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Managing Your Hazardous A Guide for Small Businesses

1EPA United States Solid Waste and EPA530-K-01-005 Environmental Protection Emergency Response December 2001 Agency (5305W) www.epa.gov/osw CONTENTS

1 INTRODUCTION

2 DECIDING WHETHER HAZARDOUS WASTE REGULATIONS APPLY TO YOU

2 Defining Hazardous Waste 3 Identifying Your Waste 3 Finding Your Generator Category

7 OVERVIEW OF REQUIREMENTS FOR CONDITIONALLY EXEMPT SMALL QUANTITY GENERATORS

8 OBTAINING AN EPA IDENTIFICATION NUMBER

11 MANAGING HAZARDOUS WASTE ON SITE

11 Accumulating Your Waste 13 Treating Your Waste To Meet the Land Disposal Restrictions 13 Preventing Accidents 14 Responding to Emergencies

16 SHIPPING WASTE OFF SITE

16 Selecting a Treatment, Storage, and Disposal Facility 16 Labeling Waste Shipments 17 Preparing Hazardous Waste Manifests 17 Land Disposal Restrictions (LDR) Reporting Requirements 18 Export Notification 18 Closure

21 SUMMARY OF REQUIREMENTS FOR LARGE QUANTITY GENERATORS

22 WHERE TO GET MORE HELP

22 EPA and Other Federal Resource Centers 24 EPA Regional Offices

26 ACRONYMS AND DEFINITIONS

ii INTRODUCTION TIP oes your business generate (1) Conditionally exempt small Dhazardous waste? Many small quantity generators (CESQGs), ou can look up unfamiliar businesses do. If you need help which generate less than 220 Ywords, phrases, or understanding which federal haz- lbs (100 kg) per month. acronyms in the list of defini- ardous regula- tions found on page 26. (2) Small quantity generators tions apply to your business, this (SQGs), which generate handbook is for you. It has been between 220 lbs (100 kg) and prepared by the U.S. Environmen- 2,200 lbs (1,000 kg) per tal Protection Agency (EPA) to help hazardous waste regulations. In month. small-business owners and opera- some of these states, the require- tors understand how best to com- (3) Large quantity generators ments are the same as the federal ply with federal hazardous waste (LQGs), which generate more standards and definitions. Other management regulations. than 2,200 lbs (1,000 kg) per states, however, have developed month. more stringent requirements than This handbook provides an the federal program. If this is the overview of the regulations to give Each category of generator must case in your state, you must com- you a basic understanding of your comply with the hazardous waste ply with the state regulations. To responsibilities. It should not be rules specific to that category. This become familiar with your state’s used as a substitute for the actual handbook is intended primarily for requirements, consult your state requirements. All of the federal businesses that generate a small hazardous waste agency. For the hazardous waste regulations are quantity of hazardous waste (SQGs address or phone number for your located in Title 40 of the Code of and CESQGs) to help them learn state agency, contact the RCRA Federal Regulations (CFR), Parts about regulations that apply to Call Center at 800 424-9346 or 260 to 299 (www.epa.gov/ them. TDD 800 553-7672. epacfr40). This handbook explains only the EPA defines three categories of federal requirements for hazardous hazardous waste generators based waste management. Many states upon the quantity of hazardous have their own hazardous waste waste they generate per month: regulations based on the federal

FOR MORE INFORMATION

If you have questions about any part of this book, or the federal hazardous waste regula- tions, contact the RCRA Call Center at 703 412-9810 or TDD 703 412-3323 in the Washington, DC, area or at 800 424-9346 or TDD 800 533-7672 from other locations, or .

The Call Center provides free technical assis- tance. Any information you share will not be 1 used for any other purpose. DECIDING WHETHER HAZARDOUS WASTE REGULATIONS APPLY TO YOU

