1. RCRA (Resource Conservation and Recovery Act)
1965 SWDA, Solid Waste Disposal Act
1976 RCRA law
Major amendments in 1980, and 1984
Subtitle D, solid waste (non-hazardous)
Administered by States
Subtitle C is the hazardous waste law.

2. Slide show courtesy of Williams Petroleum
copyright.

3. ON-SITE WASTE MANAGEMENT ON-SITE WASTE MANAGEMENT
A Compliance Guide to RCRA

4. The Federal Resource Conservation and Recovery Act
1976 (1984) to protect environment from solid waste contamination
Authorizes EPA to regulate hazardous wastes from cradle to grave
Including:generation
transportation
storage
treatment
disposal

5. RCRA regulates facilities under three generator categories
Conditionally Exempt Small Quantity Generators (CESQGs)
Generates less than 100 kg (220 lb.) of hazardous waste per month
Small Quantity Generators (SQGs)
Generates between 100 kg/month and 1,000 kg/month
Large Quantity Generators (LQGs)
Generates more than 1,000 kg/month
Different quantity limits exist for acutely hazardous waste

6. Classifying then Profiling...
When classifying a waste, six questions need consideration:
1.) Is the material a waste?
2.) If yes, is it a hazardous waste?
3.) If yes, is the hazardous waste listed in the regulations?
4.) Does the waste exhibit a hazardous characteristic?
5.) Is the hazardous waste specifically excluded or exempted from regulation?
6.) Does the waste fall into any other special categories?

7. Question #1. Is the material a waste?
RCRA considers a waste to be any solid, liquid, or contained gaseous material that is discarded by being disposed of, burned or incinerated, or recycled.
Wastes can be a byproduct of a manufacturing process or simply a commercial product used in business.
Some wastes are categorically exempted from RCRA's definition of a waste. These exemptions are usually due to the waste already being regulated under other statutes.

8. Examples of materials considered to be wastes, but exempted, include:
sewage that is carried through a sewer system to a publicly owned treatment works
Industrial waste discharges monitored under the federal Clean Water Act's National Pollutant Discharge Elimination System (NPDES)
Regulated nuclear and radioactive wastes
Irrigation return flows

9. Question #2. Is it a hazardous waste?
RCRA Definition of a HAZARDOUS WASTE:
A solid waste - or a combination of solid wastes - that, because of its quantity, concentration, or physical, chemical, or infectious characteristics, may:
Cause, or significantly contribute to, an increase in mortality or an increase in a serious irreversible illness, or incapacitating, reversible illness; or
Pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of, or otherwise managed.
This definition is vague. Regulations implementing RCRA help clarify this.

10. There are only two types of hazardous wastes:
Listed Wastes
Characteristic Wastes

11. Question #3. Is the Hazardous Waste Listed in the RCRA Regulations?
A waste is considered to be hazardous if it appears on one of four lists published in the Code of Federal Regulations.

12. RCRA listed wastes are subdivided into F, K, P, and U wastes.
F Wastes - Hazardous waste from nonspecific sources
K Wastes - Hazardous waste from specific sources
U Wastes - discarded commercial products, off-specification chemicals, and container and spill residues of commercial chemical products.
P Wastes - Same as U wastes except are classified as acutely hazardous due to their acute toxicity or reactivity
Listed wastes can be petitioned by a generator to the EPA to be delisted.
F wastes are generic – common to many industries, such as “spent halogenated solvents”
K wastes are industry specific, such as wood preserving.

13. Look at lists in regs
You have these four lists, see Submodule 3B.

14. Question #4 Does the Waste Exhibit a Hazardous Characteristic?
RCRA establishes four criteria for evaluating hazardous wastes:
Ignitability
Reactivity
Corrosivity
Toxicity

15. Question #5 Is the Hazardous Waste Specifically Excluded or Exempted from Regulation?
Fed. Regulations contain several exclusions from the classification of waste as hazardous - even if the waste exhibits hazardous characteristics.

16. Some exclusions from classifying waste as hazardous include:
Household Wastes
Agricultural wastes returned to the soil as fertilizers
Mining overburden that is returned to the mine site
Cement kiln dust
Most Oil Production Wastes (drilling fluids, process waters, etc.)
Many others

17. Recycling exemptions and exclusions
EPA carefully regulates recycling of industrial wastes by both encouraging recycling and discouraging schemes devised to avoid RCRA

18. Question #6 Does the Waste Fall into Any Other Special Categories?
Acutely Hazardous Wastes - more stringent management required
Household Hazardous Wastes - voluntary collection programs
Universal Wastes - less stringent requirements
Mixtures of Hazardous and Nonhazardous Wastes
When listed wastes are mixed, all is hazardous waste
characteristic wastes can, many times, be mixed to eliminate the characteristic hazard
Used Oil exempt from RCRA if it:
is not RCRA ignitable, not mixed with listed waste, is recycled
Variances - can seek individual ruling from the state agency

19. Requirements for the Small Quantity and Large Quantity Generators
Requirements are intended to ensure safe onsite handling of wastes, avoidance of excessive waste accumulation and the ability of EPA to monitor waste from cradle to grave

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

21. Waste Handling, Storage, and Labeling
Can be stored in many types of containers providing they are compatible with material being stored
Must be labeled within 24 hours of generation
Containers must be stored in arrangements conducive to inspections

22. Waste Accumulation Limitations
LQG may not hold haz waste onsite for more than 90 days
SQG can not hold haz waste for more than 180 days
SQG can hold haz waste for 270 days if waste must be transported more than 200 miles

23. Satellite Accumulation
The clock starts ticking the day after most hazardous waste is generated
Satellite accumulation areas can be designated and not regulated until 3 days after the container is full.
55 gallon max. (1 quart max for acute)

24. Personnel Training LQG must train personnel within 6 months of hiring
training must include:
routine handling
emergency spill response
annual refresher training

25. Emergency Management
LQG must engage in prevention and preparedness activities with respect to their wastes
SQG's and LQG's must have a designated trained emergency coordinator onsite or on call at all times

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

27. EPA and DOT use different names for the same entity

28. Shipping Wastes for Treatment or Disposal
Generator must package and label the hazardous waste according to DOT rules
Specific procedures for use of manifest during transport
Important for generator to choose competent transporters and TSDFs
(TSDF = Transportation, Storage and Disposal Facilities)

29. Land Disposal Restrictions
LDR program requires waste be treated to reduce hazardous constituents to EPA set levels
(We’ll Talk about LDR when we discuss treatment. )
TSDF must receive an LDR notice from generator for each shipment.

30. Uniform Hazardous Waste Manifest
Multi-copy shipping form used to track shipments and effectively respond to spills
must accompany each hazardous waste shipment (Also, see next submodule.)
All parties involved must sign and date (and keep copy on file for three years)
States may define wastes differently - know where the waste is going
International shipments have different requirements (Alaska shipments often go through Canada.)

31. Reporting and Record Keeping
Generator must maintain records for 3 years for:
manifests, chemical analyses, inspection reports, biennial reports
Land disposal restriction documentation must be maintained for 5 years

32. Transporter Requirements
Must have EPA ID number
Must not accept hazardous waste from a generator w/o manifest
Retain copies of manifest for three years
Comply with DOT
Be able to respond to spills
Provide training to employees

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