora-tion caused by corrosion or other factors.

■ Maintain the containers in good condition. If acontainer leaks, put the hazardous waste inanother container, or contain it in some otherway that complies with EPA and state regula-tions.

■ Do not mix incompatible wastes or materialsunless precautions are taken to prevent certainhazards.

MANAGING HAZARDOUS WASTE ON-SITE

✔ Accumulate wastes according to

limits established for SQGs.

✔ Follow the storage and handling pro-

cedures required by federal and

Arizona rules for SQGs.

✔ Follow requirements for equipment

testing and maintenance, access to

communications or alarms, aisle space,

and emergency arrangements with

local authorities as required by

federal and Arizona rules.

Properly store hazardous materials.

SQGs


TREATING YOUR WASTE TO MEET THE LAND

DISPOSAL RESTRICTIONS (LDRS)

Most hazardous wastes may not be landdisposed unless they meet treatment

standards. The Land Disposal Restrictions(LDR) program requires that the waste is treatedto reduce the hazardous constituents to levels setby EPA, or that the waste is treated using aspecific technology. It is your responsibility toensure that your waste is treated to meet LDRtreatment standards before it is land disposed.(See page 22 for a description of required LDRnotices.) Most SQGs probably will have theirdesignated TSDF do this treatment. If you chooseto treat your waste yourself to meet LDR treat-ment standards, there are additional require-ments, including waste analysis plans, notifica-tions, and certifications. To learn about theserequirements call the EPA RCRA Hotline(800) 424-9346, the ADEQ Inspections &Compliance Unit (602) 771-4108, or consult 40CFR Part 268 (as incorporated by R18-8-268).

For tanks, you must:

■ Label each tank with the words HAZARDOUSWASTE.

■ Store only waste that will not cause the tank orthe inner liner of the tank to rupture, leak,corrode, or fail.

■ Equip tanks that have an automatic waste feedwith a waste feed cutoff system or a bypasssystem for use in the event of a leak or over-flow.

■ Inspect discharge control and monitoringequipment and the level of waste in uncoveredtanks at least once each operating day. Inspectthe tanks and surrounding areas for leaks orother problems (such as corrosion) once eachoperating day.

■ Use the National Fire Protection Association(NFPA) buffer zone requirements for coveredtanks containing ignitable or reactive wastes.These requirements specify distances consid-ered to be safe buffer zones for various ignit-able or reactive wastes. You can reach theNFPA at (617) 770-3000.

■ Do not mix incompatible wastes or materialsunless precautions are taken to prevent certainhazards.

■ Do not place ignitable or reactive wastes intanks unless certain precautions are taken.

■ Provide at least two feet (60 centimeters) offreeboard (space at the top of each tank) inuncovered tanks, unless the tank is equippedwith a containment structure, adrainage control system, or astandby tank with adequatecapacity.

TIPS

✔ It is good practice never to mix wastes.

Mixing wastes can create an unsafe

work environment and lead to com-

plex and expensive cleanups and dis-

posal.

✔ Clean up spills and leaks quickly to

avoid larger problems.

Safely store hazardous wastes

in suitable containers.

SQGs


HAZARDOUS WASTE CODE CHART

PULL OUT AND POST

FOR QUICK REFERENCE


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cid

Hyd

rofl

uori

c A

cid

Nitr

ic A

cid

Ace

tone

F003

Ben

zene

F005

n-B

utyl

Alc

ohol

F003

Chl

orob

enze

neF0

02

Cyc

lohe

xano

neF0

03

Eth

yl A

ceta

teF0

03

LEAD-A

CID

BATTERIE

S

Use

d le

ad-a

cid

batte

ries

sho

uld

bere

port

ed o

n th

e no

tific

atio

n fo

rmon

ly if

they

are

not

rec

ycle

d. U

sed

lead

-aci

d ba

tteri

es th

at a

re r

ecyc

led

do n

ot n

eed

to b

e co

unte

d in

dete

rmin

ing

the

quan

tity

of w

aste

that

you

gene

rate

in a

ny m

onth

. Spe

cial

req

uire

men

ts d

oap

ply

if y

ou r

ecyc

le y

our

batte

ries

on

your

ow

npr

emis

es (

see

40 C

FR 2

66).