Federal hazardous waste burning for fuel) might be demonstrates one or more of considered waste. the following characteristics: management regulations Hazardous waste can be one of ᮣ It catches fire under certain apply to most businesses two types: conditions. This is known as that generate hazardous an ignitable waste. Examples ᮣᮣ Listed waste. Your waste is are paints and certain waste. To determine if considered hazardous if it degreasers and solvents. these regulations apply to appears on one of four lists published in the Code of ᮣ It corrodes metals or has a your business, you must Federal Regulations (40 CFR very high or low pH. This is first determine if you even Part 261). Currently, more known as a corrosive waste. than 500 are listed. Examples are rust removers, generate hazardous Wastes are listed as haz- acid or alkaline cleaning flu- waste. ardous because they are ids, and battery acid. known to be harmful to human ᮣ It is unstable and explodes health and the environment Defining Hazardous Waste or produces toxic fumes, when not managed properly. gases, and vapors when waste is any solid, liquid, or con- Even when managed properly, mixed with water or under tained gaseous material that is A some listed wastes are so other conditions such as discarded by being disposed of, dangerous that they are called heat or pressure. This is burned or incinerated, or recycled. acutely hazardous wastes. known as a reactive waste. (There are some exceptions for recy- Examples of acutely haz- Examples are certain cled materials.) It can be the by- ardous wastes include wastes cyanides or sulfide-bearing product of a process generated from some pesti- wastes. or simply a commercial product that cides and that can be fatal to you use in your business—such as ᮣ It is harmful or fatal when humans even in low doses. a cleaning fluid or battery acid—and ingested or absorbed, or it that is being disposed of. Even ᮣᮣ Characteristic wastes. If your leaches toxic chemicals into materials that are recyclable or can waste does not appear on the soil or ground water when be reused in some way (such as one of the hazardous waste disposed of on land. This is lists, it still might be known as a . considered hazardous if it Examples are wastes that contain high concentrations of , such as cad- Determine if you generate hazardous waste mium, lead, or . in the first place. You can determine if your waste is Measure the amount of hazardous waste that toxic by having it tested using the you produce per month. Toxicity Characteristic Determine your generator category to learn the management requirements that apply to you. 2 TIP

ne way to help determine if your waste exhibits any of the Ocharacteristics listed on page 2 is to check the Material Safety Data Sheet (MSDS) that comes with all products containing hazardous materials (www.msdsonline.com for information). In addition, your national trade association or its local chapter might be able to help you.

Procedure (TCLP), or by simply need to measure the amount of lbs (100 kg) of acutely hazardous knowing that your waste is haz- waste you produce per month. The waste spill residues) in a calendar ardous or that your processes gen- amount of hazardous waste you month, and never store more than erate hazardous waste. For more generate determines your genera- that amount for any period of time, information about the TCLP and tor category. you may manage the acutely haz- other test methods, contact the ardous waste according to the Many hazardous wastes are liquids RCRA Call Center or the Methods CESQG requirements. If you gener- and are measured in gallons—not Information Communication ate or store more than 2.2 lbs pounds. In order to measure your Exchange (MICE) at 703 676-4690 (1kg) of acutely hazardous waste liquid wastes, you will need to con- or . on site, you must manage it vert from gallons to pounds. To do according to the LQG requirements this, you must know the density of Identifying Your Waste (see below). the liquid. A rough guide is that 30 o help you identify some of the gallons (about half of a 55-gallon SQGs: Twaste streams common to your ) of waste with a density simi- Small Quantity Generators: You business, consult the table on lar to water weighs about 220 are considered an SQG if you gen- page 4 to find a list of typical haz- pounds (100 kg); 300 gallons of a erate between 220 and 2,200 lbs ardous wastes generated by small waste with a density similar to (100 and 1,000 kg) per month of businesses. Use the insert in the water weighs about 2,200 lbs hazardous waste. SQGs must com- middle of this handbook for a (1,000 kg). ply with EPA requirements for man- more detailed listing of the EPA aging hazardous waste described EPA has established three genera- waste codes associated with these in this document. tor categories, as follows, each of waste streams to determine if your which is regulated differently: LQGs: waste is hazardous. Commercial Large Quantity Generators: You chemical products that are discard- CESQGs: are considered an LQG if you gen- ed might also become hazardous Conditionally Exempt Small erate more than 2,200 lbs (1,000 waste. For a complete listing of Quantity Generators: You are con- kg) per month of hazardous waste. hazardous waste codes, see 40 sidered a CESQG if you generate LQGs must comply with more CFR Part 261. less than 220 lbs (100 kg) per extensive hazardous waste rules month of hazardous waste. You If your waste is hazardous, you will than those summarized in this are exempt from hazardous waste need to manage it according to handbook. See page 21 for an management regulations provided appropriate federal regulations. overview. that you comply with the basic Finding Your Generator requirements described on page 6. Category If you are a CESQG and you gener- nce you know that you gener- ate no more than 2.2 lbs (1 kg) of Oate hazardous waste, you acutely hazardous waste (or 220

