1. science
2. ecology
3. waste management
4. waste disposal

CHAPTER 1
POLLUTION PREVENTION
AND
HOW TO AVOID PROBLEMS
3
CRADLE TO GRAVE
Did you know that you always retain some liability for the hazardous
waste you generate? This “cradle to grave” responsibility continues even
if the waste was shipped to an approved recycling, treatment or disposal
facility. You may still become a responsible party to a cleanup if your
waste contributes to contamination of the environment. You may make
your hazardous waste problem more manageable, reduce your costs and
help keep our environment clean and safe by institutionalizing pollution
prevention in your business. To reduce your liability you should reduce
the amount of hazardous waste you generate, develop methods of
reclaiming or recycling your hazardous waste on-site, or assure that your
hazardous waste is properly managed when disposal is necessary.
Your business probably generates hazardous waste if it uses the following
materials:
b
b
b
b
b
A
Pesticides or other chemicals
Dyes, paints, thinners, solvents, cleaning
fluids, or coolants
Oil or other petroleum products
Materials that bum or itch on contact with skin
Materials that dissolve metals, wood, paper, or
clothing
Flammable materials
Materials that bubble or fume upon contact
with water
Products delivered with a shipping paper or
label indicating that the product is hazardous
PRACTICAL TOXIC USE AND HAZARDOUS WASTE REDUCTIO>
Pollution prevention is the best approach for most handlers of hazardou
material and generators of hazardous waste to reduce their liabilitj
While the elimination or reduction of all wastes may not be currentl:
feasible, the following are some simple steps to get you started ii
pollution prevention.
Invento1-y Management:
t
Make an inventory of the raw materials your
process uses and determine which have
hazardous characteristics.
b
Ask yourself whether the hazardous
materials can be substituted with nonhazardous materials.
t
Purchase fewer hazardous and more nonhazardous products.
t
Purchase only what you need and avoid
ending up with out-of-date or offspecification chemicals that require disposal.
t
Tightly cover and properly store chemical
containers.
Process Modiji’cafion;
t
Use more non-toxic chemicals as raw
materials.
t
Modify processes to reduce hazardous
emissions and waste generation (i.e. reduce
the flow of water in cleaning operations,
replace water cleaning with mechanical
methods, or install closed-loop systems for
recycling processed waste waters or waste
streams).
F
Improve the efficiency of equipment operation.
F
Perform regular preventive maintenance on
equipment.
w
Involve employees and get feedback from
them.
Volume Reduction:
F
Do not mix hazardous with non-hazardous
waste. Hazardous waste mixed with nonhazardous waste requires managing the
entire waste stream as hazardous.
Recmei-y and Reuse:
F
Recover and recycle hazardous waste onsite.
F
Reuse waste in the process.
F
Participate in a materials exchange program.
WastelMaterials Exchange:
b
Remember pollution prevention can save
money.
F
A network of waste/materials exchanges
exists throughout the country. By contacting
a waste/materials exchange, your waste may
be listed in a publication that is circulated to
other generators, recyclers and waste
brokers. If a business can use your waste,
you will be contacted through the exchange.
CHAPTER 2
HAZARDOUS MATERIALS
AND
HAZARDOUS WASTE
7
RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
In 1976 the U.S. Congress enacted the Resource Conservation and
Recovery Act (RCRA) to protect public health and the environment from
improper management of hazardous waste. It placed “cradle to grave”
responsibilities on generators. In 1986, the EPA Office of Technology
Assessment (OTA) estimated that 10 percent of the hazardous waste
stream was being improperly disposed of by generators of greater than
220 but less than 2,200 pounds of hazardous waste per month. Some of
these hazardous wastes were going into landfills without leachate
collection systems or liners. As this waste mixed with household
hazardous waste, it began leaching into surrounding areas. Many
landfills were deemed high priority cleanup sites under Superfund.
Almost half of Superfund sites are old landfills.
Hazardous waste causes other problems. Disposal into sewer systems can
upset the bacterial activity and can poison the sludge so that it cannot be
land applied. Other hazardous waste mismanagement causes air pollution
and fire hazards.
Congress decided these problems warranted hazardous waste
management regulation for generators of smaller amounts of hazardous
waste. The Hazardous Solid Waste Amendments (HSWA) were added to
RCRA in November 1984. This brought Small Quantity Generators
(SQGs), who produce greater than 220 but less that 2,200 Ibs. of
hazardous waste per calendar month, under regulation.
K
I
WHAT IS A HAZARDOUS MATERIAL?
A hazardous material is a solid, liquid,
or contained gas material with certain
properties that could pose dangers to
human health, property, or the
environment.
WHAT IS A HAZARDOUS WASTE?
A waste is any solid, liquid or contained gaseous material that you nc
longer use, and either throw away, recycle, or store until you have enough
to treat or dispose of. A waste that poses a threat to human health or the
environment is called a hazardous waste. Hazardous'wastes are material5
that are either listed or characteristic.
For r-egulatoiy purposes, hazardous wastes are
categorized in two ways:
b
b
Listed hazardous wastes
Characteristic hazardous wastes
LISTED HAZARDOUS WASTES
Listed hazardous wastes can be broken into four categories: non-specific
process waste streams, process-specific waste streams, discardec
commercial chemical products, container residues or spill residues. P
listed waste is listed among the approximately 400 substances thc
Environmental Protection Agency (EPA) has determined to be hazardous
To obtain information about these substances the State reference is R3 15.
2- 10, the Federal reference is 40 CFR 261.3 1, 261.32, 26 1.33.
The following is a partial list of “listed” hazardous wastes.
Many spent halogenated solvents and
mixtures of these solvents used as
cleaners/degreasers: methylene chloride,
perchloroethylene (perc), trichloromethane,
trichlorethylene. See Appendix 1 for “F”
listed wastes.
b
Many other waste cleaners/ strippers:
acetone/butyl alcohol, carbon disulfide,
cresol, ethyl acetate, methyl ethyl ketone
(MEK), methyl isobutyl ketone (MIBK),
methyl (wood) alcohol, toluene, xylene. (See
Appendix 1)
b
Residues (still bottoms) from stills or any
other system used to recover spent solvents.
Most wastes from electroplating operations:
cleaning/stripping tank solutions, plating
bath solutions and sludge, and sludge from
pretreatment of wastewater from this
process.
b
b
1n
Certain wastes from the heat treatment of
metals.
b
Wastes produced during specific manufacturing
processes including manufacturing of certain
chemicals, explosives, inks and pigments,
petroleum refining, and steel finishing
(pickle liquor).
b
Many out-of-date commercial products are
listed as hazardous wastes; aniline, certain
antibiotics, arsenic compounds, formaldehyde,
hydrofluoric acid, hydrogen sulfide, lead
compounds, mercury compounds, naphthalene,
many nitrogen compounds, many pesticides.
pentachlorophenol (penta), phenols and
pyradine. This list includes more than 200
chemicals.
b
Certain pesticide wastes.
w
Any residue or contaminated soil, water or
other debris resulting from the cleanup of a
spill into or on any land or water, or any
residues that are federally-listed hazardous
wastes.
11
CHARACTERISTIC WASTES
Characteristic hazardous wastes exhibit certain properties that make them
harmful to human health and/or the environment. These properties are:
Zgnituhility (state reference R 3 15-2-9(d))
A liquid is considered ignitable if it has a “flash point” below 140 degrees
E A solid is considered hazardous if it can spontaneously catch fire and
burn so persistently that it presents a hazard.
1.
Ignitable
The waste material is a liquid (other than an
aqueous solution containing less than 24%
alcohol) and has a flash point of less than
140 F.
The waste material is a solid of gas and is
capable, under standard pressure, of causing
fire through friction, absorption of moisture,
or spontaneous combustion.
The waste is a oxidizer as defined in 49 CFR
173.151.
The hazai.dous waste code is DO01
Coi-imii,iry(state reference R3 15-2-9(e))
Any water-based waste having a “ph” (the unit used to describe the
strength of an acid or caustic) less than or equal to 2.0, or greater than or
equal to 12.5, is considered corrosive.
Any liquid that can corrode steel at the rate of 1/4” per year also is
classified as corrosive.
’
2.
Corrosivity
The waste material must be liquid and have
a pH of less than or equal to 2.0 or greater
than or equal to 12.5.
The waste is a liquid which corrodes steel at
a rate greater than 0.25 inches per year.
The hazardous wuste code is 0002.
Reactivity (state reference R3 15-2-9(f))
Unstable or explosive wastes, or wastes that react violently when broughl
into contact with water are considered reactive. Wastes that release toxic
vapors, such as hydrogen cyanide or hydrogen sulfide, also are reactive.
3.
Reactivity
The waste material is reactive to water,
shock, heat or pressure and undergoes a
rapid or violent chemical reaction. Some
examples are perchlorates, peroxides, and
cyanides.
The hazardous waste code is 0003.
Toxicity Cha~acteiistic(statereference R3 15-2-9(g) and Federal 40 CFR
261.24, Table 1)
Wastes that release certain amounts of toxic metals, solvents or othei
materials when subjected to a specific laboratory procedure are known as
toxicity characteristic (TC) wastes. If a lab sample of waste exceeds
these levels, the waste is toxic, and therefore is considered hazardous
Refer to the following table for toxic materials subject to toxicitj
characteristic testing.
4.
Toxicity Characteristic (TC)
This category includes eight heavy metals
and thirty-two organic chemicals including
ten pesticides.
The hm>ebeen assigned codesfr-om 0004 to
0043.
13
EPA HW
CODE
TOXIC
CONSTITUENT
REGULATORY
LEVEL ppm
DO04
DO05
DO06
DO07
DO08
DO09
DO10
DO1 1
DO12
DO13
DO14
DO15
DO16
DO17
DO1 8
DO19
DO20
DO2 1
DO22
DO23
DO24
DO25
DO26
DO27
DO28
DO29
DO30
DO3 1
DO32
DO33
DO34
DO35
DO36
DO37
DO3 8
DO39
DO40
DO4 I
DO42
DO43
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Endrin
Lindane
Methoxychlor
Toxaphene
2,4-D
2,4,5-TP(Silvex)
Benzene
Carbon tetrachloride
Chlordane
Chlorobenzene
Chloroform
o-Cresol
m-Cresol
p-Cresol
Cresol
1,4-Dichlorobenzene
1,2-DichIoroehtane
1,l-Dichlorethylene
2,4-Dinitrotoluene
Heptachlor (and its epoxide)
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
Methyl ethyl ketone
Nitrobenzene
Pentachlorophenol
Pyridine
Tetrachlorophenol
Trichloroethylene
2,4,S-Trichlorophenol
5 .o
1.4
100.0
1.o
5.0
5 .o
0.2
1.o
5 .o
0.02
0.4
10.0
0.5
10.0
1.o
0.5
0.5
0.03
100.0
6.0
200.0
200.0
200.0
200.0
7.5
0.5
0.7
0.13
0.008
0.13
0.5
3 .O
200.0
2.0
100.0
5.0
0.7
0.5
400.0
2,4,6-Trichloropheno12.0
Vinyl Chloride
0.2
Acutelv Hazardous Wastes
Some wastes are considered to be “acutely hazardous.” These are waste!
that EPA has determined to be so dangerous in small amounts that the)
are regulated the same way as are large amounts of other hazardou:
wastes. Acutely hazardous wastes, for example, may be generated using
certain pesticides. They also include dioxin containing wastes.