Ben

zene

F005

Car

bon

Dis

ulfi

deF0

05C

arbo

n Te

trac

hlor

ide

F001

Chl

orob

enze

neF0

02C

reso

lsF0

04C

resy

lic A

cid

F004

O-D

ichl

orob

enze

neF0

02E

than

olD

001

2-E

thox

yeth

anol

F005

Eth

ylen

e D

ichl

orid

eD

001

Isob

utan

olF0

05Is

opro

pano

lD

001

Ker

osen

eD

001

Met

hyl E

thyl

Ket

one

F005

Met

hyle

ne C

hlor

ide

F001

, F00

2N

apht

haD

001

Nitr

oben

zene

F004

2-N

itrob

enze

neF0

04

Lea

d D

ross

D00

8Sp

ent A

cids

D00

2L

ead-

Aci

d B

atte

ries

D00

8

IGN

ITABLE W

ASTES

Igni

tabl

e w

aste

s ar

e an

y liq

uids

that

hav

e a

flas

hpoi

nt le

ss th

an14

0°F,

any

non

-liq

uids

that

are

cap

able

of

caus

ing

a fi

re th

roug

hfr

ictio

n, a

bsor

ptio

n of

moi

stur

e, o

r sp

onta

neou

s ch

emic

al c

hang

e, o

ran

y ig

nita

ble

com

pres

sed

gas

as d

escr

ibed

in 4

9 C

FR 1

73.3

00 (

for

aco

mpl

ete

desc

ript

ion

of ig

nita

ble

was

tes,

see

40

CFR

261

.21)

.E

xam

ples

are

spe

nt s

olve

nts,

sol

vent

stil

l bot

tom

s, e

poxy

res

ins

and

adhe

sive

s,an

d w

aste

inks

con

tain

ing

flam

mab

le s

olve

nts.

Unl

ess

othe

rwis

e sp

ecif

ied,

all

igni

tabl

e w

aste

s ha

ve th

e w

aste

cod

e D

0

PESTIC

IDES The

pes

ticid

es li

sted

bel

ow a

reha

zard

ous.

Was

tes

mar

ked

with

an a

ster

isk

(*)

have

bee

n de

sig-

nate

d ac

utel

y ha

zard

ous.

For

am

ore

com

plet

e lis

ting,

see

40

CFR

261

.32

for

spec

ific

list

ed p

estic

ides

, and

othe

r w

aste

s, w

aste

wat

ers,

slu

dges

, and

by-

prod

ucts

fro

m p

estic

ide

form

ulat

ors.

EPA

HAZARD

OU

S W

ASTE

CO

DES F

OR

WASTE S

TREAM

S

CO

MM

ON

LY

GEN

ERATED B

Y S

MALL

QU

AN

TIT

Y

GEN

ERATO

RS

Eth

yl B

enze

neF0

03E

thyl

Eth

er00

3E

thyl

ene

Dic

hlor

ide

D00

1M

etha

nol

F003

Met

hyl I

sobu

tyl K

eton

e F0

03Pe

trol

eum

Dis

tilla

tes

D00

1X

ylen

eF0

03

Petr

oleu

m S

olve

nts

D00

1 (

Flas

hpoi

nt le

ss th

an 1

40°F

)Py

ridi

neF0

051,

1,1-

Tri

chlo

roet

hane

F001

, F00

21,

1,2-

Tri

chlo

roet

hane

F002

Tetr

achl

oroe

thyl

ene

F001

, F00

2 (

Perc

hlor

oeth

ylen

e)To

luen

eF0

05T

rich

loro

ethy

lene

F001

, F00

2T

rich

loro

fluo

rom

etha

neF0

02T

rich

loro

trif

luor

oeth

ane

(Val

clen

e)F0

02W

hite

Spi

rits

D00

1


WO

OD P

RESERVIN

G A

GEN

TS

The

was

tew

ater

trea

tmen

t slu

dges

fro

m w

aste

wat

er tr

eatm

ent o

pera

-tio

ns a

re c

onsi

dere

d ha

zard

ous.

Bot

tom

sed

imen

t slu

dges

fro

m th

etr

eatm

ent o

f 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

addi

tion,

unl

ess

othe

rwis

ein

dica

ted,

spe

cifi

c w

ood

pres

ervi

ng c

ompo

unds

are

:

Chr

omat

ed C

oppe

r Ars

enat

eD

004

Cre

osot

eU

051

Ars

enic

D00

4B

ariu

mD

005

Cad

miu

mD

006

Chr

omiu

mD

007

HEAVY M

ETA

LS/I

NO

RG

AN

ICS

Hea

vy m

etal

s an

d ot

her

inor

gani

c w

aste

mat

eria

ls a

re c

onsi

dere

dha

zard

ous

if th

e ex

trac

t fro

m a

rep

rese

ntat

ive

sam

ple

of th

e w

aste

has

any

of th

e sp

ecif

ic c

onst

ituen

t con

cent

ratio

ns a

s sh

own

in 4

0C

FR 2

62.2

4, T

able

1. M

ater

ials

may

incl

ude

dust

s, s

olut

ions

, was

te-

wat

er tr

eatm

ent s

ludg

es, p

aint

was

tes,

and

was

te in

ks. T

he f

ollo

win

gar

e co

mm

on h

eavy

met

als/

inor

gani

cs:

Lea

dD

008

Mer

cury

D00

9Se

leni

umD

010

Silv

erD

011

CD

ASH

G

INK S

LUD

GES C

ON

TAIN

ING C

HRO

MIU

M A

ND L

EAD

Thi

s ca

tego

ry in

clud

es s

olve

nt w

ashe

s an

d sl

udge

s, c

aust

ic w

ashe

san

d sl

udge

s, a

nd w

ater

was

hes

and

slud

ges

from

cle

anin

g tu

bs a

ndeq

uipm

ent u

sed

in th

e fo

rmul

atio

n of

ink

from

pig

men

ts, d

rier

s,so

aps,

and

sta

biliz

ers

cont

aini

ng c

hrom

ium

and

lead

. All

ink

slud

ges

have

the

was

te c

ode

K08

6.

DRY C

LEAN

ING

FIL

TRATIO

N R

ESID

UES

Coo

ked

pow

der

resi

due

(per

-ch

loro

ethy

lene

pla

nts

only

), s

till

resi

dues

, and

spe

nt c

artr

idge

filte

rs c

onta

inin

g pe

rchl

oro-

ethy

lene

or

valc

lene

are

haz

ard-

ous

and

have

the

was

te c

ode

F00

2. S

till

resi

dues

con

tain

ing

petr

oleu

m s

olve

nts

with

afl

ashp

oint

less

than

140

°F a

re c

onsi

dere

dha

zard

ous

and

have

the

was

te c

ode

D00

1.

REACTIV

ES R

eact

ive

was

tes

incl

ude

mat

eria

ls o

rm

ixtu

res

that

are

uns

tabl

e, r

eact

viol

ently

with

or

form

exp

losi

vem

ixtu

res

with

wat

er, g

ener

ate

toxi

cga

ses

or v

apor

s w

hen

mix

ed w

ith w

ater

(or

whe

nex

pose

d to

pH

con

ditio

ns b

etw

een

2 an

d 12

.5 in

the

case

of

cyan

ide

or s

ulfi

de-b

eari

ng w

aste

s), o

rar

e ca

pabl

e of

det

onat

ion

or e

xplo

sive

rea

ctio

nw

hen

heat

ed o

r su

bjec

t to

shoc

k (f

or a

com

plet

ede

scri

ptio

n of

rea

ctiv

e w

aste

s, s

ee 4

0 C

FR26

1.23

). U

nles

s ot

herw

ise

spec

ifie

d, a

ll re

activ

ew

aste

s ha

ve th

e w

aste

cod

e D

003.

The

fol

low

ing

mat

eria

ls a

re c

omm

only

con

side

red

to b

e re

activ

e:

SPEN

T P

LATIN

G A

ND C

YAN

IDE W

ASTES

Spen

t pla

ting

was

tes

cont

ain

clea

ning

sol

utio

ns a

nd p

latin

g so

lutio

nsw

ith c

aust

ics,

sol

vent

s, h

eavy

met

als,

and

cya

nide

s. C

yani

de w

aste

sm

ay a

lso

be g

ener

ated

fro

m h

eat t

reat

men

t ope

ratio

ns, p

igm

ent

prod

uctio

n, a

nd m

anuf

actu

ring

of

anti-

caki

ng a

gent

s. P

latin

g w

aste

sge

nera

lly h

ave

the

was

te c

odes

F00

6-F

009 ,

with

F00

7 an

d F

009

cont

aini

ngcy

anid

e. C

yani

de h

eat t

reat

ing

was

tes

gene

rally

hav

e th

e w

aste

cod

es F

010-

F01

2(s

ee 4

0 C

FR 2

61.3

1 fo

r a

mor

e co

mpl

ete

desc

ript

ion

of p

latin

g w

aste

s).

Pent

achl

orop

heno

lF0

27

Ace

tyl C

hlor

ide

Chr

omic

Aci

dC

yani

des

Hyp

ochl

orite

sO

rgan

ic P

erox

ides

Perc

hlor

ates

Perm

anga

nate

sSu

lfid

es

Ald

icar

b*P0

70A

mitr

ole

U01

11,

2-D

ichl

orop

rope

neU

084

Hep

tach

lor*

P059

Lin

dane

U12

9M

ethy

l Par

athi

on*

P071

Para

thio

n*P0

89Ph

orat

e*P0

94

Perc

hlor

ic A

cid

Phos

phor

ic A

cid

Pota

ssiu

m H

ydro

xide

Sodi

um H

ydro

xide

Sulf

uric

Aci

d

This list can b

e u

sed a

s a g

uid

e for

small

quantity

genera

tors

to d

ete

rmin

e w

hic

h o

f th

eir

wast

es, if any, are

hazard

ous, a

nd to d

ete

rmin

e

the E

PA w

ast

e c

odes

ass

ocia

ted w

ith e

ach

wast

e. It is

not in

tended to p

rovid

e a

com

pre

hensive list of all w

ast

e c

odes

and w

ast

e

stre

am

s th

at sm

all b

usiness

es

could

genera

te.