3 TYPICAL HAZARDOUS WASTE GENERATED BY SMALL BUSINESSES

TYPE OF BUSINESS HOW GENERATED TYPICAL WASTES WASTE CODES

Drycleaning and Commercial drycleaning Still residues from distilla- D001, D039, F002, F005, U210 Laundry Plants processes tion, spent filter cartridges, cooked powder residue, spent solvents, unused perchloroethylene

Furniture/Wood Wood cleaning and wax removal, Ignitable wastes, toxic wastes, D001, F001-F005 Manufacturing and refinishing/stripping, staining, paint- solvent wastes, paint wastes Refinishing ing, finishing, brush cleaning and spray brush cleaning

Construction Paint preparation and painting, - Ignitable wastes, toxic wastes, D001, D002, F001-F005 pentry and floor work, other special- solvent wastes, paint wastes, used ty contracting activities, heavy oil, acids/bases construction, wrecking and demoli- tion, vehicle and equipment mainte- nance for construction activities

Laboratories Diagnostic and other Spent solvents, unused reagents, D001, D002, D003, F001-F005, U211 testing reaction products, testing samples, contaminated materials

Vehicle Degreasing, rust removal, paint Acids/bases, solvents, ignitable D001, D002, D006, D007, D008, Maintenance preparation, spray booth, spray wastes, toxic wastes, paint wastes, D035, F001-F005, U002, U080, U134, guns, brush cleaning, paint removal, batteries, used oil, unused cleaning U154, U159, U161, U220, U228, tank cleanout, installing lead-acid chemicals U239 batteries, oil and fluid replacement

Printing and Allied Plate preparation, stencil prepara- Acids/bases, heavy metal wastes, D002, D006, D008, D011, D019, Industries tion for screen printing, photopro- solvents, toxic wastes, ink, unused D035, D039, D040, D043, F001-F005, cessing, printing, cleanup chemicals U002, U019, U043, U055, U056, U069, U080, U112, U122, U154, U159, U161, U210, U211, U220, U223, U226, U228, U239, U259, U359

Equipment Repair Degreasing, equipment cleaning, Acids/bases, toxic wastes, D001, D002, D006, D008, F001-F005 rust removal, paint preparation, ignitable wastes, paint wastes, painting, paint removal, spray booth, solvents spray guns, and brush cleaning.

Pesticide End- application and cleanup Used/unused , solvent D001, F001-F005, U129, U136, P094, Users/Application wastes, ignitable wastes, contami- P123 Services nated soil (from spills), contaminat- ed rinsewater, empty containers

Educational and Automobile engine and body repair, Ignitable wastes, solvent wastes, D001, D002, F001-F005 Vocational Shops metalworking, graphic arts-plate acids/bases, paint wastes preparation, woodworking

Photo Processing Processing and developing nega- Acid regenerants, cleaners, D001, D002, D007, D011 tives/prints, stabilization system ignitable wastes, silver cleaning

Leather Hair removal, bating, soaking, Acids/bases, ignitables wastes, D001, D002, D003, D007, D035, Manufacturing tanning, buffing, and dyeing toxic wastes, solvent wastes, F001-F005, U159, U228, U220 unused chemicals

4 TIP

n many cases, small businesses that fall Iinto different generator categories at different times choose to satisfy the more stringent requirements to simplify compliance.