If your business generates more than 1 kg (approximately 2.2 pounds) ol
acutely hazardous wastes in a calendar month or stores more than thai
amount for any period of time, you are subject to all of the regulations
that apply to generators that generate more than 1000 kilograms 01
hazardous waste per calendar month.
Excluded Wastes
Some solid wastes are excluded from regulation as a hazardous waste.
even though they may possess hazardous waste characteristics. The
exclusion depends on the type of the materials, and/or the waste
management method. Below is a partial listing of the most common
wastes that are generally excluded from being a hazardous waste.
b
b
b
b
b
b
Household hazardous waste
Intact used lead-acid batteries when destined
for off-site recycling
Used oil that has not been mixed with a
hazardous waste (such as a solvent) and is
properly recycled or used for energy
recovery
Household sewage
Residue in empty containers
Materials recycled on-site in a closed loop
process
ENVIRONMENTAL IMPACTS OF HAZARDOUS WASTE
There are a number of ways, besides accidental spills and improper
disposal-that hazardous wastes reach the environment.
Municipal Waste Landfills
Land disposal of hazardous waste has long been the first choice of
industry and businesses. Before the regulatory activities of the 1970’s,
most hazardous wastes from industry and businesses that could not be
discharged into rivers and streams were either dumped into municipal
landfills with household garbage, or they went into unlined landfills at the
industrial site.
Concerns began to rise as it became apparent that some wastes being
disposed of with ordinary garbage were dangerously reactive, flammable,
corrosive or toxic.
As a result of this discovery, regulations were developed to direct and
encourage hazardous waste generators to treat certain hazardous wastes
destined for landfills or to consider alternate disposal options. Many
landfill operators, either to comply with new regulations, or out of
concern for long term liability, restrict the wastes they will accept.
Liquids are of particular concern because of their ability to seep through
landfill liners with the potential of contaminating groundwater sources.
Sewer Systems1Wastewater Treatment Plants
Hazardous waste discharged to a sewage system may contain toxic
materials that adversely affect the treatment process at the sewage
treatment plant. These wastes can also degrade the collection system and
can pose a health threat to workers. Discharge of ignitable wastes have
the potential of causing an explosion in the collection system.
Streams and Rivers
Prior to regulations such as the Clean Water Act, many industries simply
discharged untreated wastes to streams and rivers. However, discharging
these wastes directly into waterbodies can pollute water supplies, can be
fatal to fish, and, over time, can negatively impact boating, swimming
and fishing. Hazardous wastes can also enter waterways indirectly as
runoff carrying hazardous materials enter storm drains. Recently
implemented storm water regulations require industries and
municipalities to review management and process practices so that the
potential for hazardous wastes to be picked up and carried off in storm
water is reduced.
I /
CHAPTER 3
HOW TO IDENTIFY WHETHER YOU ARE A
HAZARDOUS WASTE GENERATOR AND HOW
TO DETERMINE YOUR GENERATOR CATEGORY
WHO PRODUCES HAZARDOUS WASTE?
While hazardous wastes are generally associated with large industries, in
the State of Utah there are far more small businesses that are generating
hazardous wastes than there are large businesses.
What types of small businesses generate hazardous waste? The following
is a list of the typical kinds of hazardous wastes commonly generated by
specific businesses.
TYPICAL WASTE STREAMS GENERATED BY
SMALL OUANTITY GENERATORS
Type of
Business
Types of
Hazardous Wastes Generated
Building Cleaning & Maintenance Acids/Bases, Solvents
Chemical Manufacturers
AcidsIBases, Cyanide Wastes,
Heavy Metalsfinorganics,
Ignitable Wastes, Reactives,
Solvents
Cleaning Agents and Cosmetics
Acids/Bases
Heavy Metals/Inorganics,
Ignitable Wastes, Pesticides,
Solvents
Construction
Acids/Bases
Ignitable Wastes, Solvents
Educational & Vocational Shops
Acids/Bases
Ignitable Wastes, Pesticides,
Reactives, Solvents
Equipment Repair
Acids/Bases
Ignitable Wastes, Solvents
Formulators
Acids/Bases
Cyanide Wastes
Heavy Metalsfinorganics
Ignitable Wastes, Pesticides,
Reactives, Solvents
Funeral Services
Solvents, Formaldehyde
Furniture/Wood Manufacturing
and Refinishing
Ignitable Wastes, Solvents
Laboratories
Acids/Bases
Heavy Metals/Inorganics
Ignitable Wastes, Reactives,
Solvents
Laundries and Dry Cleaners
Dry Cleaning Filtration Residues,
Solvents
Metal Manufacturing
Acids/Bases, Cyanide Wastes,
Heavy Metals/Inorganics
Ignitable Wastes, Reactives,
Solvents, Spent Plating Wastes
Motor Freight Terminals and
Railroad Transportation
Acids/Bases
Heavy Metals/Inorganics,
Ignitable Wastes, Lead-Acid
Batteries, Solvents
Other Manufacturing:
1)Textiles
2)Plastics
3)Leather
Heavy Metals/Inorganics
Solvents
Pesticide End Users and
Application Services
Heavy Metalsflnorganics
Pesticides, Solvents
Printing and Related Industries
Acids/Bases
Heavy Metalsflnorganics
Ink Sludges, Spent Plating Wastes
Solvents
Vehicle Maintenance
Acids/Bases
Heavy Metalsflnorganics
Ignitable Wastes, Lead-Acid
Batteries, Solvents
Wood Preserving
Preserving Agents
in
HOW TO DETERMINE IF YOUR BUSINESS
IS A REGULATED HAZARDOUS WASTE GENERATOR:
Generator category is determined in t ~ v
Mlays:
b
b
Volume of hazardous waste produced per month,
or
Volume of hazardous waste stored on site at
any one time.
It is the responsibility of the business that generates a waste to determine
whether the waste is hazardous.
Many businesses do not think they “generate” hazardous waste because
their operations do not involve an industrial or manufacturing process.
However, hazardous wastes may be generated when:
b
b
A material has been used and is spent, such
as used solvent,
or
A stored material has exceeded its shelf life,
is no longer usable and must be discarded.
For example, a construction company will not generate the types of
hazardous wastes commonly associated with an industrial process, but it
may generate hazardous waste in the form of discarded paints and
solvents or other materials, and thus would be classified as a hazardous
waste generator.
HAZARDOUS WASTE GENERATORS FALL INTO THREE
CATEGORIES DEPENDING ON THE AMOUNT OF WASTE
GENERATED IN ONE MONTH OR THE AMOUNT OF WASTE
STORED ON THE SITE AT ANY ONETIME.
1. YOU ARE A CONDITIONALLY EXEMPT SMALL QUANTITY
GENERATOR (CESQC), IF...
In one calendar month you.. .
generate less than 2.2 pounds of acutely
hazardous wastes, or
generate less than 220 pounds of hazardous
wastes. or
generate less than 220 pounds of spill
cleanup debris containing hazardous waste,
and
.
hazardous waste accumulated on-site never
exceeds 2,200 pounds.
31
SPECIFIC WASTE MANAGEMENT REQUIREMENTS FOR
CONDITIONALLY EXEMPT SMALL QUANTITY GENERATORS
CESQG’s are not regulated in the same way as large producers of
hazardous waste. Still, they have a responsibility to manage hazardous
waste properly.
A CESQG may treat its hazardous waste as per Utah Department of
Environmental Quality regulations in an on-site facility or ensure
delivery to an off-site treatment, storage or disposal facility. The off-site
management facility must be:
b
a designated hazardous waste management facility; or
F
a designated recycling facility; or,
b
a facility permitted to take municipal or industrial solid
waste. Please note: solid Mwste mana,qement facilities
have cotitla1 over what types cf nwstes they will accept.
SOLID WASTE FACILITIES ARE NOT ALLOWED TO
ACCEPT LIQUIDS FOR DISPOSAL. Whet? in doubt,
contact the landfill operator. Many facility operators
rvstr-ict disposal i f all types of haxi-dous waste at their
facilities. YOU SHOULD HAVE THE APPROVAL OF
THE RECEIVING FACILITY TO LEAVE YOUR WASTE
THERE!
CESQGs are not required to have an EPA Identification Number, but
most transporters and disposal facilities will not accept hazardous waste
without an EPA Identification Number and a proper hazardous waste
manifest.
22
2. YOU ARE A SMALL QUANTITY GENERATOR (SQG) IF. ..
In one calendar month you ...
b
generate more than 220 pounds and less than
2,200 pounds of hazardous wastes, or
F
generate more than 220 pounds and less than
2,200 pounds of spill cleanup debris
containing hazardous wastes, and
b
never accumulate more than 6000 kg of
hazardous waste on-site.
3. YOU ARE A LARGE QUANTITY GENERATOR (LQG) IF. ..
In one calendar month you...
F
generate 2,200 pounds or more or hazardous
waste. or
F
generate 2,200 pounds or more or spill
cleanup debris containing hazardous waste,
or
F
generate more than 2.2 pounds of acute
hazardous waste, or
generate more than 220 pounds of spill
cleanup debris containing an acute
hazardous waste. or
F
At any time you ...
b
accumulate more than 2.2 pounds of acute
hazardous waste on-site DETERMINING
YOUR GENERATOR CATEGORY
Since the regulations for each of the hazardous waste generator categories
are different, it is important to be aware of changes in the quantity of
waste you produce for any one calendar month, and how any changes
may effect your compliance requirements.
33
How to find out your generator category:
1.
Determine the type and maximum amount of hazardous waste
generated in one calendar month. When measuring the
amount of hazardous waste generated, include the following:
w
Waste accumulated prior to recycling,
transporting, storing, treating or disposing.
b
Waste transported off-site for treatment,
storage, disposal or recycling.
w
Waste recycled on-site.
w
Waste from &Iprocesses.
2.
Once you have calculated the total amount of hazardous waste
produced in one month, refer to the generator status
classifications.
3.