Except fo

r th

e p

est

icid

e a

nd w

ood p

rese

rvin

g

cate

gories, this list does

not in

clu

de w

ast

e c

odes

for

com

merc

ial chem

ical pro

ducts

that are

hazard

ous

when d

iscard

ed u

nuse

d. These

wast

es, a

s w

ell a

s all o

thers

not list

ed h

ere

, can

be found in T

itle

40 o

f 40 C

FR P

art

261. If y

ou

have a

ny q

uest

ions, c

onta

ct AD

EQ

at

(602) 771-4

108 o

r (8

00) 234-5

677, th

e R

CRA

Hotlin

e a

t (8

00) 424-9

346 o

r

TD

D (800) 533-7

672 fro

m o

ther

locations.


IF YOU THINK YOU HAVE AN EMERGENCY, IMMEDIATELY

CALL THE NATIONAL RESPONSE CENTER AT

(800) 424-8802 AND ADEQ AT (602) 771-2330OR (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 appro-

priate emergency decisions. In many cases, you will

find that the problem you faced was not a true emer-

gency, but it is better to call if you are not sure. Stiffpenalties exist for failing to report emergencies.

RESPONDING TO EMERGENCIES

You must be prepared for an emergency atyour facility. One way is to develop a

contingency plan. A contingency plan usuallyanswers a set of “what if” questions. For ex-ample: “What if there is a fire in the area wherehazardous waste is stored?” or “What if I spillhazardous waste, or one of my hazardous wastecontainers leaks?” Although EPA does not requireSQGs to develop a written contingency plan, incase of a fire, explosion, or toxic release, havingsuch a plan would provide an organized andcoordinated course of action. EPA does requireSQGs to establish basic safety guidelines andresponse procedures to follow in the event of anemergency.

Worksheets 1 and 2 (see page 19) can help youset up these procedures. The information onWorksheet 1 must be posted near your phone. Youmust ensure that employees are familiar withthese procedures. Keep information current.

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-sitemust be equipped with:

■ An internal communications or alarm systemcapable of providing immediate emergencyinstruction (voice or signal) to all personnel.

■ A device, such as a telephone (immediatelyavailable at the scene of operations) or a hand-held, two-way radio, capable of summoningemergency assistance from local police andfire departments or emergency response teams.

■ Portable fire extinguishers, fire control devices(including special extinguishing equipment,such as that using foam, inert gas, or drychemicals), spill control materials, and decon-tamination supplies.

■ Water at adequate volume and pressure tosupply water hose streams, foam-producingequipment, automatic sprinklers, or waterspray systems.

You must test and maintain all equipment toensure proper operation. Allow sufficient aislespace to permit the unobstructed movement ofpersonnel, fire protection equipment, spillcontrol equipment, and decontamination equip-

ment to any area of facility opera-tion. Attempt to secure arrangementswith fire departments, police, emer-gency response teams, equipmentsuppliers, and local hospitals, asappropriate, to provide services inthe event of an emergency. Ensurethat personnel handling hazardouswaste have immediate access to analarm or emergency communicationsdevice.

PREVENTING ACCIDENTSSQGs


WASTE MINIMIZATION: THE KEY TO BETTER WASTE MANAGEMENT

The easiest and most cost-effective way ofmanaging any waste is not to generate it in

the first place. You can decrease the amount ofhazardous waste your business produces bydeveloping a few good housekeeping habits.Good housekeeping procedures generally savebusinesses money, and they prevent accidentsand waste. To help reduce the amount of wasteyou generate, try the following practices at yourbusiness.

■ Do not mix wastes. Do not mix nonhazardouswaste with hazardous waste. Once you mixnonhazardous waste with hazardous waste, youmay increase the amount of hazardous wastecreated, as the whole batch may becomehazardous. Mixing waste can also makerecycling very difficult, if not impossible. Atypical example of mixing wastes would beputting nonhazardous cleaning agents in acontainer of used hazardous solvents.

■ Recycle and reuse manufacturing materials.Many companies routinely put useful compo-nents back into productive use rather thandisposing of them. Items such as oil, solvents,acids, and metals are commonly recycled andused again. In addition, some companies havetaken waste minimization actions, such asusing fewer solvents to do the same job, usingsolvents that are less toxic, or switching to adetergent solution.