UNIVERSAL WASTES he Universal Waste Rule was written to streamline envi- ᮣᮣ Agricultural pesticides that have been recalled or Tronmental regulations for wastes generated by large banned from use, are obsolete, have become - numbers of businesses in relatively small quantities. It is aged, or are no longer needed due to changes in designed to reduce the amount of hazardous waste dis- cropping patterns or other factors. They often are posed of in , encourage the stored for long periods of time in sheds or barns. and proper disposal of certain common hazardous wastes, ᮣᮣ Thermostats, which can contain as much as 3 grams and reduce the regulatory burden for businesses that gen- of liquid mercury and are located in almost any build- erate these wastes. ing, including commercial, industrial, agricultural, com- Universal wastes are items commonly thrown into the munity, and household buildings. trash by households and small businesses. Although han- ᮣᮣ Lamps, which typically contain mercury and some- dlers of universal wastes can meet less stringent stan- times lead, and are found in businesses and house- dards for storing, transporting, and collecting these holds. Examples include fluorescent, high-intensity wastes, handlers must still comply with the full hazardous discharge (HID), neon, mercury vapor, high-pressure waste requirements for final recycling, treatment, or dis- sodium, and metal halide lamps. posal. By providing a waste management structure that removes these wastes from municipal and inciner- Materials are continually added to the Universal Waste list; ators, this rule ensures stronger safeguards for public check health and the environment. for the latest information. Universal wastes include: The Universal Waste Rule also encourages communities and businesses to establish collection programs or partici- ᮣᮣ Batteries, such as nickel-cadmium (Ni-Cd) and small pate in manufacturer take-back programs required by a sealed lead-acid batteries, which are found in many number of states. Many large manufacturers and trade common items, including electronic equipment, cell associations are already planning national and regional col- phones, portable , and emergency backup lection programs for their universal waste products. lighting. For more information, see 40 CFR Part 273.

WHAT IS YOUR GENERATOR CATEGORY?

Depending on your type of business, you might be regulated under different rules at different times. If, for example, you gen- erate less than 220 lbs (100 kg) of hazardous waste during the month of June, you would be considered a CESQG for June, and your June waste would be subject to the hazardous waste man- agement requirements for CESQGs. If, in July, you generate between 220 and 2,200 lbs (100 kg to 1,000 kg) of hazardous waste, your generator status would change, and you would be considered an SQG for July. Your July waste would then be subject to the management requirements for SQGs. If you mix the wastes generated during June and July, the entire mixture would be subject to the more stringent SQG standards.

5 WHAT DO YOU MEASURE TO DETERMINE YOUR GENERATOR CATEGORY?

DO Measure: DO NOT Measure: must comply with the Clean Water Act. POTWs are public All quantities of listed and char- Wastes that: utilities, usually owned by acteristic hazardous wastes that ᮣᮣ Are specifically exempted the city, county, or state, that are: from counting. Examples treat industrial and domestic ᮣᮣ Accumulated on the property include lead-acid batteries for disposal. for any period of time before that will be reclaimed, ᮣᮣ Have already been counted disposal or recycling. metal that will be recycled, once during the calendar (Drycleaners, for example, used oil managed under the month, and are treated on must count any residue used oil provisions of 40 site or reclaimed in some removed from machines, CFR 279, and universal manner, and used again. as well as spent cartridge wastes (e.g., batteries, pesti- filters.) cides, thermostats, and ᮣᮣ Are regulated under the uni- lamps) managed under 40 versal waste rule or have ᮣᮣ Packaged and transported CFR 273. other special requirements. away from your business. The federal regulations con- ᮣᮣ Might be left in the bottom ᮣᮣ Placed directly in a regulated tain special, limited require- of containers that have been treatment or disposal unit at ments for managing certain thoroughly emptied through your place of business. commonly generated wastes. conventional means such as These wastes can be man- ᮣᮣ Generated as still bottoms pouring or pumping. or sludges and removed aged following the less bur- ᮣᮣ Are left as residue in the bot- from product storage tanks. densome requirements listed tom of tanks storing prod- below instead of the usual ucts, if the residue is not hazardous waste require- removed from the product ments. Check with your state tank. agency to determine if your state has similar regulations. ᮣᮣ Are reclaimed continuously on site without storing prior Used oil—40 CFR Part 279 to reclamation, such as Lead-acid batteries that are drycleaning solvents. reclaimed—40 CFR Part ᮣᮣ Are managed in an “elemen- 266, Subpart G tary neutralization unit,” a Scrap metal that is recy- “totally enclosed treatment cled—40 CFR 261.6 (a)(3) unit,” or a “wastewater treat- ment unit,” without being Universal wastes (e.g., cer- stored first. (See Definitions tain batteries, recalled and for an explanation of these collected pesticides, and types of units.) mercury-containing thermo- stats and lamps)—40 CFR ᮣᮣ Are discharged directly to Part 273 publicly owned treatment works (POTWs) without being stored or accumulated first. This discharge to a POTW

