1ESC 504.RCRA

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Resource Conservation and

Recovery Act (RCRA)

1ESC 504

Text: Toxic Substances and Controls Guide2nd Edn.

Reading Assignment: RCRA: p 167-196

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Recovery Act (RCRA)

U.S. Code citation: 42 USC 6901 et seq

Regulation: 40 CFR 240-271

Federal Agency with Jurisdiction: EPA

Enacted 1976

Amended 1978, 1980, 1984, and 1988

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Recovery Act (RCRA)

What it Regulates and Why

Control solid waste disposal

Encourage recycling and alternative sourceof energy

Major emphasis on control of HazardousWaste

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Recovery Act (RCRA)

Law establishes a system which identifies

hazardous waste and track their generation,

transportation, and ultimate disposal Set standards for sites and state hazardous

waste programs

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Brief History of RCRA

In 70s only 10% of all HW was managed inan environmentally sound manner.

Threats posed by mismanagement:- accidental spills

transportation hazards

- illegal midnight dumping

- improper disposal at landfills- health hazards

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Waste generated in the early 1900s

- 500,000 metric tons

Waste Generated this decade

- over 279 million metric tons

Reason of increase:

- industrial revolution, WWII, Medical science,

Agriculture, population growth

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1970s Environmental Decade

1976 - Love Canal

1980s hazardous waste leading issue

1990s hazardous waste accounted for 50%

of the $8.2 billion -consulting market

Estimate for 2020- $30 Trillion

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Where does RCRA fit On the Regulatory Scheme?

TSCAFIFRAFFDCA

Waste byproductlaws:

RCRACAA

CWASDWA

OSHAHMTA

RCRA

CERCLA

CradleHazardous Waste

Generation

HMTA

Grave

RIPRIP

RIPRIP

CAA

Transportation of

Hazardous waste

RCRA Landfill

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Evolution of RCRASOLID WASTE DISPOSAL ACT OF 1965

RESOURCE CONSERVATION &

RECOVERY ACT OF 1976

HAZARDOUS AND SOLID WASTE

AMENDMENTS OF 1984

FEDERAL FACILITY COMPLIANCE

ACT OF 1992

LAND DISPOSAL PROGRAMFLEXIBILITY ACT OF 1996

SWDA

RCRA

HSWA

FFCA

LDPFA

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Major Subtitles of Act

Subtitle B: Solid Waste and Resource

Recovery

Subtitle C: Hazardous Waste Management Subtitle E: New technologies and new

markets for recycled materials

Subtitle I: Regulation of UndergroundStorage Tanks (USTs)

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What is involved in the management

of Hazardous waste

HW Identification

Recycling/ Universal

wastes Generators

Transporters

TSDFs

Permitting

Corrective Action

Land Disposal

Restrictions Enforcement

Authorizing states to

implement RCRA

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RCRA: Major Provisions

The major provisions in the law for the control of

toxic chemical waste are:

1. Section 3001: identifies and lists hazardouswaste and provides the provisions for the

regulation of small generators of small

quantities of hazardous waste.

2. Sections 3002 and 3003: Sets standards forhazardous waste generators and transporters.

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RCRA: Major Provisions

3. Section 3004: Sets standards for

facilities which treat, store and dispose

hazardous waste. 4. Section 3005: Provides permitting

standards for hazardous waste facilities.

5. Section 3007, 3008: Providesenforcement of standards.

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Subtitle C Regulations

Cradle-to-Grave management of

hazardous Waste

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Definition of Hazardous Waste

A waste is a hazardous waste if it:

Is not excluded under 6621.4 or 25143.2

Exhibits a characteristics found in Article 3

Is a listed in Article 4

Is a mixture of a waste and hazardous waste

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Hazardous Waste Identification Process

Is material a solid

waste?

Is waste excluded from

the definition of solidor hazardous waste

Is waste a listed or

characteristic waste?

Is waste delisted?

Material is Not

subject to RCRA

Subtitle C Regulation

Waste is subject to RCRA

Subtitle C Regulation

No

No

No

No

Yes

Yes

Yes

Yes

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Hazardous Waste Determination

Questions to Ask:

1. Is material a waste

2. Is it excluded 3. Is Material a Hazardous Waste

4. Is it listed

5. Does it exhibit a characteristic of hazardouswaste

6. Is it excluded or exempted

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Determination of Hazardous Waste

Is it a Waste?

A material which has been used or

otherwise served it intended purpose and,for whatever reason (contamination, being

spent, or simply intent) can or will no

longer be used for its intended purpose.

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Exempted Waste

Household waste

agricultural waste

mining overburden

waste characterization samples

treatability samples

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Excluded Wastes

Spent CFC refrigerant

used oil filters

used oil (recycled)

domestic sewage

Industrial waste discharge

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Listed Wastes

F series wastes- non-specific sources

- most common

examples are spent

solvents

- material must be used

or spent

K series wastes

- specific sources

- applies primarily to

industrial processes

P wastes- acutely toxic

- dangerous at very

small quantities

U Wastes

- toxic waste

- other characteristics ignitable

reactive

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Listed Wastes

F series wastes

HW from non-specific sources

most common examples are spent solvents

material must be used or spent

Designated with a 4-digit code beginning with

an F

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Listed Wastes

K series wastes

HW from specific sources

applies primarily to industrial processes U and P wastes

Discarded commercial chemical products ,

containers residues and chemical products Designated with a four digit code beginning

with U or P

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Characteristic Waste

Ignitability- a liquid w/flash point less than 60 C (140F)

except for aqueous solutions containing less

than 24 % alcohol- a non-liquid capable of causing fire

- a substance that burns vigorously

- an ignitable compressed gas- an oxidizer per HMTA regulations

- Designated as D001

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Characteristic Wastes

Corrosivity

An aqueous with pH less than 2 or more

than 12.5 a liquid that corrodes steel at a rate

greater than 6.35 mm (.25 inch) per year

at 55 C. Designated as D002

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Reactivity

Normally unstable, undergo violent change

without detonating

Reacts violently with water

forms potentially explosive mixture with

H2O

Generates toxic gases, vapors, fumes

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will detonate at standard temp and pressure