■ Change materials, processes, or both. Busi-nesses can save money and increase efficiencyby replacing a material or a process withanother that produces less waste. For example,you could use plastic blast media for paintstripping of metal parts rather than conven-tional solvent stripping.

■ Safely store hazardous products and containers.You can avoid creating more hazardous wasteby preventing spills or leaks. Store hazardousproduct and waste containers in secure areas,and inspect them frequently for leaks. Whenleaks or spills occur, materials used to cleanthem up also become hazardous waste.

Recycle and reuse manufacturing materials.

Employee training helps prevent waste.

SQGs


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

✃

EMERGENCY RESPONSE INFORMATION

WORKSHEET 1

EMERGENCY COORDINATOR

Name:______________________________

________________________________________Telephone:__________________________

FIRE EXTINGUISHER

Location(s):_________________________

_______________________________________

_______________________________________

SPILL CONTROL MATERIALS

Location(s):________________________

_______________________________________

FIRE ALARM (IF PRESENT)Location(s): _______________________

_______________________________________

FIRE DEPARTMENT

Telephone: ________________________

Fill in shaded area and post this information next to your telephone. Makesure all employees read and are familiar with its contents.

WORKSHEET 2

EMERGENCY RESPONSE PROCEDURES

In the event of a spill:

Contain the flow of hazardous waste tothe extent possible, and as soon as ispossible, clean up the hazardous wasteand 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 fireextinguisher.

In the event of a fire, explosion, or otherrelease that could threaten human healthoutside the facility, or if you know thatthe spill has reached surface water:Call the National Response Center at its24-hour number (800) 424-8802 andADEQ 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:____________________________

✃

SQGs


SELECTING A TSDF

SQGs may send their waste only to a regulatedTSDF or recycler. Most regulated TSDFs andrecyclers will have a permit from the state orEPA. Some, however, may operate under otherregulations that do not require a permit. Checkwith the appropriate state authorities to be surethe facility you select has any necessary permits.All TSDFs and recyclers must have EPA IDnumbers.

LABELING WASTE SHIPMENTS

SQGs must properly package, label and mark allhazardous waste shipments, and placard thevehicles in which these wastes are shippedfollowing DOT regulations. Most small busi-nesses use a commercial transporter to shiphazardous waste. These transporters can adviseyou on specific requirements for placarding,labeling, marking, and packaging; however, youremain responsible for compliance. For addi-tional information, consult DOT regulations (49CFR Parts 172 and 173), or call the DOT hazard-ous materials information line at (202) 366-4488.In Arizona, you can also contact ADOT, Hazard-ous Materials, at (602) 712-4407.

Federal and Arizona regulations allow you totransport your own hazardous waste to a

designated TSDF provided that you comply withDOT rules and register with ADEQ as a hazard-ous waste transporter. Some states, however, donot allow this practice. Call DOT and the statehazardous waste management agency to whichyou are shipping the waste regarding applicableregulations.

SHIPPING HAZARDOUS WASTE OFF-SITE

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

Placard and label shipments properly.

SQGs

■ Package, label and mark your shipment,and placard the vehicle in which yourwaste is shipped as specified in Depart-ment of Transportation (DOT) regula-tions.

■ Prepare a hazardous waste manifest toaccompany your shipment.

■ Include a notice and certification witheach waste shipment.

■ Ensure the proper management of anyhazardous waste you ship (even when itis no longer in your possession).


PREPARING

HAZARDOUS WASTE MANIFESTS

A hazardous waste manifestmust accompany all hazardous

waste that is shipped off-site. A hazard-ous waste manifest is a multipart formdesigned to track hazardous waste fromgeneration to disposal. It will help youtrack your waste during shipment andensure it arrives at the proper destina-tion. If you send waste to a recyclingfacility, you may be able to use a tollingagreement instead of a manifest. Atolling agreement is a closed-looparrangement whereby a generatorcontracts with a recycling company toreclaim its hazardous waste and returnit as a recycled product, thereby avoid-ing disposal. A copy of the contractmust be kept on file for three years afterthe contract has ended.

Various versions of hazardous wastemanifest forms are available.

■ Some states require their own mani-fest form. Arizona uses the federalform (Uniform Hazardous WasteManifest, EPA form 8700-22). If thestate to which you are shipping yourwaste requires its own manifest, usethat state’s form. To obtain manifestforms, contact the hazardous wastemanagement agency of the recipientstate, your transporter, or the TSDFthat you intend to use.