6 CESQG

OVERVIEW OF REQUIREMENTS FOR CONDITIONALLY EXEMPT SMALL QUANTITY GENERATORS

If you generate no more time. Finally, you must ensure such as certain batteries, delivery of your hazardous waste recalled and collected pesti- than 220 lbs (100 kg) of to an off-site treatment or disposal cides, or mercury-containing hazardous waste per facility that is one of the following, thermostats or lamps.) month, you are a or, if you treat or dispose of your hazardous waste on Conditionally Exempt site, your facility Small Quantity Generator also most be: STATE REQUIREMENTS (CESQG). You must comply ᮣᮣ A state or fed- ome states have additional requirements erally regulated Sfor CESQGs. For example, some states with three basic waste hazardous require CESQGs to follow some of the SQG management requirements waste manage- requirements such as obtaining an EPA identifi- ment treat- cation number, or complying with storage stan- to remain exempt from the ment, storage, dards. See page 14 for SQG storage full hazardous waste regu- or disposal requirements. lations that apply to gener- facility. ᮣᮣ A facility permitted, licensed, ators of larger quantities Suggestion: or registered by a state to (SQGs and LQGs). manage municipal or industri- It’s a good idea to call the appro- al solid waste. priate state agency to verify that the treatment, storage, and dispos- ᮣᮣ A facility that uses, reuses, or (Note: there are different al facility (TSDF) you have selected legitimately recycles the has any necessary permits, etc. quantity limits for acutely waste (or treats the waste You also may want to see that the prior to use, , or hazardous waste.) facility fits into one of the above recycling). categories. (It’s a good idea to irst, you must identify all haz- ᮣᮣ A universal waste handler or document such calls for your F ardous waste that you gener- destination facility subject to records.) ate. Second, you may not store the universal waste require- more than 2,200 lbs (1,000 kg) of ments of 40 CFR Part 273. hazardous waste on site at any (Universal wastes are wastes

Identify your hazardous waste. Comply with storage quantity limits. Ensure proper treatment and disposal of your waste.

7 SQG

OBTAINING AN EPA IDENTIFICATION NUMBER

If your business generates offices are listed on pages 24 copy of the form for each busi- or visit ). You will be Each site will receive its own sent a booklet that contains a EPA identification number. of hazardous waste per form with instructions and Make sure you sign the certifi- month, you are an SQG, those portions of the regula- cation in Item X. tions that will help you identify and you must obtain and ᮣᮣ Send the completed form to your waste. A sample copy of a your state hazardous waste use an EPA identification completed notification form is contact. This address is listed shown on pages 9-10. (Note: A number. EPA and states in the information booklet that few states use a form that is you will receive with the form. use these 12-character different from the one shown. numbers to monitor and Your state agency will send EPA records the information on the you the appropriate form to form and assigns an EPA identifica- track hazardous waste complete.) tion number to the site identified on your form. The EPA number stays activities. You will need to ᮣᮣ Fill in the form as shown in the with the property when ownership example. To complete Item IX use your identification changes. If you move your business, of the form, you will need to number when you send you must notify EPA or the state of identify your hazardous waste your new location and submit a new waste off site to be by its EPA Hazardous Waste form. If another business previously Code. A list of common haz- managed. handled hazardous waste at this ardous wastes and their waste location and obtained an EPA codes can be found on the To obtain an EPA identification Identification Number, you will be insert in this handbook; for a number, you should: assigned the same number after complete list of waste codes, you have notified EPA that you have ᮣᮣ Call or write your state haz- you should consult 40 CFR Part moved to this location. Otherwise, ardous waste management 261, or contact your state or EPA will assign you a new identifica- agency or the hazardous waste regional EPA office or the RCRA tion number. division of your EPA Regional Call Center. The form you office and ask for a copy of receive from your state might EPA Form 8700-12, contain an additional sheet “Notification of Hazardous that provides more space for Waste Activity” (EPA Regional waste codes. Complete one

Call your state agency to determine if you need an EPA identification number. If you do, obtain a copy of EPA Form 8700-12. Fill in the form completely. Send the form to your STATE hazardous waste contact. 8 SQG

SAMPLE “NOTIFICATION OF REGULATED WASTE ACTIVITY” FORM

9 SQG

SAMPLE “NOTIFICATION OF REGULATED WASTE ACTIVITY” FORM (CONTINUED)

10 TIP

t is a good practice never to mix wastes. Mixing Iwastes can create an unsafe work environment and SQG lead to complex and expensive cleanups and disposal.

