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RCRA RCRA (Resource Conservation and Recovery (Resource Conservation and Recovery Act)Act)

1965 SWDA, Solid Waste Disposal Act 1976 RCRA law Major amendments in 1980, and 1984 Subtitle D, solid waste (non-hazardous)

Administered by States Subtitle C is the hazardous waste law.

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Slide show courtesy of Williams Petroleum

copyright.

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A Compliance Guide to RCRA

ON-SITE WASTE ON-SITE WASTE MANAGEMENTMANAGEMENTON-SITE WASTE ON-SITE WASTE MANAGEMENTMANAGEMENT

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The Federal Resource Conservation and Recovery Act

1976 (1984) to protect environment from solid waste contamination

Authorizes EPA to regulate hazardous wastes from cradle to grave

Including:generation – transportation– storage – treatment– disposal

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RCRA regulates facilities under three generator categories

Conditionally Exempt Small Quantity Generators (CESQGs)

– Generates less than 100 kg (220 lb.) of hazardous waste per month

Small Quantity Generators (SQGs)– Generates between 100 kg/month and 1,000

kg/month Large Quantity Generators (LQGs)

– Generates more than 1,000 kg/month Different quantity limits exist for acutely hazardous waste

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Classifying then Profiling... When classifying a waste, six questions need consideration:

– 1.) Is the material a waste?– 2.) If yes, is it a hazardous waste?– 3.) If yes, is the hazardous waste listed in the

regulations?– 4.) Does the waste exhibit a hazardous

characteristic?– 5.) Is the hazardous waste specifically excluded or

exempted from regulation?– 6.) Does the waste fall into any other special

categories?

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Question #1. Is the material a waste?

RCRA considers a waste to be any solid, liquid, or contained gaseous material that is discarded by being disposed of, burned or incinerated, or recycled.

Wastes can be a byproduct of a manufacturing process or simply a commercial product used in business.

Some wastes are categorically exempted from RCRA's definition of a waste. These exemptions are usually due to the waste already being regulated under other statutes.

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Examples of materials considered to be wastes,

but exempted, include: sewage that is carried through a sewer system to a publicly owned treatment works

Industrial waste discharges monitored under the federal Clean Water Act's National Pollutant Discharge Elimination System (NPDES)

Regulated nuclear and radioactive wastes Irrigation return flows

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Question #2. Is it a hazardous waste?

RCRA Definition of a HAZARDOUS WASTE:– A solid waste - or a combination of solid wastes - that,

because of its quantity, concentration, or physical, chemical, or infectious characteristics, may:

Cause, or significantly contribute to, an increase in mortality or an increase in a serious irreversible illness, or incapacitating, reversible illness; or

Pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of, or otherwise managed.

This definition is vague. Regulations implementing RCRA help clarify this.

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There are only two types of hazardous wastes:

Listed Wastes Characteristic Wastes

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A waste is considered to be hazardous if it appears on one of four lists published in the Code of Federal Regulations.

Question #3. Is the Question #3. Is the Hazardous Waste Listed in Hazardous Waste Listed in

the RCRA Regulations?the RCRA Regulations?

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RCRA listed wastes are subdivided into F, K, P, and U wastes.

F Wastes - Hazardous waste from nonspecific sources K Wastes - Hazardous waste from specific sources U Wastes - discarded commercial products, off-

specification chemicals, and container and spill residues of commercial chemical products.

P Wastes - Same as U wastes except are classified as acutely hazardous due to their acute toxicity or reactivity

Listed wastes can be petitioned by a generator to the EPA to be delisted.

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Look at lists in regs You have these four lists, see

Submodule 3B.

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Question #4 Does the Waste Exhibit a Hazardous

Characteristic?

RCRA establishes four criteria for evaluating hazardous wastes:

– Ignitability– Reactivity– Corrosivity– Toxicity

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Question #5 Is the Hazardous Waste Specifically Excluded or

Exempted from Regulation?