Utah DEQ bases a generators’ category on the largest amount
of hazardous waste generated during a month. For example, if
a business produces more than 220 Ibs but less than 2200 Ibs of
hazardous waste in a singe month, that business will be
considered a SQG and must comply with appropriate rules. If,
during the following month, that business produces over 2200
lbs of hazardous waste that business will be considered a LQG
and is subject to the rules governing LQG’s.
Although UDEQ reporting requirements are biannual, it is
recommended that a generator comply with rules relative to the
largest quantity of hazardous waste generated within a two year
period.
Benefits of ProDer Hazardous Waste Management
Beyond reducing environmental risks, proper management of hazardous
waste makes good business sense. Here are some of the benefits of a
sound hazardous waste management program:
w
Reduced Economic Liability
Improper disposal of hazardous waste can lead to verj
costly cleanups. Under Federal law, businesses are liablc
for clean up of improper hazardous waste disposal
The economic
hazardous waste spill and/or releases.
burden of such liability can be minimized, if not altogethei
avoided, through good waste management techniques.
w
Reduced Insurance Costs
Many insurance companies require an environmental audi
of businesses before issuing policies. A compan)
practicing responsible waste management may qualify foi
lower insurance rates. On the other hand, if a company ha!
sloppy management practices, or if they are unable tc
account for all of their waste activity, they may be charge(
higher rates, or in some cases, may be refused coverage.
w
Muinfcncrnre ?f P m p e i q Value
A property with known or suspected contamination fron
hazardous wastes can suffer serious loss of value, an(
lending institutions may hesitate to offer loans on sucl
properties.
w
Enhanced Public Image qf Business
Many customers prefer doing business with organization
that manage their hazardous wastes responsibly.
w
Minimized Worh-el.E.vposure
OSHA requires that certain workplace safety standards bl
followed. Proper hazardous waste management can reducl
worker exposure to chemicals.
Proper waste management makes sense not only from a regulator:
compliance standpoint, but it makes sense in terms of reducing risk tl
humans and the environment. It also makes good economic sense in tha
improper disposal of hazardous waste can result in expensiv
environmental remediation.
2
26
CHAPTER 4
HOW TO CONDUCT A HAZARDOUS
WASTE DETERMINATION
A hazardous waste detei-mination must he conducted
in order to identify the amount o j hazardous waste
y”‘busiJ?ess generates. Each solid M’aste must be
evaluated to determine if it is a hazardous waste.
This piwcess is called, “Hazai.dou.s Waste
Determination”. This chapter will outline the steps
you need to j d l o in
~~
order to complete the process.
27
WHAT ARE THE REQUIREMENTS FOR CONDUCTING A
HAZARDOUS WASTE DETERMINATION
It is the generator’s responsibility to determine if its waste is considered
hazardous under RCRA regulations. All generators of waste material are
required by law to identify and evaluate their wastes. This is called a
“hazardous waste determination”.
Because a hazardous waste determination is the foundation on which
proper hazardous waste management is built, failure to conduct a
hazardous waste determination is a very serious violation and may be
subject to a civil penalty of up to $10,000 per day. This is one of the
easiest violations to avoid and is the most common one found during
hazardous waste inspections.
A COMPLETE HAZARDOUS WASTE DETERMINATION
MUST ANSWER THE FOLLOWING QUESTIONS:
b
Is the solid waste being generated a hazardous waste?
w
If the waste is hazardous, what is (are) the correct
hazardous waste code(s)?
To answer these questions, a generator should do the following:
Step 1:
Check for Excluded Wastes
Determine if the generated waste is excluded. Specifically, does some
exclusion apply to the specific waste stream, refer to R315-2-4 of the
State rules.
Other areas of the hazardous waste regulations which should be checked
to determine whether a waste is exempt from regulation are R3 15-2-2,
R 3 15-2-3 and R315-2-6 of the State rules. Some examples of exclusions
are:
x Used oil not mixed with hazardous waste.
x
Lead acid batteries destined for off-site recycling.
Batteries and battery cells returned to the manufacturer for
regeneration.
Domestic sewage.
Wastes discharged into a publicly owned treatment work!
(POTW’s), provided the discharge is covered under :
UPDES or pretreatment permit.
Residue in RCRA defined “empty” containers.(State rule!
R3 15-2-7.)
Materials recycled in on-site closed-loop process
Step 2:
Check Hazardous Waste Lists
To help generators determine if their solid waste is a listed hazardou:
waste, EPA has developed lists of hazardous waste. A generator shoulc
compare both the waste generating process and the concentration of thc
hazardous constituent against these lists. The Utah rules R3 15-2-10 an(
11 reference the hazardous waste lists in 40 CFR parts 26 1.3I , 26 1.32 an(
26 1.22
b
Non-specific sources, R3 15-2- 10(e) and 40 CFR 26 1.3 1
(i.e. spent solvents from degreasing operations, FOOl, anc
waste water treatment sludges from electroplatinj
operations F006).
b
Specific sources, R315-2-10(f) and 40 CFR 261.32 (i.e
bottom sediment sludge from the treatment of waste water:
from wood preserving processes that use creosote and/oi
pentachlorophenol, KOOl).
b
Discarded commercial chemical products, containei
residues or spill residues there of (40 CFR 261 3 3 ) make ul
the “U” and “P” lists. The products on the “U” lists arc
called “toxic” wastes (i.e. vinyl chloride). Products on the
“P” list are called “acute hazardous” wastes (i.e. cyanide
and are subject to more rigorous controls than the othei
listed hazardous wastes. These wastes are so dangerous ir
small amounts that they are regulated the same way a:
large amounts of other hazardous wastes.
Remember: The process by which a waste is generated will
determine if the waste stream is or is not listed.
STEP 3 : Check for Hazardous Waste Characteristics
Remember that more than one waste code may apply to the waste stream
you are evaluating, so even if the waste is listed, you may need to identify
is as a characteristic hazardous waste. Therefore, determine if the waste
exhibits any of the following characteristics:
( 1)
lgnitahility
A liquid is considered ignitable if it has a “flash point” below 140 degrees
E A solid is considered hazardous if it can spontaneously catch fire and
burn so persistently that it presents a hazard. The hazardous waste code
is DO01 (State rules R315-2-9(d)).
(2)
Corrosiviry
Any water-based waste having a “ph” (the unit used to describe the
strength of an acid or caustic) less than or equal to 2.0, or greater than or
equal to 12.5, is considered corrosive.
Any liquid that can corrode steel at the rate of 1/4” per year also is
classified as corrosive. The hazardous waste code is DO02 (State rules
R3 15-2-9(e)).
(3)
Reactivity
Unstable or explosive wastes, or wastes that react violently when brought
into contact with water are considered reactive. Wastes that release toxic
vapors, such as hydrogen cyanide or hydrogen sulfide, also are reactive.
The hazardous waste code is DO03 (State rules R3 15-2-9(f)).
(4)
Toxicity Characteristic
Wastes that release certain amounts of toxic metals, solvents or other
materials when subjected to a specific laboratory procedure are known as
toxicity characteristic (TC) wastes. If a lab sample of waste exceeds
these levels, the waste is toxic, and therefore is considered hazardous.
These have been assigned codes from D004-D043. State rules R3 15-29(g) which reference 40CFR 261.24 Table # I .
KNOWLEDGE OF PROCESS/ANALYSIS
In general, there are two methods for performing a hazardous waste
determination. The first, “knowledge of process”, makes the use of
available information to make the determination. The second analysis.
relies on the testing of the waste to determine the presence of hazardous
constituents.
Knowledge of process, analytical data and/or a combination of these form
the basis by which all hazardous waste determinations are completed.
Knowled<geof Process
The more information available concerning the waste stream, the easier a
hazardous waste determination will be to complete. Useful sources of
information include:
1.
Material Safety Data Sheet (MSDS) for product information.
2.
Your supplier/manufacturer or vendor.
3.
Product labels.
Note: Waste stream may differ greatly from original products.
4.
Description of the process generating the waste stream. The
process may determine if the waste is or is not listed. Compare
product information with the listed wastes and hazardous waste
characteristics in 40 CFR 261.3 1, 32 and 33, State rules R3 152-10.
5.
Trade associations and/or corporate headquarters. Your trade
association can be a good source of information on hazardous
waste management practices. It can provide assistance in
handling, packaging, and labeling your waste.
Some
associations publish periodic newsletters which include
information on proper hazardous waste management.
Someone else in your industry may have already completed the
determination. Caution: Industry A & B both make widgets
but they make them by different processes, therefore one
company’s waste determination may not apply to another
company’s.
.
21
File ull documentation regarding hazardous waste determinations.
If you have completed a hazardous waste determination based on
knowledge of process, be sure to document all sources of information you
used to reach this determination. File this information with your
hazardous waste determination records. Records should be
maintained for as long as the waste is generated and three years after
it is no longer generated.
Analyzing Your. Wustrs
You may not have enough information to complete a “knowledge of
process” hazardous waste determination for all your waste streams. Your
only alternative is to take a sample and have a Utah certified commercial
testing laboratory test your waste.
Reducinn the Cost qf Testing Your Waste Stream
You can use your knowledge of the process to limit laboratory testing.
You should ask the lab to perform only those tests needed to determine
the hazardous characteristics. (Testing will not determine if the waste is
listed; the process in which the waste is generated will determine if the
waste is listed.) The cost of analysis will depend upon the complexity of
these tests. You can reduce your analytical costs by providing the
laboratory with as much information as possible on the constituents of the
waste.
DETERMINING THE AMOUNT OF HAZARDOUS WASTE
YOUR COMPANY GENERATES
An important part of the Hazardous Waste Determination is to determine
the amount of a particular waste you generate.
The generator must determine the total amount of hazardous waste
produced in a calendar month and the total volume of hazardous waste
stored. If the hazardous wastes generated from all sources add up to more
than 220 pounds (or there are more than 2,200 pounds stored on-site a
any time). The SQG must manage them according to RCRA rules anc
regulations.
Wastes You DO Count
To determine the correct generator status, each generator is required t c
count the following:
b
Any wastes that have been stored on-site before treatmen
or disposal, or accumulated prior to recycling, includinz
hazardous waste accumulating in satellite accumulatior
containers.
b
Wastes that are packaged for off-site transport.
b
Wastes going into RCRA regulated disposal or treatmeni
facilities.
b
Wastes treated or managed on-site in accordance witt
UDEQ regulations (unless exempt)
Wastes You Do NOT Count
b
Wastes recycled in a closed-loop system.
b
Wastes stored in exempt wastewater treatment unit tanks.
b
Wastes generated in a manufacturing unit prior to remova
(i.e. sludge in a vapor degreaser would not be counted unti
the sludge was removed from the vapor degreaser).
b
Used oil that has not been mixed with hazardous waste
provided the used oil is recycled or burned for energq
recovery.