MANAGING HAZARDOUS WASTE ON SITE

Most small businesses disposal. Limited extensions may ᮣᮣ Use a container made of, or be granted by the state director or lined with, a material that is accumulate some haz- the regional EPA administrator. If compatible with the haz- ardous waste on site for a you exceed these limits, you are ardous waste to be stored. short period of time and considered a TSDF and must (This will prevent the waste obtain an operating permit. Wastes from reacting with or corroding then ship it off site to a generated in small amounts the container.) throughout your facility may be treatment, storage, or dis- ᮣᮣ Keep all containers holding stored in accumulation hazardous waste closed dur- posal facility (TSDF). areas located at or near the point ing storage, except when of generation of the waste. The adding or removing waste. Do total amount of waste that may be Accumulating Your Waste not open, handle, or store accumulated at a satellite area is (e.g., stack) containers in a ccumulating hazardous waste limited to 55 gallons. Once this way that might rupture them, Aon site can pose a threat to quantity has been exceeded, you cause them to leak, or other- human health and the environment, have 3 days to transfer the waste wise fail. so you may keep it only for a short to your designated 180-day (or time without a permit. Before ship- 270-day) storage area. ᮣᮣ Inspect areas where contain- ping the waste for disposal or recy- ers are stored at least weekly. (Note: Different quantity limits apply cling, you are responsible for its Look for leaks and for deterio- to acutely hazardous wastes.) safe management, which includes ration caused by corrosion or safe storage, safe treatment, pre- SQGs must accumulate waste in other factors. venting accidents, and responding tanks or containers, such as 55- ᮣᮣ Maintain the containers in to emergencies in accordance with gallon drums. Your storage tanks good condition. If a container federal regulations. and containers must be managed leaks, put the hazardous waste according to EPA requirements SQGs can accumulate no more in another container, or contain summarized below: than 13,228 lbs (6,000 kg) of haz- it in some other way that com- ardous waste on site for up to 180 For containers, you must: plies with EPA regulations. days without a permit. You can ᮣᮣ Label each container with the ᮣᮣ Do not mix incompatible accumulate this amount of waste words “HAZARDOUS WASTE” wastes or materials unless for up to 270 days if you must and the date that the waste precautions are taken to it more than 200 miles was generated. prevent certain hazards. away for recovery, treatment, or

Accumulate wastes according to limits estab- lished by EPA for SQGs. Follow the storage and handling procedures required by EPA for SQGs. Follow EPA requirements for equipment testing and maintenance, access to communications or alarms, aisle space, and emergency arrangements 11 with local authorities. SQG

WASTE MINIMIZATION: THE KEY TO BETTER WASTE MANAGEMENT

he easiest and most cost-effective way of managing any waste is not to generate it in the first place. You Tcan decrease the amount of hazardous waste your business produces by developing a few “good house- keeping” habits. Good housekeeping procedures generally save businesses money, and they prevent acci- dents and waste. To help reduce the amount of waste you generate, try the following practices at your business.

ᮣᮣ Do not mix wastes. Do not taken waste minimization ᮣᮣ Make a good faith effort. mix nonhazardous waste with actions such as using fewer SQGs do not have to docu- hazardous waste. Once you solvents to do the same job, ment their waste minimiza- mix anything with listed haz- using solvents that are less tion activities or create a ardous waste, the whole toxic, or switching to a deter- waste minimization plan. You batch becomes hazardous. gent solution. do, however, need to certify Mixing waste can also make on your manifests that you ᮣᮣ Safely store hazardous prod- recycling very difficult, if not have made a good faith ucts and containers. You impossible. A typical example effort to minimize waste gen- can avoid creating more haz- of mixing wastes would be eration when you send your ardous waste by preventing putting nonhazardous clean- waste off site. spills or leaks. Store haz- ing agents in a container of ardous product and waste used hazardous solvents. containers in secure areas, ᮣᮣ Change materials, process- and inspect them frequently es, or both. Businesses can for leaks. When leaks or save money and increase spills occur, materials used efficiency by replacing a to clean them also become material or a process with hazardous waste. another that produces less waste. For example, you could use plastic blast media for paint stripping of metal parts rather than con- ventional solvent stripping.