■ If the state to which you are shippingdoes not require its own manifest,you can use the federal form. Copiesare available from some transporters,TSDFs, and some commercialprinters.

■ Arizona requires a hazardous wastegeneration fee of $10 for each tongenerated and shipped off site,beginning at 1 ton and prorated peradditional ton. Companies havingapproved Arizona Pollution Preven-tion Plans receive a $5 per tondiscount. See Appendix C.

SELECTING ATRANSPORTER OR TSDF/RECYCLER

It is important to choose your transporter andyour TSDF carefully since you remain responsiblefor the proper management of your hazardouswaste even after it has left your site and has beenprocessed by your TSDF.

For help in choosing a transporter or TSDF, checkwith the following sources:

■ References from business colleagues who haveused a specific hazardous waste transporter orTSDF.

■ Trade associations for your industry that mightkeep a file on companies that handle hazardouswaste.

■ The Better Business Bureau or Chamber ofCommerce in the TSDF’s area, which mighthave a record of any complaints registeredagainst a transporter or a facility.

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

Technological advances can help reduce waste.

SQGs


You must fill in all parts of amanifest and sign it. Information

requested includes: name of transporter,name of the designated facility, yourEPA ID number, quantity of waste, anda description of the waste based onDOT requirements, such as propershipping name and hazard class. Callthe DOT information line for moreinformation on DOT waste descriptionrequirements. Arizona requires the EPAWaste Codes to be listed in Column I.

The transporter is required to sign thecompleted manifest when the shipmentis accepted for transport. The facilityoperator at the designated TSDF alsosigns the form when the shipment isreceived and sends a copy of it back toyou. You must keep this copy on file forthree years. (It might be a good practice,however, to keep it for as long as youare in business.) Arizona also requiresthe generator and transporter to send acopy of the manifest to ADEQ, Hazard-ous Waste Section, Facility AssistanceUnit, 1110 W. Washington St., 4415A-1,Phoenix, AZ, 85007. All TSDFs locatedin Arizona are also required to sendcopies to ADEQ.

Arizona requires generators to submitmanifests for hazardous waste ship-ments only. The generator copy submit-ted to ADEQ must have three signa-tures: the generator, the transporter,and the TSDF.

Any SQG that does not receive a signedcopy of the manifest from the desig-nated TSDF must submit a legible copyof the manifest together with a writtennotice indicating that a signed copy wasnot received from the facility operator.This is known as an exception reportand must be submitted to ADEQ within60 days following the end of the monthof shipment of the waste. If errors arefound in your manifest, you mustcorrect the manifest and pay a $20 permanifest resubmittal fee. See AppendixC for example.

LAND DISPOSAL RESTRICTIONS

(LDR) REPORTING REQUIREMENTS

Regardless of where the wasteis being sent, for each ship-

ment of waste subject to LDRs youmust send the receiving TSDF orrecycler an LDR notice. This noticemust provide information aboutyour waste, such as the EPAhazardous waste code and the LDRtreatment standard. The purpose ofthis notice is to let the TSDF knowthat the waste must meet treatmentstandards before it is land disposed.There is no required form for thisnotice, but your TSDF may providea form for you to use. A certifica-tion may also be required in spe-cific situations. Call the EPA RCRAHotline at (800) 424-9346, theADEQ Inspections and ComplianceUnit at (602) 771-4108, and consult40 CFR Part 268 for help with LDRnotification and certificationrequirements.

EXPORT

NOTIFICATION

If you choose to export yourhazardous waste, you must

notify EPA 60 days before theintended date of shipment toobtain written consent. EPA’sAcknowledgment of Consentdocument must accompany theshipment at all times. For moreinformation on how to obtainthe consent to export hazardouswaste, contact the EPA RCRAHotline at (800) 424-9346.

Plating processes must be managed properly.

SQGs


Hazardous waste determina-

tion (40 CFR 262.10)

Generator category determi-

nation [40 CFR 262.10 (b)

and 261.5 (b) and (c)]

EPA ID numbers (40 CFR

262.12)

Prepare hazardous waste for

shipment off-site (40 CFR

262.30–262.33)

The manifest (40 CFR

262.20–262.23, 262.42)

Managing hazardous waste

on-site (40 CFR 262.34)

Recordkeeping, registration,

fees, and annual report (40

CFR 262.40–262.41) Arizona

requires an annual report.

Comply with land disposal

restrictions (40 CFR 268)

Export/import requirements

(40 CFR 262 Subparts E and

F)

LQG REQUIREMENTS

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).

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.

Package, label, mark, and placard wastes following DOT require-

ments. Ship waste using hazardous waste transporter.

Ship waste to 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.

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.