32
34
b
Spent lead acid batteries sent off-site for reclamation.
b
Waste that was already counted in the month and was
recycled or treated on-site.
F
Residue in the bottom of “empty” containers.
b
Scrap metal going for recycling.
b
Used batteries returned to a battery manufacturer for
regeneration.
b
Any waste stream that has an exclusion.
CHAPTER 5
HOW TO MANAGE AND STORE HAZARDOUS WASTE
PROPERLY
Ini-entolying, acumulating, piqm'iiig emei'gency
procedui.es a i d preparedness plans, and properstorage and handling are all part of good xraste
management practices. This chapter uill describe
these practices plus many other munugement
r~equirementsfor small quantity hazardous waste
genei-ators.
I
CATEGORIES OF HAZARDOUS WASTE GENERATORS
Generators of No
More than 100
kg/mo
~
100- 1000 kg/mo
Generators
Generators of 1000
kg/mo or More
If you generate more
than 100 and less
than 1000 kg
(between 220 and
2200 pounds or
about 25 to under
300 gallons) of
hazardous waste and
no more than 1 kg of
ac U t e 1y hazardous
waste in any month,
you are a 100-1000
kg/mo generator and
the federal hazardous
waste laws require
you to coniply with
the I986 rules ,for
nianaging hazardous
Mlaste, includiiig the
accumulation,
ti-eutnient,storagc,
and disposal
i'rquiivnieiits
de.sc~r.ibedin this
hunclbook.
If you generate 1000
kg (about 2200
pounds or 300
gallons) or more of
hazardous waste, or
more than lkg of
acutely hazardous
waste in any month,
you are a generator
of 1000 kg/mo or
more and the federal
hazardous waste
laws require you to
cornply Miith all
applicable hazurdous
w m t e management
1xles.
. . . . . . . . . . . . . . . . . . . .
If you generate no
more than 100
Kilograms (about
220 pounds or 25
Gallons) of
Hazardous Waste in
any Calendar month,
you are a
conditional1y-exempt
small quantity
generator and the
federal hazardous
waste laws require
you ne\w
ucuniirlute mol-e
thun 1000kg (f
hazardous M u t e on
your. pr.oper'ty. ( I f you
do, you become
subject to all the
1-equirenionts
applicuble to 100I000 kglrno
geneintoix e.vplaincd
in this handbook.
ManaginP Hazardous Waste in Containers
R315-5-10 of the State rules (40CFR 262.34(a),(d) and subpart I of 4C
CFR 265)
When handling and storing hazardous waste, establish good
housekeeping practices to avoid possible spills. Follow these waste
management practices:
b
A container must be marked with the date that waste was
first put in that container (unless the container meets the
requirements of satellite accumulation where it does no1
need to be dated until full.
b
A container must be marked with the words “Hazardous
Waste” (unless the container meets the requirements 01
satellite accumulation, in which case it must be marked in
a manner that identifies the waste).
Containers must be in good condition, handled carefullj
and replaced if leaking occurs.
b
Containers must be taken off-site or recycled on-site as pel
Utah Department of Environmental Quality’s regulations
depending on the distance the waste is transported to its
treatment, storage or disposal facility (TSDF).
b
Containers must not be used to store hazardous wastes i j
the waste may cause the container to rupture, leak, corrode
or otherwise fail.
b
Containers must be compatible with the hazardous waste
stored in them and must meet Department 01
Transportation (DOT) standards.
b
Containers holding hazardous waste must be closed excepl
when being filled or emptied.
b
Containers must be inspected at least weekly for leaks and
signs of corrosion. An inspection log should be kept.
F
Containers which are holding incompatible wastes must be
stored separately.
b
Incompatible wastes should not be placed in the same
container unless done so in accorrdance with 40 CFR Par1
265.17 (b).
15
ManaginP Hazardous Waste In Tanks
R315-5-10 of the State rules (40CFR 262.34(a) and subpart J of 40 CFR
265)
Rather than store hazardous waste in containers, you may choose to use
storage tanks. To safely manage hazardous waste storage tanks, they
must:
b
Not be used to store hazardous wastes if the wastes can
cause the tank to fail. For example, incompatible wastes
must not be placed in the same tank.
b
Be kept covered; or in uncovered tanks, have at least two
feet of freeboard.
b
Be inspected weekly for leaks or corrosion and daily for
any monitoring of gauging systems.
Additional
requirements apply to underground tanks, check with the
State DEQ for specifics.
b
Be marked the words “Hazardous Waste”.
b
Be in compliance with the National Fire Protection
Associations (NFPA) buffer zone requirements for tanks
containing ignitable or reactive wastes.
These
requirements specify distances considered as safe buffer
zones for various liquids.
b
Be taken off-site or recycled on-site as per Utah
Department of Environmental Quality regulations.
b
Waste must be maintained in a manner which prevents
reactive and ignitable wastes from reacting or igniting.
Remember: A SQG can never generate more than 2,200 pounds per
month ( approximately 280 gallons) and remain a SQG. A tank can
exceed these limits very quickly.
Note: A SQG is ,lot required by /OM’ to ha1.e secotzdaiy containment ,forhazardous u,aste storage tanks. A s a safety precaution, DEQ stimgly
r.ecomniend~ that atiy SQG using tanks for. storage or treatment of
haxrzlous nwste iiistall secondary containnzent for those tanks. An ounce
of protection may he )$vi.th thousands of dollars in cleanup costs.
Local fire codes may require secondary containment.
18
Hazardous Waste Storape Areas
DEQ recommends that hazardous waste storage areas be constructed t
include:
b
A solid base that will hold leaks, spills, and any rainfa
until they are discovered and removed. Cement surface
should be sealed to prevent their contamination.
b
A drainage system to separate containers from rainwatt
and/or spillage.
b
A holding area large enough to contain a spill amounting t
the volume of the largest container, or 10 percent of th
total volume of all containers, whichever is greater.
b
If possible, the storage area should be covered, curbed, c
bermed to prevent run-on and run-off.
Treating or ManapinP Hazardous Waste On-Site
SQGs may treat their own hazardous wastes without a permit undc
certain conditions.
b
Treatment takes place within an accumulation tank c
closed container(s).
b
Wastes are treated within 180 days.
b
Containers and tanks meet RCRA regulations.
b
Modified contingency plan is prepared and followed.
If the business does not meet each of these four requirements and trea
hazardous wastes on-site, it must obtain a RCRA hazardous was1
treatment permit.
A business may not dispose of its hazardous waste on-site unless it h:
obtained a TSDF permit - an involved, costly, and time consumin
process. The process is described in R3 15-3 of the State rules.
3
Satellite Accumulation Areas tSAA)
R315-5-10 of the State rules [40 CFR 262.34 (c)(i) and (c)(2)].
The purpose of the satellite accumulation rule is to allow the generator the
ability to store “slowly accumulating” hazardous waste at or near the
point of generation for time periods greater than those which apply to
generator shortage.
When handled properly, satellite accumulation can be an important
element of a successful waste management plan.
Advantages to Satellite Accumulation
b
There is no accumulation time limit on
wastes being stored in a SAA.
w
The container need not be dated until 55
gallons of hazardous waste have been
generated.
w
Avoid excessive cost associated with
managing small amount of hazardous waste.
The Elements of Successful Satellite Accumulation
A generator claiming that a hazardous waste is being accumulated in a
satellite accumulation area MUST meet the following elements.
Accumulation Limits:
b
N o more than 55 gallons of hazardous waste
or
b
One quart of acute hazardous waste.
Storage of these wastes must be:
40
b
At or near the point of generation.
b
Under the control of the operator of the
process generating the waste.
b
Containers must be labeled to identify its
contents or with the words “Hazardous
Waste”.
b
Containers must remain closed except when
being added to or removed.
When hazardous waste is accumulated in excess ‘of the generatio
limits, the generator must:
b
Remove any waste (generated in excess of
accumulation limits of 55 gallons or one
quart of acute hazardous waste) to the
facility’s hazardous waste storage area
within three days.
b
The container must be marked with the
words, “Hazardous Waste”.
b
The container must be marked with the date
the excess amount began accumulating.
Common SAA Violations:
b
Failure to keep the container closed except
when adding or removing hazardous waste
(i.e. a funnel in a SAA drum).
b
Failure to mark the drum with the words,
“Hazardous Waste” or other words
describing the drum’s contents.
b
The drum is not at or near the point of
generation (i.e. the SAA container is stored
in another room).
b
Accumulation of more than a total aggregate
of 55 gallons of hazardous waste without
removing the excess to the facility’s
hazardous waste storage area.
b
A full SAA drum (55 gallons) was not dated.
4
Disadvantages to Satellite Accumulation
b
Violate the satellite accumulation regulations
and a SQG could be cited for failure to date,
label and remove to storage area, a Class 1
violation.
f
l
s
:
As part of responsible management, DEQ recommends you maintain a
complete written record of any hazardous waste management activities
including any on-site treatment, the first date of accumulation, amount,
type and number of containers of each hazardous waste you generate.
Avoid Mixine Waste Streams
Place each waste type in separate containers. Do not mix different wastes
together because it can increase the cost of identifying, testing and
disposing of or recycling the contents. It may also increase your
generator status.
42
PREPARING FOR AND PREVENTING ACCIDENTS WITH
HAZARDOUS WASTE
These standards are required for owners and operators of hazardous waste
treatment, storage, and disposal facilities. These standards are
recommended standards for any company that deals with hazardou:
waste (State R315-5-10).
General Reauirements for hazardous waste:
b
Your business is to be maintained and
operated to minimize the possibility of fire,
explosion or any unplanned release of
hazardous waste or hazardous waste
constituents to the environment (40 CFR
26.5.31).
b
The owner or operator must maintain aisle
space to allow the unobstructed movement
of personnel and equipment to any area of
the facility in an emergency (40 CFR
26.5.35). A 55-gallon drum is approximately
24 inches in diameter. To remove a drum
using a dolly takes approximately 42 inches
of aisle space. Certain forklifts can operate
in less room; acceptable aisle space depends
on the type of response taken. However, 24
inches is a minimum aisle space that should
be maintained.
SDecific Reauired Eauipment
All facilities must be equipped with the following, unless none of thc
hazards posed by the waste handled at the facility could require sucl
equipment:
b
Internal communications or alarm system
capable of immediate emergency instruction
(voice or signal) to facility personnel (40
CFR 265.32(a)).
4.
