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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
Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved
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
Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved
Hazardous Waste Regulatory Program Overview
Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved
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
Hazardous Waste Regulatory Program Overview
Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved
Hazardous Waste Regulatory Program Overview
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
Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved
Hazardous Waste Regulatory Program Overview
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"
Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved
Basic Requirements of Hazardous Waste Generators
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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?)
Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved
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
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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
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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
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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
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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
Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved
EPA’s Definition of Solid Waste (40 CFR 261.2)
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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”
Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved
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
Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved
““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
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““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
Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved
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
Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved
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
Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved
Solid Waste/Hazardous Waste Determinations (40 CFR 261.3)
Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved
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))
Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved
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)
Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved
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
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“Hazardous Wastes from Non-Specific Sources” (40 CFR 261.31)
““F-List”F-List”
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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.
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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
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“Hazardous Wastes from Specific Sources”
(40 CFR 261.32)
““K-List”K-List”
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Process Wastes from Specified Industries
Wood PreservationWood Preservation Inorganic PigmentsInorganic Pigments Organic ChemicalsOrganic Chemicals Inorganic ChemicalsInorganic Chemicals PesticidesPesticides ExplosivesExplosives
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Process Wastes from Specified Industries
Petroleum RefiningPetroleum Refining Iron & SteelIron & Steel Primary CopperPrimary Copper Primary LeadPrimary Lead Primary ZincPrimary Zinc Primary AluminumPrimary Aluminum
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Process Wastes from Specified Industries
FerroalloysFerroalloys Secondary LeadSecondary Lead Veterinary PharmaceuticalsVeterinary Pharmaceuticals Ink FormulationInk Formulation CokingCoking
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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”
Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved
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)
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Mostly Natural and Synthetic OrganicsMostly Natural and Synthetic Organics Listings Include Spill ResiduesListings Include Spill Residues
U-List
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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
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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
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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
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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)
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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.
Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved
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
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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
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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)
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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
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When Does a Solid Waste Become a Hazardous Waste?
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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….
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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
Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved
Regulatory Categories
Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved
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.
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Regulatory Categories
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
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Standards For Generators(40 CFR 262)
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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)
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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
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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)
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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
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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).
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Preparedness and Prevention(40 CFR Part 265, Subpart C)
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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
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Preparedness and Prevention
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)
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Preparedness and Prevention
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
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Contingency Plans(40 CFR Part 265, Subpart D)
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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
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Personnel Training(40 CFR 265.16)
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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?
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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.
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Requirements for 100-1000 Kg/Month Small Quantity Generators
(40 CFR 262.34(d))
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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
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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
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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
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Satellite Accumulation(40 CFR 262.34(c))
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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.
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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.
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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.
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A Practical Approach to Land Disposal Restrictions (40 CFR 268)
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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
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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.
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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.
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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).
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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.
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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
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Generator Requirements
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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
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Eight Elements for LDR Compliance
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.
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Eight Elements for LDR Compliance
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.
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EPA/DOT Regulatory Requirements
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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
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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
Generators Shipping Hazardous Wastes Off-Site
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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.
Generators Shipping Hazardous Wastes Off-Site
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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.
Generators Shipping Hazardous Wastes Off-Site
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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
Generators Shipping Hazardous Wastes Off-Site
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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.
Generators Shipping Hazardous Wastes Off-Site
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