Generates toxic gases, vapors, fumes

will detonate at standard temp and pressure listed by HMTA as a class A or B explosive

Designated as D003

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Toxicity

according to TCLP

include:heavy metals

volatile organic compounds (VOCs)

pesticides

Designated as D004 through D043

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Section 3002, 3003

Generator and Transported Standards

This section establish the regulation which

specifies the duties of generators and

transporters of hazardous waste Generators Defined:

Any person or firm who creates or produces

a hazardous waste or first brings it into theRCRA subtitle C system.

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Generator Classification

Large Quantity Generators (LQG) Generates over 1000 Kg hazardous waste/

calendar month or

Generates over 1 kg of acutely hazardouswaste

Storage requirements: 90 days

Can accumulate up to 6000 kg at any time

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Small Quantity Generators (SQG)

- Generates between 100 and 1000 kg hazardous

waste/ calendar months or- Up to 1 kg of acutely hazardous waste/ calendar

month

- Storage requirements: 180 days (230 days if

transportation to TSDF is over 200 miles away)

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Conditionally Exempt Small QuantityGenerators (CESQG)

Generates less than 100 kg hazardous waste/

calendar monthOr less than 1 kg of acutely hazardous waste /

cal month

Currently exempt from regulation provided that

Treatment of hazardous waste is done atlicensed facility

Above requirements are met

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Generator Requirements

1. EPA I.D. number: Generators must apply for

permit within 90 days of beginning operation.

2. Labeling: must use appropriate containers and

labels as specified by DOT

3. Manifesting waste: Use of Registered haulers

4. Record-keeping

5. Waste Reduction

6. Onsite requirements

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Transporters Requirement

1. EPA I.D.

2. Manifest

3. Registration: Haulers are required to

have minimum of 1 Million Liability

Training

4. Drivers have to be trained

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Transporters Requirement

5. Certification of Vehicles

6. Comply with DOT rules on reportingdischarges and spills

7. Clean up any waste discharged duringtransportation.

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Section 3004: Treatment Storage

and Disposal Facilities (TSD)

Any place which stores hazardous waste for

more than 90 days or offsite needs a permit.

Two types of permits Part A. (Interim Status Document):

Under RCRA, you have to have both A and B

permitting. Part A allows existing facility to operate while

going through part B.

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Treatment Storage

and Disposal (TSD) Facilities

Part B (Final Permit): the 1986 HSWA

amendment came into effect and found that

only 6 facilities have permit.

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Section 3004: TSD Facilities

General Facility Requirements:

Analyze waste entering facility to assure

identity Provide Security

Train Employees

Take special precautions to preventaccidental reactions etc.

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Maintain accessible and operatingemergency equipment etc.

Inform police and local emergency responseteam about layout of facility and hazardsthey may encounter

Have a written plan for responding to

emergencies and an emergency coordinatorto handle such situations

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Manifest, Record Keeping and Reporting

Operator must sign and date manifest andreturn a copy to transporter and generatorwithin 30 days.

Waste that arrives without a manifest mustbe reported within 15 days.

Records of type, quantity and how waste istreated must be kept.

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Operating Criteria:

Must monitor groundwater

Monitor waste medical

Other requirements

1. Tanks: Tanks should have secondary

containment , valves, and other controls.

2. Landfills (Land bans) 3. Storage facilities

4. Ponds

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Section 3005: Facility Permits

Section requires that any facility that treats,

stores, or disposes wastes must obtain

permit from EPA, or from relevant state(authorized state).

EPA reviews permit applications andinforms public about application.

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Section 3005: Facility Permits

If EPA decides to grant permit, it must

inform public and schedule time for public

notice, comment, and sometimes hearing. Once issued permits are effective for 10

years.

Permits are reviewed every five years andfacilities inspected every two years

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Section 3007, 3008: Facility

Enforcement

Enforcement of RCRA is carried out by

States, EPA and DOT.

DOT monitors transporters and Shippers ofhazardous wastes.

EPA uses compliance orders, administrative

orders, and consent decrees to enforcecompliance with the law.

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Section 3007, 3008: Facility Enforcement

EPA is also authorized to enter sites to

inspect for compliance, collect samples of

waste, and examine and copy records towaste.

Civil penalties up to $25,00 per day areauthorized for missing compliance deadline.

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Section 3007, 3008: Facility Enforcement

EPA also can issue corrective orders to facility

under interim status if a release of hazardous

waste occurs.

Failure to meet corrective order deadlines can also

result in civil penalties up to 25,000/day

Penalties for knowingly violating provisions of

law may result I penalties of up to $50,000/adyand /or up to two years in jail

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Subtitle I: Underground Storage Tank

This subtitle provides for the regulation ofunderground storage tanks that containpetroleum or other regulated substances.

The program exempts residential tanks,septic tanks, and tanks regulated under otherlaws.

Tanks under this amendment must meetcertain technical performance standards.

1ESC 504.RCRA

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