2. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Heritage University RCRA REVIEW TRAINING Conducted by: Alfred A. Capuano, Ed.D.,CET Vice President, Safety & Training

3. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved EPA and OSHA  EPA rules are designed to protect human health and the environment, focusing on off-site receptors (env. media and the public) rather than employees  Little consideration of OSHA standards, and no cross references to OSHA standards  More coordination between DOT rules and EPA rules in the establishment of RCRA regs  Bottom Line: Compliance with RCRA rules no assurance of compliance with OSHA standards

4. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Hazardous Waste Regulatory Program Overview

5. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  Resource Conservation and Recovery Act of 1976 (RCRA), As Amended  Waste Inventory/Hazardous Waste Determination/ Determination of Regulatory Status  Notification - EPA Identification Numbers for Generators, Transporters, and TSD Facilities Hazardous Waste Regulatory Program Overview

6. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Hazardous Waste Regulatory Program Overview  Permits for Treatment, Storage, and Disposal (TSD) Facilities (Permits Not Required for 90 Day Accumulation in Containers/tanks)  Standards for Generators, Transporters, and TSD Facilities  Treatment Standards for Wastes Before Land Disposal, and Minimum Technology Requirements for Land Disposal Facilities

7. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Hazardous Waste Regulatory Program Overview  Use of manifest for transportation  State regulatory programs - authorization  Inspections and enforcement  Requirements for clean-up and ultimate responsibility of generator for disposition and environmental impact of waste - "Cradle to Grave"

8. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Basic Requirements of Hazardous Waste Generators

9. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Basic Determinations Questions to be asked and answered on an on-going basis.  Identify Wastestreams (What are all the wastes at the facility?)  Hazardous Waste Determination (Which of these wastes are hazardous, using the regulatory definitions?)  Determination of Regulatory Categories (How much and what is done on-site?)

10. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Containers Must Be...  In Good Condition  Compatible With the Waste  Labeled or Marked Clearly With the Words "Hazardous Waste"  Marked With the Accumulation Start Date Container Management (Performance and Prescriptive) Standards

11. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Container Management Standards  Kept Closed  Managed to Avoid Damage and Releases  Incompatible Wastes Are Not to Be Placed in the Same Container.  Subpart CC Air Emissions Standards May Apply

12. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  Ignitable/reactive Wastes Must Be 50 Ft. From the Property Line*  "No Smoking" Signs Must Be Posted*  Incompatible Wastes Are to Be Separated or Protected From Each Other  Emergency Equipment Is to Be Available*  Adequate Aisle Space (2½ Feet) Is to Be Maintained* Container Accumulation Area Standards

13. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  Inspect Container Accumulation Areas Weekly  Inspect Emergency Equipment at Least Monthly*  Shipments Are to Be Made Every 90 Days for Large Quantity Generators  Shipments Are to Be Made Every 180 Days for Small Quantity Generators Container Accumulation Area Standards

14. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Compliance Documentation  Contingency Plan  Personnel Training Program & Records  Inspections  Manifests and LDR Forms  Biennial Reports  Waste Analyses/Determinations  Waste Minimization Program

15. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved EPA’s Definition of Solid Waste (40 CFR 261.2)

16. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Any Material  Disposed of or Abandoned in Lieu of Disposal  Burned, Incinerated or Recycled  “Inherently Waste-like”

17. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Please Note  EPA takes an “all or nothing” approach. Secondary materials are either comprehensively regulated or totally unregulated, which ignores laws of chemistry and physics, making no allowance for severity or degree of hazard.  RCRA rules do not address chemical inventory issues, which are addressed under EPCRA and OSHA regs

18. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved “Materials Which Are Not Solid Wastes” (40 CFR 261.4(a))  Domestic Sewage Exclusion  Point Source (NPDES) Exclusion  Secondary Materials That Are Reclaimed and Returned to the Original Process(es) in Which They Were Generated Where They Are Reused in the Production Process Exclusions

19. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved “Solid Wastes Which Are Not Hazardous Wastes” (40 CFR 261.4(b))  Household Wastes  Petroleum-Contaminated Media and Debris (D018-D043 Only) From Regulated UST Releases Pertinent Exclusions

20. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  Samples (40 CFR 261.4(d))  Treatability Study Samples (40 CFR 261.4(e)&(f))  CESQG Hazardous Wastes (40 CFR 261.5)  Specified Recyclable Materials (40 CFR 261.6)  Residues In Empty Containers (40 CFR 261.7)  PCB Wastes Exhibiting the Toxicity Characteristic (D018-D043) Regulated Under TSCA (40 CFR 261.8)  Universal Wastes (40 CFR 261.9, Referencing 40 CFR Part 273) Other Pertinent Exclusions

21. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  Product or Raw Material Storage Tank Residues; Residues in Product or Raw Material Transport Vehicles, Vessels or Pipelines; and Residues in Manufacturing Process Units While These Units Are in Service (40 CFR 261.4(c)) Other Pertinent Exclusions

22. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Solid Waste/Hazardous Waste Determinations (40 CFR 261.3)

23. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Solid Waste Determination  Excluded From Definition of Solid Waste (40 CFR 261.4(a) or by Reuse or Recycling)  Excluded from Definition of Hazardous Waste (40 CFR 261.4(b))

24. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Hazardous Waste Determination  Listed (40 CFR 261, Subpart D)  Mixture of Solid Waste and Listed Hazardous Waste (40 CFR 261.3(a)(2)(iv))  Solid Waste Derived from T, S, or D of Listed Hazardous Waste (40 CFR 261.3(c)(2)(i))  Waste Exhibits any Characteristics of Hazardous Waste (40 CFR 261, Subpart C - either by testing or knowledge of waste)

25. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Lists of Hazardous Wastes (40 CFR Part 261, Subpart D) Four Lists:  F- list  K- list  P- list  U-list

26. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved “Hazardous Wastes from Non-Specific Sources” (40 CFR 261.31)“F-List”

27. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved F-List (40 CFR 261.31)  Spent Solvents (F001-F005) (Not Commercial Products or Manufacturing Process Wastes) - “Solvent Mixture Rule”  All spent solvent mixtures/blends containing, before use, a total of 10% or more (by volume) of one or more of the solvents listed in F001, F002, F004 and F005 are now regulated.

28. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved F-List (40 CFR 261.31)  Need to determine if F001, F002, F004 or F005 solvents are present in Trade Name Solvents or solvent blends.  Electroplating Wastes (F006, F007, F008, F009)  Metal Heat-Treating Wastes (F010, F011, F012)  WWT Sludges from Chemical Conversion Coating of Aluminum (F019)  Miscellaneous

29. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved “Hazardous Wastes from Specific Sources” (40 CFR 261.32) “K-List”

30. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Process Wastes from Specified Industries  Wood Preservation  Inorganic Pigments  Organic Chemicals  Inorganic Chemicals  Pesticides  Explosives

31. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Process Wastes from Specified Industries  Petroleum Refining  Iron & Steel  Primary Copper  Primary Lead  Primary Zinc  Primary Aluminum

32. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Process Wastes from Specified Industries  Ferroalloys  Secondary Lead  Veterinary Pharmaceuticals  Ink Formulation  Coking

33. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Commercial Chemical Products Lists Acute Hazardous (H) Waste (40 CFR 261.33(e)) – “P-List” and Toxic (T) Wastes (40 CFR 261.33(f)) – “U-List”

34. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved P-List Examples  Mostly Pesticides, Toxic Organics, Pure Cyanides, and Certain Heavy Metal Compounds  Listings Include Unrinsed Containers/Liners and Spill Residues  Lower Small-Quantity Generator Exclusion (1 Kilogram/100 Kilograms Spill Residue)

35. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  Mostly Natural and Synthetic Organics  Listings Include Spill Residues U-List

36. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Commercial chemical product listings do not apply to spent materials or manufacturing process wastes containing listed chemicals. Listings apply to technical grade chemicals or formulations where the listed chemical is the sole active ingredient. The commercial chemical products listings apply if and when such chemicals are spilled, discarded or intended to be discarded. Listings should be consulted prior to disposal of virgin chemical spill residues, off-specification chemical products, manufacturing chemical intermediates, obsolete chemical inventory, excess or surplus inventory, or expired chemical products. Note

37. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Characteristics of Hazardous Waste (40 CFR Part 261, Subpart C) A focus on acute hazards, except for the Toxicity Characteristic

38. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Ignitability (I) D001 (40 CFR 261.21)  Liquid, With Closed Cup Flashpoint <140  F  Nonliquid, Capable of Spontaneous and Sustained Combustion and When Ignited, Burns So Vigorously and Persistently As to Create a Hazard  DOT Oxidizers and Ignitable Compressed Gases

39. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  Aqueous, pH  2 or pH  12.5  Liquid, Corrodes SAE 1020 Steel > 1/4" Per Year at 130  F  Federally, no recognition of corrosive solids Corrosivity (C) D002 (40 CFR 261.22)

40. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Reactivity (R) D003 (40 CFR 261.23)  Unstable, Reacts Violently  Water ‑ reactive or Forms Potentially Explosive Mixtures With Water  Forms Toxic Gases, Vapors, or Fumes Endangering Health When Mixed With Water  Cyanide or Sulfide Containing Waste Which Can Generate Toxic Gases at pH Conditions Between 2 and 12.

41. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  EPA Guidance: Reactive Cyanide (SW846-9010): 250 mg HCN/kg Waste 250 mg HCN/kg Waste Reactive Sulfide (SW846-9030): 500 mg H 2 S/kg Waste 500 mg H 2 S/kg Waste Reactivity (R) D003

42. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  Capable of Detonation or Explosive Reaction  DOT Explosive Divisions 1.1 to 1.3 (Class A or B) Reactivity (R) D003

43. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  Toxicity Characteristic Leaching Procedure (TCLP) Extract of Waste Analyzed for Specified Heavy Metals and Toxic Organics. Zero Headspace Extraction (ZHE) Required for Volatile Organic Constituents. Toxicity (E) D004-D043 (40 CFR 261.24)

44. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  TCLP Extraction Developed to Simulate Effects of Waste Mismanagement Upon the Groundwater in a Municipal Landfill Co-disposal Scenario. Regulatory Thresholds Are Derived by Multiplying the Chronic Toxicity Level (Typically MCLs) by the Dilution Attenuation Factor (DAF). DAF Is Currently Set at 100. Toxicity (E) D004-D043

45. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved When Does a Solid Waste Become a Hazardous Waste?

46. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  When It First Meets the Listing Description  For Mixtures, When Listed Hazardous Waste is First Added to Solid Waste (“Mixture Rule” - 40 CFR 261.3(a)(2)(iv))  When the Waste Exhibits Any of the Characteristics of Hazardous Waste Note: Point of Generation to be Used for Regulatory Purposes (before aggregation / consolidation or treatment) Note: Point of Generation to be Used for Regulatory Purposes (before aggregation / consolidation or treatment) A Waste Becomes Hazardous….

47. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  Sludges  Treatment Residues  Spill Residues  Ash  Air Emission Control Sludge/Dust  Leachate (“Derived From” Rule - 40 CFR 261.3(c)(2)) Residues from Treatment, Storage, or Disposal of Listed Hazardous Waste

48. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Regulatory Categories

49. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Regulatory Categories  Conditionally-Exempt Generator or CEG (<100 Kg/Mo)  Small Quantity Generator or SQG (100 - 1000 Kg/Mo)  Generator Who Accumulates On-Site in Containers or Tanks for Less Than 90 Days (Large Quantity Generator or LQG) Note: These Categories are Mutually Exclusive at Any One Point In Time. Note: These Categories are Mutually Exclusive at Any One Point In Time.

50. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Regulatory Categories  Generator/Shipper (to Off-site TSD)  Used Oil Generators, Transporters, Processors/re-refiners, Burners and Marketers  Owner/Operator of Underground Petroleum Or Hazardous Substance Storage Tank  Commercial TSD Facility

51. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Standards For Generators (40 CFR 262)

52. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Accumulation Time (40 CFR 262.34)  Use and Management of Containers (40 CFR 265 ‑ Subpart I and Subparts AA, BB, and CC as Applicable)  Tank Systems (40 CFR 265 ‑ Subpart J, Except 265.197(c) and 265.200 and Subparts AA, BB, and CC as Applicable)  Containment Buildings (40 CFR 265 - Subpart DD)

53. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Accumulation Time  Accumulation Start Date Marking (90 Day Limit ‑ 30 Day Extension Possible) ‑ Satellite Accumulation (40 CFR 262.34(c)) (Excess Accumulation Date Starts 90 Day Period) (Excess Accumulation Date Starts 90 Day Period)  Hazardous Waste Marking/Labeling

54. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Accumulation Time  Preparedness and Prevention (40 CFR 265 ‑ Subpart C)  Contingency Plan and Emergency Procedures (40 CFR 265 ‑ Subpart D)  Personnel Training (40 CFR 265.16)

55. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Accumulation Time  Closure Performance Standards (40 CFR 265.111 and 265.114) -Control of Post-Closure Releases -Removal and Proper Disposal of All Hazardous Wastes, Residues and Contaminated Soil

56. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Note  Satellite Accumulation Provisions at 40 CFR 262.34(c).  Small Quantity Generator Provisions at 40 CFR 262.34(d).

57. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Preparedness and Prevention (40 CFR Part 265, Subpart C)

58. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Preparedness and Prevention  Maintain and Operate the Facility So As to Minimize the Possibility of Fire, Explosion or Unplanned Release (265.31)  Provision of Certain Required Equipment (265.32) :  Internal Communications or alarm system  Telephone or two-way radio  Portable fire extinguishers, fire control equipment, spill control and decontamination equipment  Water at adequate volume and pressure

59. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Preparedness and Prevention  Testing and Maintenance of Equipment (265.33)  Aisle Space Required to Allow Emergency Response (265.35)

60. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Preparedness and Prevention  Arrangements With Local Authorities Must be Attempted, as Appropriate(265.37):  Police, Fire, and Emergency Response Teams  Agreements Designating Primary Fire and Police Authorities  Agreements With State Emergency Response Teams, Emergency Response Contractors, and Equipment Suppliers  Local Hospitals

61. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Contingency Plans (40 CFR Part 265, Subpart D)

62. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Contents  Actions of Facility Personnel in Response to HW Emergencies  Arrangements Made With Local Authorities  List of Emergency Coordinators  Emergency Equipment List  Evacuation Plan

63. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Personnel Training (40 CFR 265.16)

64. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Personnel Training  Who Gets Trained?  What Should the Training Consist of and Accomplish?  Who Performs the Training?  How Often Is Training Performed?  What Constitutes Appropriate Documentation?

65. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Note  Compliance With RCRA HWM Training Requirements Is Not Adequate Training for OSHA Hazard Communication Standard or DOT Subpart H, 49CFR 172.700 Compliance, and May Not Be Adequate for Compliance With the OSHA Hazardous Waste and Emergency Response Operations Standard.

66. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Requirements for 100-1000 Kg/Month Small Quantity Generators (40 CFR 262.34(d))

67. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Requirements  Notify and Obtain U.S. EPA ID Number  Accumulate No More Than 6,000 Kg On- Site for Up to 180 Days (270 Days If TSD Over 200 Miles Away)  Mark Each Container With the Words “Hazardous Waste” and Accumulation Start Date

68. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Requirements  Follow Container or Tank Accumulation Requirements  Preparedness and Prevention Requirements  Emergency Planning and Notification of Releases

69. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Requirements  Utilize Planning and Notification of Releases  Follow DOT Requirements Re: Packaging, Labeling and Marking  Use Uniform Hazardous Waste Manifest  Limited Exception Reporting Requirements if Return Copy Not Received Within 60 Days of Shipment

70. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Satellite Accumulation (40 CFR 262.34(c))

71. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Satellite Accumulation Points  Areas “At or Near Any Point of Generation Where Wastes Initially Accumulate, Which Is Under the Control of the Operator of the Process Generating the Waste".  Satellite Accumulation Points Are Not Subject to the 90-day Accumulation Standards That Apply to Central Accumulation/Storage Areas.

72. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Satellite Requirements  Wastes Must Be Placed in Containers That Are in Good Condition.  Wastes Must Be Compatible With the Containers.  Containers Must Always Be Closed, Unless Wastes Are Being Added or Removed.

73. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Satellite Requirements  Containers Must Be Marked With the Accumulation Start Date When "Excess Accumulation" Begins (When the Container Is Filled to Capacity).  Full Containers Must Be Moved to 90-day Accumulation Area Within 3 Days After Being Filled to Capacity.

74. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved A Practical Approach to Land Disposal Restrictions (40 CFR 268)

75. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved General Outline  Land Disposal Restrictions (LDR) are found at 40 CFR Part 268.  LDR regulations developed to reduce the toxicity and/or mobility of hazardous waste constituents that are land disposed.  Majority of hazardous wastes do not meet treatment standards as generated

76. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved General Outline  Hazardous wastes must meet LDR treatment standards before they can be land disposed. Treatment standards are based on Best Demonstrated Available Technology, or BDAT. Technology-based rather than health- or risk-based. LDR treatment standards attach at the point of initial generation.

77. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved General Outline  Definition of "wastewater" under LDR regulations is a waste that contains less than 1% total suspended solids and less than 1% total organic carbon.  Subcategories further categorize certain hazardous wastes. Not all waste codes have subcategories.

78. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved General Outline  Three types of treatment standards :  Total Waste Standards (totals analysis);  Waste Extract Standards (TCLP analysis); or  Specified Technology Standards (specify a treatment technology by five letter code, rather than constituent concentration).

79. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved General Outline  Concentration-based Universal Treatment Standards (UTS) specify a single numerical treatment standard for each organic, metal and cyanide constituent, regardless of the type of waste, that must be met prior to land disposal.

80. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved General Outline  There is One Table at 40 CFR 268.40 That Specifies All Treatment Standards for the Various Hazardous Wastes  Waste Code, Description/Subcategory, Regulated Hazardous Constituents, and Wastewater/Non-Wastewater Treatment Standards  One Treatment Standard for Wastewater and One for Non-Wastewater for Each Waste Code

81. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Generator Requirements

82. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Eight Elements for LDR Compliance  Determine, at the Point of Generation, All Applicable Codes, the Category (WW or Non-WW), and the Subcategory (If Any) for Each Restricted Waste.  Determine Which Treatment Standard(s) Apply to Each Restricted Waste

83. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Eight Elements for LDR Compliance  Identify Underlying Hazardous Constituents (Where Required).  Determine, Through Specified Analytical Techniques or Knowledge of the Waste, Whether the Treatment Standard Has Been Achieved.  Comply With Time Limitations.

84. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved Eight Elements for LDR Compliance  Comply with prohibitions on evaporation and dilution.  Prepare notifications and/or certifications required for onsite or offsite waste management.  Comply with recordkeeping requirements to maintain all LDR documentation.

85. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved EPA/DOT Regulatory Requirements

86. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  Select Appropriate Shipping Description and Determine If RQ Is Being Shipped in a Single Container  Perform LDR determinations  Comply With DOT Requirements for Packaging, Labeling and Marking Generators Shipping Hazardous Wastes Off-Site

87. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  Verify That Transporter and Designated TSD Facility Have Valid EPA Identification Numbers and Relevant Permits Generators Shipping Hazardous Wastes Off-Site

88. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  Prepare a Uniform Hazardous Waste Manifest (EPA Form 8700-22), Utilizing Appropriate Form per Acquisition Hierarchy. Prepare the Appropriate Notice(s) for Restricted Waste Shipments to Treatment Facilities. Prepare the Appropriate Certification(s) for Restricted Waste Shipments to Land Disposal Facilities. Generators Shipping Hazardous Wastes Off-Site

89. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  Offer the Transporter Appropriate Placards.  Sign and Date Manifest, Certifying Shipment Meets EPA and DOT Pre-transportation Requirements. Signature also Certifies that a Waste Minimization Program is in Place, and that the Method of T, S, or D Selected is Environmentally Appropriate. Generators Shipping Hazardous Wastes Off-Site

90. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  Obtain Signature of Transporter and Date of Acceptance  Retain One Copy of the Signed Manifest and Give the Remaining Copies to the Transporter Generators Shipping Hazardous Wastes Off-Site

91. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved  Monitor the Manifest Tracking System.  Submit Exception Reports, as Appropriate.  Prepare and Submit Biennial Reports Including a Description of Waste Minimization Efforts and Achievements.  Keep Copies of Manifests, Land Disposal Restriction Notices/ Certifications, Biennial Reports, Any Exception Reports, and Waste Analyses/Determinations. Generators Shipping Hazardous Wastes Off-Site

92. Copyright 2004, Heritage Environmental Services, LLC – All Rights Reserved