~
AA
b
A telephone or similar communication
device immediately available at the scene of
operations or a hand-held two-way radio,
capable
of
summoning
emergency
assistance from local police, fire, state or
local emergency response teams (40 CFR
265.32(b)).
b
Portable fire extinguishes, fire control
equipment, spill control equipment, and
decontamination equipment (40 CFR
265.32(c)).
b
Water at adequate volume and pressure to
supply water hose streams or foam
producing
equipment, or automatic
sprinklers, or water spray systems (40 CFR
265.32(d)).
b
All facility communications or alarm
systems, fire protection equipment, spill
control equipment, and decontamination
equipment, where required, must be tested
and maintained as necessary to assure its
proper operation in time of emergency (40
CFR 265.33).
b
All persons involved in the handling
operation of hazardous waste must have
immediate access to either internal or
external alarm or communication equipment
(40 CFR 265.34(a)).
b
If there is ever just one employee on the
premises while the facility is operating,
he/she must have immediate access to a
device, such as a telephone (immediately
available at the scene of operation) or a
hand-held two-way radio, capable of
summoning external emergency assistance,
unless such a device is not required under 40
CFR 265.34(b)
Arranpements with Local Authorities
The owner or operator must attempt to make the following arrangements.
as appropriate for the type of waste handled at his facility and the
potential need for the services of these organizations (40 CFR 265.37(a)).
F
Arrangements to familiarize police, fire
departments, and emergency response teams
with the layout of the facility, properties of
hazardous waste handled and associated
hazards, places where facility personnel
would normally be working, entrances to
roads inside the facility, and possible
evacuation routes (40 CFR 265.37(a)( 1)).
b
When more than one police and fire
department might respond to an emergency,
agreements designating primary emergency
authority to a specific police and fire
department and agreements with any others
to provide support to the primary emergency
authority (40 CFR 265.37(a)(2)).
b
Agreements with state emergency response
teams, emergency response contractors, and
equipment suppliers (40 CFR 265.37(a)(3)).
b
Arrangements to familiarize local hospitals
with the properties of hazardous waste
handled at the facility and the types of
injuries or illnesses which could result from
fires, explosions, or releases at the facility
(40 CFR 265.37(a)(4)).
F
Where state or local authorities decline to
enter into such arrangements, the owner or
operator must document the refusal in the
operating record (40 CFR 265.37(b)).
RESPONDING IN THE EVENT OF AN ACCIDENT WITH
HAZARDOUS WASTE
Contingency Plans and Emergency Procedures are required of both large
and small quantity generators. Section R3 15-5-10 (40 CFR 262.34(a)(4))
outlines the requirements for large quantity generators and R3 15-5-10 (40
CFR 262.34(d)(5)) outlines the requirements for small quantity
generators.
Preparing a “Modified Contingency Plan”
A SQG is required to comply with 40 CFR 262.34(d)(4), 265 Subpart C
- Preparedness and Prevention, and 40 CFR 262.34(d)(5). These sections
form the basis of the SQG’s “modified contingency plan”. These
requirements are intended to ensure that your employees are adequately
prepared to handle hazardous waste and to respond to any emergencies
that might arise. This modified contingency plan does not have to be
written. However, a written plan is much easier to develop and
implement.
Personnel Training For Emergencv Procedures
All employees must be thoroughly familiar with proper waste handling
and emergency procedures specified in R315-5-10 of the State rules (40
CFR 262.34(d)(5)(iii). Workers should be trained and aware of
emergency procedures including:
’
A L
b
Location of telephone emergency numbers,
fire extinguisher, and spill control materials.
b
Evacuation routes and procedures to account
for employees.
b
Procedures for using, inspecting, repairing,
and replacing the emergency equipment.
b
Spill or release incident reporting (National
Response CenterEmergency Management
Division and UDEQ) and designated
reporter.
b
Procedures for employees who stay behind
for the shut-down of facility operations and
their evacuation.
CHAPTER 6
PREPARING FOR AND PREVENTING ACCIDENTS WITH
HAZARDOUS MATERIALS
A
PREPARING FOR AN ACCIDENT WITH
HAZARDOUS AND TOXIC MATERIALS
The Emergency Planning and Community Right-to-Know Act of 1986
established requirements for Federal, State and local governments and
industry regarding emergency planning and “community right-to-know”
reporting on hazardous and toxic chemicals. This legislation builds upon
EPA’s Chemical Emergency Preparedness Program (CEPP) and
numerous State and local programs aimed at helping communities to
better meet their responsibilities in regard to potential chemical
emergencies. The community right-to-know provisions will help to
increase the public’s knowledge and access to information on the
presence of hazardous chemicals in their communities and releases of
these chemicals into the environment. States and communities working
with facilities. will be better able to improve chemical safety and protect
public health and the environment.
The Emergency Planning and Community Right-to-know Act (also
known as SARA Title 111) has four major sections:
( 1) emergency planning (Section 301-303)
(2) emergency release notification (Section 304)
(3) community
right-to-know
reporting
requirements (Sections 3 I 1,312)
(4) toxic chemical release inventory (Section
313)
Emergencv Planning Sections 301-303
The emergency planning sections are designed to develop State and Local
governments‘ emergency response and preparedness capabilities through
better coordination and planning, especially within the local community.
SARA Title I11 requires that the Governor of each state designate a State
Emergency Response Commission (SERC). The SERC must designate
local emergency planning districts and appoint local emergency planning
committees (LEPC). The SERC is responsible for supervising and
coordinating the activities of the LEPC, for establishing procedures for
receiving and processing public requests for information collected under
other sections of SARA Title 111, and for reviewing local emergency
plans.
AQ
Planning activities of LEPCs and facilities should be initially focused on
but not limited to, the 360 extremely hazardous substances published ir
the Federal Register. Plans should be comprehensive, addressing a1
hazardous materials of concern and transportation as well as fixec
facilities. The list includes the threshold planning quantities (minimun
levels) for each substance.
Any facility that has present any of the listed chemicals in a quantitj
equal to or greater than its threshold planning quantity is subject to tht
emergency planning requirements.
Emewencv Notification Section 304
Facilities must immediately notify the LEPCs and the SERCs likely to bc
affected if there is a release into the environment of a listed hazardoui
substance that exceeds the reportable quantity for that substance
Substances subject to this requirement are those on the list of 36(
extremely hazardous substances as published in Federal Register (4(
CFR 355) or on a list of 725 substances subject to the emergenc!
notification requirements under CERCLA Section I03(a)(40CFR 302.4
Some chemicals are cammon on both lists.
Communitv Right-To-Know Reuuirements Section 311-312
There are two community right-to-know reporting requirements withir
the Emergency Planning and Community Right-To-Know Act. Sectioi
31 1 requires facilities that must prepare material safety data sheet
(MSDS) under the Occupationalsafety and Health Administratioi
(OSHA) regulations to submit either copies of their MSDSs or a list o
MSDS chemicals to the LEPC, SERC and the local fire department wit1
jurisdiction over the facility.
Reporting under Section 3 12 requires a facility to submit an emergenc:
and hazardous chemical inventory form to the LEPC, the SERC, and thi
local fire department with jurisdiction over the facility. Hazardou
chemicals covered by section 312 are those for which facilities art
required to prepare or have available an MSDS under OSHA’s Hazardou
Communication Standard and that were present at the facility at any timl
during previous calendar year above specified thresholds.
I
Toxic Chemical Release Reportinp Section 313
Section 313 of SARA Title 111 requires EPA to establish an inventory of
routing toxic chemical emissions from certain facilities. Facilities subject
to this reporting requirements are required to complete a Toxic Chemical
Release Inventory Form (Form R) for specified chemicals. The form
must be submitted annually.
The reporting requirement applies to owners and operators of facilities
that have 10 or more full-time employees, that are in Standard Industrial
Classification (SIC) codes 20 through 39 (i.e. manufacturing facilities)
and that manufacture (including importing) process or otherwise use a
listed toxic chemical in excess of specified threshold quantities.
EMPLOYEE RIGHT-TO-KNOW TRAINING
Employers in manufacturing industries must establish a written,
comprehensive hazard communication program which includes
provisions for container labeling, materials safety data sheets, and an
employee training program. The program must include a list of the
hazardous chemicals in each work area, the means the employer uses to
inform employees of the hazards of non-routine tasks (for example, the
cleaning of reactor vessels), hazards associated with chemicals in
unlabeled containers, and the way the employer will inform contractors in
manufacturing facilities of the hazards to which their employees may be
exposed.
cn
CHAPTER 7
SELECTING A TRANSPORTER, RECYCLER, OR A TSDF
Not all TSDFs, recyclers or transporters are
qualified to help you in all situations. Selecting the
propei- waste management compuny is the
genei-ator 's responsibility.
Is the Transporter a legal hauler of hazardous waste
Often times, hazardous waste must be transported to a TSDF for proper
disposal. State and federal laws require transportation to be completed
properly, as well as safely.
When selecting a transporter, confirm that the transporter has obtained a
DEQ/EPA identification number and proper liability insurance.
SelectinP a TSDF or Recvcler
A TSDF or recycler is authorized to handle only certain hazardous wastes
which are specified in its permit. Before you ship your waste to a TSDF
or recycler, make sure the company can accept it. As part of its
authorization, a TSDF agrees to comply with many stringent state and
federal requirement which may include: personnel training, contingency
plan, financial assurance, facility closure, groundwater monitoring,
emergency equipment, arrangement with local authorities, container
storage, tank storage, and waste analysis plans.
Carefully select the TSDF or recycler you will be using. You may check
their compliance background with the appropriate agency (Utah
Department of Environmental Quality Division of Solid and Hazardous
Waste, DEQ, or the EPA). In addition, where possible, visit their sites.
Remember the generator’s cradle to grave responsibilities.
CHAPTER 8
OBTAINING A U.S. EPA IDENTIFICATION NUMBER AND
MANIFESTING REQUIREMENTS
EPA has developed a pupei- trucking system to follnn,
hazaizlous waste *%.om the c m d l e to the g i u i ’ e ” ,
called the “unifoi-mman$est” . Proper completion of
a manifest is crucial to knowing M>hatkind and how
much hazaizlous waste is being ti.ansported, as well
as where and when your waste was transpoi.ted.
OBTAINING A U.S. EPA IDENTIFICATION NUMBER
The three most important things
EPA ID number:
YOU
should know about obtaining your
b
Call the Utah Department of Environmental
Quality, Division of Solid and Hazardous
waste at 538-6170 or EPA regional office to
get a notification form.
b
Fill out the form and sign it.
b
Send the form to the Utah State Department
of Environmental Quality, Division of Solid
and Hazardous Waste.
If your business generates more than 100 kg of hazardous waste in any
calendar month, you will need to obtain a U.S. EPA Identification
Number. Transporters and facilities that store, treat, or dispose of
regulated quantities of hazardous waste must also have U.S. EPA
Identification Numbers. These twelve-character identification numbers
used by EPA and states are part of a national data base on hazardous waste
activities.