Fed. Regulations contain several exclusions from the classification of waste as hazardous - even if the waste exhibits hazardous characteristics.

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Some exclusions from classifying waste as hazardous include:

Household Wastes Agricultural wastes returned to the soil as fertilizers

Mining overburden that is returned to the mine site

Cement kiln dust Most Oil Production Wastes (drilling fluids, process waters, etc.)

Many others

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Recycling exemptions and exclusions

EPA carefully regulates recycling of industrial wastes by both encouraging recycling and discouraging schemes devised to avoid RCRA

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Question #6 Does the Waste Fall into Any Other Special

Categories?

Acutely Hazardous Wastes - more stringent management required Household Hazardous Wastes - voluntary collection programs Universal Wastes - less stringent requirements Mixtures of Hazardous and Nonhazardous Wastes

– When listed wastes are mixed, all is hazardous waste– characteristic wastes can, many times, be mixed to eliminate

the characteristic hazard Used Oil exempt from RCRA if it:

– is not RCRA ignitable, not mixed with listed waste, is recycled

Variances - can seek individual ruling from the state agency

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Requirements for the Small Quantity and Large

Quantity Generators

Requirements are intended to ensure safe onsite handling of wastes, avoidance of excessive waste accumulation and the ability of EPA to monitor waste from cradle to grave

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Identification number Generator must obtain an EPA identification number by using the "Notification of Hazardous Waste Activity" form

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Waste Handling, Storage, and Labeling

Can be stored in many types of containers providing they are compatible with material being stored

Must be labeled within 24 hours of generation

Containers must be stored in arrangements conducive to inspections

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Waste Accumulation Limitations

LQG may not hold haz waste onsite for more than 90 days

SQG can not hold haz waste for more than 180 days

SQG can hold haz waste for 270 days if waste must be transported more than 200 miles

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Satellite Accumulation The clock starts ticking the day after most hazardous waste is generated

Satellite accumulation areas can be designated and not regulated until 3 days after the container is full.

55 gallon max. (1 quart max for acute)

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Personnel Training LQG must train personnel within 6 months of hiring

training must include:– routine handling– emergency spill response– annual refresher training

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Emergency Management LQG must engage in prevention and preparedness activities with respect to their wastes

SQG's and LQG's must have a designated trained emergency coordinator onsite or on call at all times

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Waste MinimizationWaste Minimization

RCRA requires SQG's and LQG's to certify on each signed manifest that they have made efforts to minimize the generation of hazardous waste

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EPA and DOT use different names for the same entity

DOT EPA

Shipper Generator

Carrier Transporter

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Shipping Wastes for Treatment or Disposal

Generator must package and label the hazardous waste according to DOT rules

Specific procedures for use of manifest during transport

Important for generator to choose competent transporters and TSDFs

(TSDF = Transportation, Storage and Disposal Facilities)

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Land Disposal Restrictions LDR program requires waste be treated to reduce hazardous constituents to EPA set levels

(We’ll Talk about LDR when we discuss treatment. )

TSDF must receive an LDR notice from generator for each shipment.

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Uniform Hazardous Waste Manifest

Multi-copy shipping form used to track shipments and effectively respond to spills

must accompany each hazardous waste shipment (Also, see next submodule.)

All parties involved must sign and date (and keep copy on file for three years)

States may define wastes differently - know where the waste is going

International shipments have different requirements (Alaska shipments often go through Canada.)

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Reporting and Record Keeping

Generator must maintain records for 3 years for:

– manifests, chemical analyses, inspection reports, biennial reports

Land disposal restriction documentation must be maintained for 5 years

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Transporter Requirements Must have EPA ID number Must not accept hazardous waste from a generator w/o manifest

Retain copies of manifest for three years Comply with DOT Be able to respond to spills Provide training to employees

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RCRA Hotline

EPA's telephone hotline to help generators comply with the many complex aspects of the RCRA hazardous waste program.

1-800-424-9346