If you are a large quantity generator (LQG) [generating more than 2,200 lb (1,000 kg) in anycalendar month or 220 lb (100 kg) of acute spill residue], you must comply with the full setof hazardous waste regulations. If you generate or accumulate more than 2.2 lb (1 kg) acutelyhazardous waste or 220 lb (100 kg) of acute spill residue in a calendar month, the acutelyhazardous waste must be managed according to LQG regulations. This table summarizes thefederal and state LQG requirements. This is only a summary and does not include all of theLQG requirements. For more details, call the EPA RCRA Hotline, ADEQ Inspections &Compliance Unit, or see 40 CFR Part 262.

SUMMARY OF REQUIREMENTS FOR LQGS

Retain specified records for three years. Register with ADEQ and

pay annual fee of $300. Arizona requires a hazardous waste genera-

tion fee of $10 for each ton generated and shipped off site, begin-

ning at 1 ton and prorated per additional ton. Companies having

approved Arizona Pollution Prevention Plans receive a $5 per ton

discount. Submit annual reports by March 1 of each year covering

generator activities for the previous year.

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.

Follow requirements for exports and imports, including notification

of intent to export and acknowledgment of consent from receiving

country.

SUMMARY

LQGs


FINAL TIPS

CAN YOU USE THE

UNIVERSAL WASTE RULE?

Do you have hazardous wastes that can bemanaged under the hazardous waste universalwaste rule? Items such as hazardous wastebatteries, certain hazardous waste pesticides,mercury-containing thermostats, and mercury-containing waste lamps fall under the universalwaste regulations.

Small and large businesses that generate hazard-ous wastes that are in the universal waste catego-ries listed above can use the more streamlinedrequirements under the universal waste rule. Iteases the regulatory burden on businesses thatgenerate these wastes. Specifically, it has stream-lined requirements for: notification, labeling,marking, prohibitions, accumulation time limits,employee training, response to releases, off-siteshipments, tracking, exports, and transportation.

For example, the rule extends the amount of timethat businesses can accumulate these materials onsite. It also allows companies to transport themwith a common carrier, instead of a hazardouswaste transporter, and no longer requires compa-nies to obtain a manifest.

For additional assistance, contact the FacilityAssistance Unit, Compliance Assistance Pro-gram, at (602) 771-4235.

ARE YOU SURE?

■ Have you marked your containers ofhazardous waste with the wordsHAZARDOUS WASTE? Have youincluded the accumulation start date?

■ Do you keep your containers closed atall times, except when adding orremoving waste?

■ Have you done a hazardous wastedetermination? Have you kept therecords of test results, waste analysis,or other determination?

■ Are you operating and maintainingyour facility in a manner to minimizethe possibility of hazards throughabatement of potential fire, explo-sions, safety hazards, and potentialreleases? Are you providing adequatemaintenance and repair of yourequipment and structures so you arein compliance with state and localfire, electrical and building codes, andsafety codes?

■ Are you controlling, containing,cleaning up, and properly disposing ofany and all releases of hazardouswaste?

■ Have you developed and are youmaintaining and posting the requiredemergency contact information nextto your telephone?

■ Are you filing your Annual Reportand paying your registration andgeneration fees?

The above are things that inspectorstypically find facilities not doing whenthey go on inspections—don’t be caughtin violation.


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

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

APPENDIX B—EPA AND

OTHER FEDERAL RESOURCE CENTERS

EPA Region 9 / Hazardous Waste Management Div.75 Hawthorne StreetSan Francisco, CA 94105Phone: (415) 947-8708Library: (415) 744-1510www.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,hazardous waste, and underground storage tanks. Alsocan be used to find and order EPA publications.

Small Business Ombudsman Clearinghouse/HotlineU.S. EPA / Small Business Ombudsman (1230C)401 M Street SWWashington, DC 20460Phone: (800) 368-5888Fax: (703) 305-6462Helps private citizens, small businesses, and smallercommunities with questions on all program aspectswithin 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 (ac-cessible by any PC equipped with a modem) dedicatedto information on pollution prevention.

WHERE TO GET MORE HELP

Your business may also be regulated by othersections of the Code of Federal Regulations

(CFR). You may want to investigate the followingCFRs:

■ 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 (49 CFR Parts 171-

180)

APPENDIX A—STATE

HAZARDOUS WASTE MANAGEMENT ASSISTANCE

For further assistance in understanding thehazardous waste rules applicable to you,

or your compliance with them, contact:

Arizona Hazardous WasteInspections & Compliance UnitArizona Dept. of Environmental Quality1110 W. Washington St.Phoenix, AZ 85007(602) 771-4108 or (800) 234-5677

Or call the Facility Assistance Unit, ComplianceAssistance Program. The ADEQ Compliance Assis-tance program is a free, non-regulatory assistanceprogram created to help small businesses understandand follow hazardous waste regulations, and identifypollution prevention opportunities that may savemoney and reduce liability. Businesses can receivenon-regulatory assistance ranging from answeringquestions over the phone to individual facility visits.The Compliance Assistance Program can be contactedat (602) 771-4235; toll free (800) 234-5677.