To obtain your U.S. EPA Identification Number:
b
Call or write the Utah Department of Environmental Quality,
Division of Solid & Hazardous Waste or your EPA regional office
(Region 8 for those living in Utah) and ask for a copy of EPA Form
8700- 12, “Notification of Regulated Waste Activity.” You will be
sent a booklet containing a two page form and instructions for filling
it out. Figure 1 provides a sample copy of a completed notification
form to show you the kind of information required.
b
Fill in the form with the same kinds of information shown in the
sample form in Figure 1. This information covers your “installation”
(your business site) and your hazardous wastes. To complete Item X
of the form, you need to identify your hazardous waste by the EPA
hazardous waste number. Appendix B contains some common waste
types generated by small quantity generators, along with their EPA
hazardous waste numbers. If you do not understand the information
in Appendix B, or if you cannot match your wastes with those listed,
seek help from the Utah Department of Environmental Quality.
E A
b
Complete one copy of the form for each of your plant sites o
business locations where you generate or handle hazardous wastes
Each site or location will receive its own U.S. EPA Identificatior
Number.
b
Make sure your form is filled out completely and correctly and sigr
the certification in Item XI. Send the form to the Utah Department o
Environmental Quality. Please remember to keep a copy of the forn
for your own files.
This information will be recorded by EPA and the state, and you will bi
assigned a U.S. EPA Identification Number. This number will be uniqui
to the site identified on your form. Use this number on all hazardou
waste shipping papers.
The U S . EPA Identification Number will stay with the business site o
location. If you move your business to another location, you must notif
EPA or Utah Department of Environmental Quality of your new locatio
and submit a new form. If hazardous waste was previously handled at th
new location, and it already has a U.S. EPA Identification Number, yo
will be assigned that number for the site after your have notified EPA an
Utah DEQ.
SEPA
WHY SHOULD HAZARDOUS WASTE
BE SHIPPED OFF-SITE
Disposal of hazardous waste from a SQG or LQG in sanitary landfills is
prohibited in Utah. One alternative is to ship the waste to a permitted
hazardous waste recycling, treatment, storage, or disposal facility
(TSDF). To ensure proper tracking, the EPA designed the “manifest
system” R31.5-4 of the State rules (40 CFR 262.20(a)). A LQG must
always use a manifest while a SQG can ship waste off-site without one
provided the following conditions are met:
b
You must have a written agreement with a recycler to
collect and reclaim specified waste and to deliver
regenerated material back to you on a specified schedule.
b
The recycler owns and operates the vehicle that is used for
transporting the waste and regenerated material.
b
Either you or the recycler must retain ownership of the
waste material.
b
You and the recycler must retain a copy of the contractual
agreement and a copy of each shipping document.
b
The shipping document is to include: the generator’s
name, address and DEQEPA identification number; the
quantity of waste; all DOT shipping information; and the
date waste was transported by the recycler.
Manifest Exemetion
No manifest is required if the SQG meets all of the above requirements
for shipment of hazardous waste to an approved recycler (R315-4 of the
State rules (40 CFR 262.20(e)).
REMEMBER: FAILURE TO COMPLY WITH ANY OF THE
ABOVE PROVISIONS VOIDS THE MANIFEST EXEMPTION.
DEQ RECOMMENDS THE USE OF THE UNIFORM
HAZARDOUS WASTE MANIFEST FOR ALL SHIPMENTS OF
HAZARDOUS WASTE.
-
When hazardous wastes are shipped off-site, the packaging and labeling
of these wastes must meet the U.S. Department of Transportatior
shipping requirements. The generator may rely upon the producl
manufacturer, or the transporter for packaging and labeling information
The transporter may also provide packaging of the waste as part of the
transportation cost. Specific packaging and labeling requirements art
listed in R315-5-9 of the State rules (49 CFR Parts 171-179).
Each container must display the appropriate diamond shaped DOT label
These labels correspond to DOT Hazardous Material Classifications
Flammable, Corrosive, Reactive, and Toxic.
lgnmhility
roi-ro\I
\'I[)
Reactivity
Tiru1c1~
PLEASE NOTE: only the <qeiierator.m i i modify the niaiiif'est. If' tht
ti-unspoi-tei.iieeds to add u ti-nnspoi.tei-this cuii only he dime hy rweii1iiij
un okuy foi- the change fi-om the genei.atoi: Fui-thei-mow, if the TSDI
needs to modi& 01' change ariythirig o i i a mun$est, they must wcei\>t
appivvul j - o m the genet-atni: Bottom Line: The geneiutoi. is liable j o J
uny pi-ohlems "ith the manvest and thei-efoi-e must appinve a1
infoiwation conruined on the maii$est.
A sample copy of a hazardous waste manifest has been filled out for yoi
on the following page. When you sign the certification in ITEM 16 yoi
are personally confirming that:
F
The manifest is complete and accurately describes thc
shipment.
F
The shipment is ready for transport.
b
You have considered whether, given your budget. you
waste management arrangements are the best to reduce thl
amount and hazardous nature of your wastes.
I
UNIFORM HAZARDOUS
WASTE MANIFEST
1 Generator's US EPA ID No
U.T.D.1.2.3.4.5.6.7.8.9
Manifest
Document No
o.o.o,o~
2. Page 1
Df
1
Information in the shaded areas is
not required by Federal law.
A. State Manifest Document Number
B. State Generator's ID
6.
5. Transporter 1 Company Name
US EPA ID Number
C. State Transporter's ID
U.T.D.5.4.3.2.1.0.9.8.7
WASTE TRUCKING, INC.
D. Transporter's Phone
US EPA ID Number
7. Transporter 2 Company Name
(801 ) 999-3210
E. State Transporter's ID
F. Transporter's Phone
G State Facility's ID
:I
WASTE DISPOSAL, INC.
I
..
N
H. Facility's Phone
( 8 0 1 ) 888-1234
U.T.D.9.8.7.6.5.4.3.2.1
E 11 US DOT Description (Includmg Proper Shppmg Name, Hazard Class, and ID Number)
n
1
".'
,
IHhAl
'
A a'
T
0 b.
R
C.
HAZARDOUS WASTE, SOLID, NOS
9 NA3077 PG 111
(TOLUENE, ACETONE)
.-.
0.0.1
.._..-.
D.M
0.0.2.0.0
FOIL?
F005
DO01
J Additional Descriptions for Materials Listed Above
K Handling Codes for Wastes Listed Above
(a) 501
15 Special Handling Instructions and Additional Information
EVERY SPILL, RELEASE OR INCIDENT INVOLVING ABC WASTE GENERATION’S WASTE
MUST BE REPORTED TO ABC WASTE GENERATION AT (801) 123-4567
16 GENERATORS CERTIFICATION: I hereby declare that the contents of this consignmentare fully and accurately described above by proper shipping name and are classified packed marked
and labeled, and are in all respects in proper condition for transport by highway according to applicable international and national governmental regulations
If I am a large quantity generator I certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined tobe economically practicable anc
that I have selected the practicable method of treatment storage or disposal currently available to me which minimizesthe present and future threat to human health and the environment OR,
if I am a small auantitv aenerator I have made a aood faith effort to minimize mv waste aeneration and select the best waste manaaement method that is available to me and that I can afford
PrintediTyped Name
JOHN DOE
Signature
~ o h Doe
n
Month
77
I
Day
22
I
Year
92
17 Transporter 1 Acknowledgement of Receipt of Materials
Printednyped Name
Month
77
JANE DOE
PrintediTyped Name
Signature
Month
Day
I 22
Day
Year
I
92
Year
20. Facility Owner or Operator: Certification of receipt of hazardours materials covered by this manifest except as noted in item 19.
PrintediTyped Name
DAVE SMITH
Signature
Dave Smith
0RIGINAL-RETURN TO GENERATOR
Month
77
Day
Year
I 27
I 92
States, haulers, recyclers, and designated facilities may require additional
information; check with them before you prepare a hazardous waste
shipment. Your hazardous waste hauler often will be the best source for
packaging and shipping information and will help in completing the
manifest. EPA has also prepared some industry-specific information to
help you in completing the manifest. This industry-specific information
is available from EPA Regional Offices and a number of trade
associations. If you have any trouble obtaining, filling out, or using the
manifest, ask your hauler, your designated facilityoperator, Utah
De artment of Environmental Quality or Region 8 EPA for help.
Fe era1 regulations allow you to haul your hazardous waste to a
designated facility yourself. You must, however, obtain an EPA
transporter identification number and comply with applicable DOT
requirements for packaging, labeling, marking, and placarding your
shipment. There are also financial responsibilities and liability
requirements for transporting hazardous waste.
a
If you decide to transport your own hazardous wastes, call the Utah
Department of Environmental Quality to find out what state regulations
apply to you. You should also note that if you have an accident during
transport, you are responsible for the clean-up.
CHAPTER 9
DISPOSAL RESTRICTION REQUIREMENTS
EPA has determined that certain hazardous
wastes can no longer he land disposed. Wastes
so identiJi:edby EPA are termed Land Disposal
Restricted (LDR).
LAND DISPOSAL RESTRICTION REQUIREMENTS
On November 8, 1988, SQG’s wastes became regulated under R315-13
of the State rules (40 CFR part 268) land disposal restrictions. Land
disposal regulations require both LQG’s and SQG’s to:
Determine whether any of the wastes generated are subject
to land disposal restrictions.
Test or otherwise evaluate wastes to determine if they
exceed the concentration levels specified in the rules.
Obtain interim status for storage over 90 days for LQG and
180 days for SQG. This would only apply to newly listed
waste streams. This is allowed in very limited cases.
Observe prohibitions and controls on dilution or mixing of
restricted wastes.
Complete the notification requirements for wastes
exceeding the treatment standards.
Complete the certification requirements for wastes meeting
the treatment standards.
Comply with applicable packaging and manifesting
requirements.
In order to determine whether a notification or certification is needed, the
small quantity generator must identify the EPA Hazardous Waste Code
number or numbers for the waste being sent off-site. This information is
also required to be put on the manifest. Identification can be based on
knowledge of the waste or on a waste analysis. After determining the
appropriate hazardous waste codes, the generator should compare these
codes to Tables 40 CFR 268.41, 268.42 and 268.43 to determine the
appropriate treatment standards.
CHAPTER 10
SPILL REPORTING AND CLEANUP
Proper management of hazardous waste hopefully
will prevent a spillfivni ever occwl-ing. However, if
a spill happens, you need to know what to do.
FEDERAL AND STATE LAWS
A spill or release may require reporting under several federal laws and
Utah law, including:
F
F
F
F
F
F
Utah Spill Reporting laws R3 15-9- 1 through R3 15-9-4.
Resource Conservation and Recovery Act (RCRA)
Hazardous Materials Transportation Act (HMTA)
Clean Water Act (CWA)
Comprehensive Environmental Response Compensation
and Liability Act (CERCLA)
Superfund Amendment Re-authorization Act (SARA) Title 3
The Congressional intent is to have the Reportable Quantity (RQ) of a
hazardous material be the same under all the Acts. However, there may
be a lag time before all RQ levels are made uniform under all the Acts.
Also, chemicals appearing on one Act’s list may not be found on another.
For example, 130 of the 370 SARA Title 3 extremely hazardous
substances may be found in the CERCLA hazardous substance list of 721
chemicals which have reportable quantities in case of a spill. The
remaining 240 extremely hazardous substances not found on the
CERCLA list have a reportable quantity level and, in the case of spills,
must be reported under Title 3. If an emergency coordinator referred to
the CERCLA list and did not find the chemical listed with a reportable
quantity. the coordinator would be in compliance with CERCLA by not
reporting the spill. However, the coordinator would be in non-compliance
with emergency notification requirements under Title 3 provisions.
Immediate Action
As stated in R315-9-1 of the State Rules, in the event of a spill of
hazardous waste or material which, when spilled, becomes hazardous
wastes, the person responsible for the material at the time of the spill shall
immediately:
(a)
(b)
Take appropriate action to minimize the threat to human health
and the environment.
Notify the Utah State Department of Environmental Quality, 24.hour Answering Service, 80 1-536-4 123 or 1-800-572-6400 if the
following spill quantities are exceeded:
(1) One kilogram of material listed in R3 I S-21 l(e), which incorporates by reference 40
CFR 261.33(e). Notify for a spill of a lesser
quantity if there is a potential threat to
human health or the environment; or
(2) One hundred kilograms of hazardous waste
or material which, when spilled, becomes
hazardous waste, other than that listed in
R3 15-2-1l(e), which incorporates by
reference 40 CFR 261.33(e). Notify for a
spill of a lesser quantity if there is a potential
threat the human health or the environment.
Provide the following information when reDorting a spill
(1)
(2)
(3)
(4)
(5)
(6)
(7)
Name, phone number, and address of person responsible for the
spill.
Name, title, and phone number of individual reporting.
Time and date of spill.
Location of spill - as specific as possible including nearest town,
city, highway or waterway.
Description contained on the manifest and the amount of material
spilled.
Cause of spill.
Emergency action taken to minimize the threat of human health
and the environment.
Within 15 days after any spill of hazardous waste or material which, when
spilled, becomes hazardous waste, and is reported under R3 15-9-I (b). the
person responsible for the material at the time of the spill shall submit tc
the Utah Department of Environmental Quality a written report which
contains the following information:
(1)
(2)
(3)
(4)
(5)
(6)
The person's name, address, and telephone number;
Date, time, location, and nature of'the incident;
Name and quantity of material(s) involved;
The extent of injuries, if any;
An assessment of actual or potential hazards tu human health 01
the environment, which this is applicable; and
The estimated quantity and disposition of recovered material thal
resulted from the incident.
note: All spills need to be cleaned up regardless of whether it was
reportable quantity or not.
I
2
C
CHAPTER 11
TIPS FOR STAYING OUT OF TROUBLE
The four most important things you should remember about
managing your wastes properly
I. Reduce the amount of you generate.
Conduct your O M W self-inspec~tion.
3. Cooperate Mith state an local inspectors.
4 . Call your state hazardous waste
management agency O I - the U S . EPA with
youi. questions.
-3.
Good hazardous waste management can be thought of simply as using
“good housekeeping” practices such as: Using and reusing materials as
much as possible; Recycling or reclaiming waste; Treating waste to
reduce its hazards; or Reducing the amount of waste you generate.
To reduce the amount of waste you generate:
b
Do not mix non-hazardous wastes with
hazardous ones. For example, do not put
non-hazardous cleaning agents or rags in the
same container as a hazardous solvent or the
entire contents become subject to the
hazardous waste regulations.
b
Avoid mixing several different hazardous
wastes. Doing so may make recycling very
difficult, if not impossible, or make disposal
more expensive.
b
Avoid spills or leaks of hazardous products.
(The materials used to clean up such spills or
leaks also will become hazardous.)
b
Make sure the original containers of
hazardous products are completely empty
before you throw them away. Use ALL the
product.
b
Avoid using more of a hazardous product
than you need. For example, use no more
degreasing solvent or pesticide than you
need to do the job. Also, do not throw away
a container with unused solvent or pesticide
in it.
Reducing your hazardous waste means saving money on raw materials
and reducing the costs to your business for managing and disposing of
your hazardous wastes.
Another aspect of “good housekeeping” is cooperating with inspection
agencies and using a visit by an inspector as an opportunity to identify
and correct problems. Accompanying state or local inspectors on a tour
of your facility will enable you to ask any questions you may have and
receive advice on more effective ways of handling your hazardous
products and wastes. In addition, guiding the inspectors through your
property and explaining your operations may help them to be more
sensitive to the particular problems or needs of your business. Inspectors
can also serve as a valuable source of information on the record keeping,
manifests, and safety requirements specific to your facility.
The best way to prepare for a visit from an inspector is to conduct your
own self-inspection. This handbook can serve as a basic guide to
developing a self-inspection checklist. Make sure you can answer
correctly the following questions, and make sure you have met the
requirements described in the handbook:
b
Do you have some documentation on the
AMOUNTS and KINDS of hazardous wastes you
generate and on how you determined that they are
hazardous?
Do you have a U.S. EPA IDENTIFICATION
NUMBER?
b
Do you S H I P waste OFF-SITE? If so, by
which HAULER and to which DESIGNATED
HAZARDOUS WASTE MANAGEMENT
FACILITY?
,-
b
Do you have copies of MANIFESTS used to ship
your hazardous waste off-site? Are they filled out
correctly?
Have they been signed by the
designated facility?
b
Is your hazardous waste stored in the PROPER
CONTAINERS?
w
Are the containers properly DATED and
MARKED?
w
H a v e you designated an EMERGENCY
COORDINATOR?
w
Have you posted EMERGENCY TELEPHONE
NUMBERS and the location of EMERGENCY
EQUIPMENT?
w
Are your EMPLOYEES thoroughly FAMILIAR
with proper waste handling and emergency
procedures?
6!
GLOSSARY OF DEFINITIONS
Acceptable Closed Conveyance Equipment: Refers to a situation
where reclamation operations are literally enclosed, or hard plumbed with
pipes to the unit that generates the waste. This may be allowed on a caseby-case basis under 40 CFR 260.3 l(b). Refer to Volume 5 1 of the Federal
Register, page 25442, July 14, 1986 for further discussion.
Accumulation: A generator may accumulate hazardous waste for a short
period of time before shipping it off-site. The waste must be accumulated
in either tanks or containers; it may not be accumulated in surface
impoundments.
*
Large Quantity Generators may accumulate
their waste for up to 90 days before shipping i t offsite.
*
Small Quantity Generators may accumulate
their waste for up to 180 days before shipping it
off-site. If the treatment, storage, disposal or
recycling facility (to which they send their waste)
is more than 200 miles away, they may accumulate
the waste for 270 days.
Acute Hazardous Waste: P-listed wastes found in 40 CFR 261.33(e).
These wastes are acutely toxic. Generation or storage of more than 2.2
pounds of these wastes makes a generator a large quantity generator.
Annual Hazardous Waste Reports: Beginning in 1992, all Small
Quantity and Large Quantity hazardous waste generators (as well as
TSDFs and off-site recycling facilities) must complete an annual report of
hazardous waste activities. This report is intended to cover activities of
the previous calendar year and is due March 1 of each year. The report
should include both on-site and off-site hazardous waste generator
activities.
C.A.S. Number: The Chemical Abstract Service (C.A.S.) Number
identifies toxic substances by a unique number.
711
CERCLA: Comprehensive Environmental Response, Compensation
and Liability Act also known as “Superfund”.
CFR: Code of Federal Regulations.
Closed-Loop Recycling System:
A production system in which
secondary materials are reclaimed, returned to, and reused in the original
production process or processes from which they were generated
PROVIDED:
1. Only tank storage is involved, and the entire
process through completion of reclamation
is closed by being entirely connected with
pipes or other comparable means of
conveyance;
2. Reclamation does not involve controlled
flame combustion (such as occurs in boilers,
industrial furnaces, or incinerators);
3. The
secondary materials are never
accumulated in such tanks for over twelve
months without being reclaimed; and
4. The reclaimed material is not used to
produce a fuel, or used to produce products
that are used in a manner constituting
disposal.
For the purposes of “closed-loop recycling”, degreasing processes are no
considered “production” processes, and the reclaimed degreasing solvent
when subsequently used as a degreaser, is not feedstock. Therefore, i
degreasing process would not fit the criteria for a closed-loop recycling
system.
7
Conditionally Exempt Generator(CEG): See definition of Generator
Status.
Container: Any portable device in which a material is stored,
transported, treated, disposed of, or otherwise handled.
DEQ: Utah Department of Environmental Quality.
DEQ/EPA Identification Number: The number assigned by EPA or
DEQ to each generator, transporter, and treatment, storage and disposal
facility. This ID number begins with :‘OR” and is followed by a letter and
9 digits.
Designated DEQ/EPA Facility: A hazardous waste treatment, storage or
disposal facility (TSDF) which :
I.
Has received a permit (or interim status) in
accordance with 40 CFR 270 and 124;
2. Has received a permit (or interim status)
from an authorized state in accordance with
40 CFR 271; or
3. Is regulated under 40 CFR 261.6(~)(2)or
subpart F of 40 CFR 270; and
4. Has been designated on a manifest by the
generator.
Designated Recycling Facility:
A facility that is designated on a
manifest by a hazardous waste generator, and that recycles hazardous
waste received from off-site, in units that are exempt from requirements
to obtain a RCRA permit for the management of hazardous waste.
Disposal: The discharge, deposit, injection, dumping, spilling, leaking,
or placing of any hazardous waste or hazardous substance into or on any
73
land or water so that the hazardous waste or hazardous substance or any
constituent thereof may enter the environment or be emitted into the air
or discharged into any water of the state.
EPA: United Stated Environmental Protection Agency.
Facility:
Refers to all contiguous land and structures. othei
appurtenances, and improvements on the land, used for treating, storing.
or disposing of hazardous waste.
FIFRA: Federal Insecticide, Fungicide and Rodenticide Act.