To obtain the regulations, statutes, and rules referredto in this publication, contact the following or checkout the Web site listed.

Code of Federal Regulations: Contact the GovernmentPrinting Office, (202) 512-1800; http://www.epa.gov/epacfr40/chapt-I.info/


HAZARDOUS WASTE REGISTRATION FEE INVOICE AND FACILITY ANNUAL REPORT FOR SQGS

This form is mailed in January to SQGs, LQGs, TSDFs, resource recovery facilities, andtransporters. It covers your registration fees for the current year and is based on the highestamount of hazardous waste you generated in any one month of the previous year.

HAZARDOUS WASTE FACILITY ANNUAL REPORT FOR CESQGS

This form is the annual report for CESQGs. Your status is based on the highest amount ofhazardous waste you generated during any one month in the previous year. It is also mailed inJanuary. CESQGs have no registration fees.

APPENDIX C: FORMS/INVOICES FROM THE HAZARDOUS WASTE SECTION


HAZARDOUS WASTE GENERATION FEE INVOICE

This form is also mailed to SQGs in January of each year. It covers the amount of hazardouswaste you generated in the preceding year.

HAZARDOUS WASTE MANIFEST RESUBMITTAL FEE INVOICE

This form is only used when a facility has an error on the manifests submitted to ADEQ.A $20 fee is charged on each incorrect manifest.


❐ ❐

❐ ❐

✃

1. Do you have documentation on the amount and kinds of hazardous wastethat 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 they filled out correctly?

7. Have they 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 handling requirements described in thisdocument?

12. Have you designated an emergency coordinator?

13. Have you posted emergency telephone numbers and the location of emer-gency 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?

❐ ❐

❐ ❐

❐ ❐

WORKSHEET 3

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❐ ❐

❐ ❐

YES NO

These questions are geared toward the federal requirements for SQGs but may be helpful forother hazardous waste generators. Use them to help prepare for a visit from a federal, state,or local agency.


Acute Hazardous Waste

Waste that is listed and even when managedproperly is extremely dangerous.

By-product

A material that is not one of the primary productsof a production process. Examples of by-prod-ucts are process residues, such as slags or distil-lation column bottoms.

Commercial Chemical Product

A chemical substance that is manufactured orformulated for commercial or manufacturing use.

Container

Any portable device in which a material isstored, transported, treated, disposed of, orotherwise handled.

Elementary Neutralization Unit

A tank, tank system, container, transport vehicle,or vessel (including ships) that is designed tocontain and neutralize corrosive waste.

Reclaimed Material

Material that is regenerated or processed torecover a usable product. Examples are therecovery of lead values from spent batteries andthe regeneration of spent solvents.

Recovered Material

A material or by-product that has been recoveredor diverted from solid waste. Does not includematerials or by-products generated from, andcommonly used within, an original manufactur-ing process.

Recycled Material

A material that is used, reused, or reclaimed.

Reused Material

A material that is employed as an ingredient in anindustrial process to make a product, or as aneffective substitute for a commercial product.

Spent Material

Any material that has been used and, as a resultof contamination, can no longer serve thepurpose for which it was produced without firstprocessing it.

Sludge

Any solid, semi-solid, or liquid waste generatedfrom a municipal, commercial, or industrialwastewater treatment plant, water supply treat-ment plant, or air pollution control facility,exclusive of the treated effluent from a wastewa-ter treatment plant.

Still Bottom

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

Tank

A stationary device designed to contain anaccumulation of hazardous waste that is con-structed primarily of nonearthen materials (e.g.,wood, concrete, steel, plastic).

Totally Enclosed Treatment Facility

A facility for the treatment of hazardous wastethat is directly connected to an industrial produc-tion process and that is constructed and operatedso as to prevent the release of hazardous wasteinto the environment during treatment. Anexample is a pipe in which waste acid is neutral-ized.

Toxicity Characteristic Leaching Procedure

(TCLP)

A testing procedure used to determine whether awaste is hazardous. The procedure identifieswaste that might leach hazardous constituentsinto groundwater if improperly managed.

Wastewater Treatment Unit

A tank or tank system that is subject to regulationunder either Section 402 or 307(b) of the CleanWater Act, and that treats or stores an influentwastewater that is hazardous waste, or that treatsor stores a wastewater treatment sludge that ishazardous.

DEFINITIONS


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