Generator: A person who, by virtue of ownership, management, 01
control, is responsible for causing or allowing to be caused the creatior
of hazardous waste.
Generator Status: There are three categories (status) of hazardous waste
generators. Each category has different regulatory requirements. These
categories are:
*
Large Quantity Generator (LQG)
You are a Large Quantity Generator (LQG) if in one calendai
month you:
*
*
*
*
generate 2,200 or more pounds of hazardous
waste.
generate 2,200 pounds or more of spill
cleanup debris containing hazardous waste.
generate more than 2.2 pounds of acute
hazardous waste.
generate more than 220 pounds of spill
cleanup debris containing an acute
hazardous waste.
7’
*
*
accumulate, at any time, more than 2.2
pounds of acute hazardous waste on-site.
Small Quantity Generator (SQG)
You are a Small Quantity Generator (SQG) if in one calendar
month you:
*
*
*
*
generate more than 220 pounds and less than
2,200 pounds of hazardous waste.
generate more than 220 pounds and less than
2,200 pounds of spill cleanup debris
containing hazardous waste.
accumulate, at anytime, more than a total of
2,200 pounds of hazardous waste on-site.
Conditionally Exempt Small Quantity Generator (CEG)
You are a Conditionally Exempt Small Quantity Generator
(CEG) if in one calendar month you:
*
*
*
*
generate 2.2 pounds or less of acute
hazardous waste.
generate 220 pounds or less of hazardous
waste.
generate 220 pounds of less of spill cleanup
debris containing hazardous waste.
accumulate, at any time, up to 2,200 pounds
of hazardous waste on-site.
Halogenated Solvents: Solvents containing any of a group of five
chemically related nonmetallic elements including fluorine, chlorine,
bromine, iodine and astatine.
74
Hazardous Waste (HW): Means a hazardous waste as defined in 40CFF
261.3.
Hazardous Waste Minimization: The reduction, to the extent feasible
of hazardous waste that is generated or subsequently treated, stored, o
disposed of. It includes any source reduction or recycling activit!
undertaken by a generator that results in:
1. The reduction of total volume or quantity of
hazardous waste;
2. The reduction of toxicity of hazardous
waste; or
3 . Both, as long as the reduction is consistent
with the goal of minimizing present and
future threats to human health and the
environment.
Hazardous Waste Reduction:
1.
Any recycling or other activity applied after
hazardous waste is generated that is consistent with
the general goal of reducing present and future
threats to public health, safety and the environment.
Reduction may be proportionate to the increase or
decrease in production or other business changes.
The recycling or other activity shall result in:
(a) The reduction of total volume or quantity of
hazardous waste generated that would
otherwise be treated, stored, or disposed; or
(b) The reduction of toxicity of hazardous waste
that would otherwise be treated, stored, or
disposed of; or
(c) Both the reduction of total volume or
quantity and the reduction of toxicity of
hazardous waste; and
7
(d) Does not result in: 1) the transfer of
hazardous constituents from one environmental
medium to another; 2) concentrating waste
solely for the purposes of reducing volume;
and 3) using dilution as a means of reducing
toxicity.
2.
On-site or off-site treatment may be included if it can
be shown that such treatment confers a higher degree
of protection of the public health, safety and the
environment than other technically and economically
practicable waste reduction alternatives.
In-Line/Continuous Recycling/Reclamation: Refers to a situation in
which the unit that generates the waste is hard plumbed into the unit that
recycles or reclaims the material provided the following conditions are
met:
1. Only tank storage is involved, and the entire
process through completion of reclamation
is closed by being entirely connected with
pipes or other comparable means of
conveyance;
2. Reclamation does not involve controlled
flame combustion (such as occurs in boilers,
industrial furnaces, or incinerators);
3. The secondary material are never accumulated
in such tanks for over twelve months without
being reclaimed;
4. The reclaimed material is not used to
produce products that are used in a manner
constituting disposal; and
5. The reclaimed material, if used as a material
product substitute, must be demonstrated to
be a legitimate product substitute.
Any waste produced by the recycling/reclamation unit would be subject
to hazardous waste regulations.
Large Quantity Generator (LQG): See Generator Status for definition.
Large Toxic User (LTU): A facility that is required to file a form 313
under SARA Title 3.
LDR: Land Disposal Restriction commonly called “Land Ban”
Management: The treatment, storage, disposal, or recycling of hazardous
waste.
Management Facility: Means a facility that treats, stores, disposes of.
or recycles hazardous waste.
Manifest: The shipping document EPA form 8700-22 and, if necessary.
EPA form 8700-22A, originated and signed by the generator.
Manifest Document Number: The US EPA twelve digit identification
number assigned to the generator, plus a unique five digit documenl
number assigned to the manifest by the generator for recording and
reporting purposes.
Material Safety Data Sheet: Manufacturers are required by law tc
provide material safety data sheets on all products that they manufacture
and sell. These data sheets provide information on the physical
chemical and toxic properties of a product.
Mixed Radioactive Waste: A radioactive waste, as defined by the
Atomic Energy Act, which is mixed with a RCRA hazardous waste. Thi:
waste is regulated under RCRA as well as the Nuclear Regulatory Act anc
must be reported on these forms.
NPDES: National Pollutant Discharge Elimination System (NPDES), i
provision of the Clean Water Act which prohibits discharge of pollutant:
into waters of the United States unless a special permit is issued by EPA,
a state, or (where delegated) a tribal government on an Indian reservation.
Off-site: Any site away from the facility.
On-site: The same or geographically continuous property which may be
divided by public or private right-of-way, provided the entrance and exit
between the process is at a cross-road intersection and access is by
crossing as opposed to going along the right-of-way. Non-contiguous
properties owned by the same person but connected by a right-of-way
which a private individual owns and to which the public does not have
access is considered on-site property.
Open-Loop Recycling System: A recycling system that does not meet
the criteria for “closed-loop recycling” or “in-line/continuous
recycling/reclamation”.
Operator: The person responsible for the overall operation of the
facility.
Owner: The person who owns the facility or part of the facility.
POTW (Publicly Owned Treatment Works): Wastewater treatment
works, usually designed to treat domestic wastewater, owned by a state,
unit of local government, or Indian tribe.
RCRA (Resource Conservation and Recovery Act): The federal law
regulating hazardous waste.
Reclamation: A process to recover a usable product, or to regenerate a
usable material. Examples are lead recovery from spent batteries and
regeneration of spent solvents.
Recycling: The use, reuse, or reclamation of a waste material (see 40
CFR 261.2).
SARA: Superfund Amendments and Reauthorization Act of 1986.
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Standard Industrial Classification (SIC) Code: A four-digit coding
system, developed by the Census Bureau and the Office of Management
and Budget, that categorizes the principal product or group of products
produced or distributed, or services rendered at a site.
Site: The land or water area where any facility or activity is located or
conducted, including adjacent land used in connection with the facility or
activity.
Small Quantity Generator (SQG): See definition of generator Status.
Solid/Sludge Residual: Any solid or semi-solid waste generated from a
municipal, commercial, or industrial wastewater treatment plant, water
supply treatment plant, or air pollution control facility exclusive of the
treatment effluent from a wastewater treatment plant.
Source Reduction: The reduction or elimination of waste at the source
of generation, usually within a process. Source reduction activities
include process modifications, feedstock substitutions, improvements in
feedstock purity, housekeeping and management practices, increases in
the efficiency of machinery, and recycling within a process. Source
reduction implies any action that reduces the toxicity or the amount of
waste exiting a process.
Storage: The holding of hazardous waste for a temporary period at the
end of which the hazardous waste is treated, disposed of, or stored
elsewhere. (See also Accumulation).
Superfund: Also known as CERCLA
System: A process or series of processes performing a single operation
on a hazardous waste stream. May cohsist of a number of units, or single
pieces of equipment (i.e. individual tanks, surface impoundments, or
distillation systems).
Tank: A stationary device, designed to contain an accumulation of
hazardous waste which is constructed primarily of non-earthen materials
(i.e. wood, concrete, steel, plastic) which provide structural support.
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Toxic Use: Use or production of a toxic substance.
TUR: Refers to Toxic Use Reduction Plan, which must be completed if
the generator files EPA form “R” under SARA Title 3 . This would apply
only to large toxic users (LTU).
Toxic Use Reduction: In-plant changes in production or other processes
or operations, products or raw materials that reduce, avoid or eliminate
the use or production of toxic substances without creating substantial new
risks to public health, safety and the environment. Reduction may be
proportionate to increases or decreases in production or other business
changes. Reduction means application of any of the following
techniques:
1.
Input substitution, by replacing a toxic
substance or raw material used in a
production or other process or operation
with a nontoxic or less toxic substance;
2. Product reformulation, by substituting for an
existing end product, an end product which
is nontoxic or less toxic upon use, release or
disposal;
3. Production or other process or operation
modernization, by upgrading or replacing
existing equipment and methods with other
equipment and methods;
4. Production or other process or operation
redesign or modifications;
5 . Improved operation and maintenance of
production processes or equipment or
methods, and modifications or additions to
existing equipment or methods, including
un
techniques such asimproved housekeeping
practices, system adjustments, product and
process inspections or production or process
changes; or
6. Recycling, reuse or extended use of toxic by
using equipment or methods that become an
integral part of the production or other
process or operation of concern, including
but not limited to filtration and other
methods.
Transporter: A person engaged in the off-site transportation of
hazardous waste by air, rail, highway, or water.
Treatment: Any method, technique or process, including neutralization,
designed to change the physical, chemical or biological character or
composition of any hazardous waste so as to:
1. Neutralize such waste;
2. Recover energy or material resources from
the waste;
3. Render such waste non-hazardous or less
hazardous;
4. Make it safer for transport, storage, or
disposal; or
5. Make it amendable for recovery, amenable
for storage, or reduce its volume.
TSCA: Toxic Substances Control Act.
TSDF: Treatment, Storage, or Disposal Facility.
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Used or reused: A material that is
1.
Employed as an ingredient (including use as
an intermediate) in an industrial process to
make a product (i.e. distillation bottoms
from one process used as a feedstock in
another process). However, a material will
not satisfy this condition if distinct
components of the material are recovered as
separate end products (as when metals are
recovered from metal-containing secondary
materials); or
2. Employed in a particular function or
application as an effective substitute for a
commercial product (Le. spent pickle liquor
used as phosphorous precipitant and sludge
conditioner in wastewater treatment).
Waste Management Unit: A contiguous area of land on or in which
waste is placed. It is the largest area in which there is a significant
likelihood of mixing waste constituents in the same area. Usually due to
the fact that each waste management unit is subject to a uniform set of
management practices (i.e. one liner and leachate collection and removal
system).
Waste Minimization: See Hazardous Waste Minimization.