ᮣᮣ Recycle and reuse manufac- turing materials. Many com- panies routinely put useful components back into pro- ductive use rather than dis- posing of them. Items such as oil, solvents, acids, and metals are commonly recy- cled and used again. In addi- tion, some companies have

12 SQG

with a containment structure, a drainage control system, or a standby tank with adequate capacity.

Treating Your Waste to Meet the Land Disposal Restrictions (LDRs) ost hazardous wastes may Mnot be land disposed unless they meet “treatment standards.” The Land Disposal Restrictions (LDR) program requires that the waste is treated to reduce the haz- ardous constituents to levels set by EPA, or that the waste is treat- ed using a specific technology. It is your responsibility to ensure that your waste is treated to meet LDR For tanks, you must: ᮣᮣ Use the National Fire treatment standards before it is Protection Association’s ᮣᮣ Label each tank with the land disposed. (See page 17 for a (NFPA’s) buffer zone require- words “HAZARDOUS WASTE” description of required LDR ments for covered tanks con- and the date that the waste notices.) Most SQGs probably will taining ignitable or reactive was generated. have their designated TSDF do this wastes. These requirements treatment. If you choose to treat ᮣᮣ Store only waste that will not specify distances considered your waste yourself to meet LDR cause the tank or the inner to be safe buffer zones for treatment standards, there are liner of the tank to rupture, various ignitable or reactive additional requirements including leak, corrode, or fail. wastes. You can reach the waste analysis plans, notifications, ᮣᮣ Equip tanks that have an NFPA at 617 770-3000. and certifications. To learn about automatic waste feed with a ᮣᮣ Do not mix incompatible these requirements, contact the waste feed cutoff system, or a wastes or materials unless RCRA Call Center, your state bypass system for use in the precautions are taken to pre- agency, or EPA regional office, and event of a leak or overflow. vent certain hazards. consult 40 CFR Part 268. ᮣᮣ Inspect discharge control and ᮣᮣ Do not place ignitable or reac- Preventing Accidents monitoring equipment and the tive wastes in tanks unless level of waste in uncovered certain precautions are taken. henever you store hazardous tanks at least once each waste on site, you must mini- ᮣᮣ Provide at least 2 feet (60 W operating day. Inspect the mize the potential risks from fires, centimeters) of freeboard tanks and surrounding areas explosions, or other accidents. (space at the top of each for leaks or other problems tank) in uncovered tanks, (such as corrosion) at least unless the tank is equipped weekly.

13 SQG

All SQGs that store hazardous waste on site must be equipped IF YOU THINK YOU HAVE AN EMERGENCY, with: IMMEDIATELY CALL 911 AND THE NATIONAL RESPONSE CENTER AT 800 424-8802. ᮣᮣ An internal communications or alarm system capable of pro- n the event of a fire, explosion, the situation and help you make viding immediate emergency Ior other release of hazardous appropriate emergency deci- instruction (voice or signal) to waste that could threaten sions. In many cases, you will all personnel. human health outside the facili- find that the problem you faced ty, or if you think that a spill has was not a true emergency, but it ᮣᮣ A device, such as a telephone reached surface water, call the is better to call if you are not (immediately available at the National Response Center to sure. Serious penalties exist for scene of operations) or a report the emergency. The failing to report emergencies. hand-held, two-way radio, Response Center will evaluate capable of summoning emer- gency assistance from local police and fire departments or ers, and local , as appro- ardous waste is stored?” or “What emergency response teams. priate, to provide services in the if I spill hazardous waste, or one of event of an emergency. Ensure my hazardous waste containers ᮣᮣ Portable fire extinguishers, that personnel handling hazardous leaks?” In case of a fire, explo- fire-control devices (including waste have immediate access to sion, or toxic release, having such special extinguishing equip- an alarm or emergency communi- a plan provides an organized and ment, such as those using cations device. coordinated course of action. foam, inert gas, or dry chemi- SQGs are required to establish cals), spill-control materials, You are not required to have a for- basic safety guidelines and and decontamination mal personnel training program, but response procedures to follow in supplies. you must ensure that employees the event of an emergency. handling hazardous waste are famil- ᮣᮣ Water at adequate volume iar with proper handling and emer- Worksheets 1 and 2 (on page 15) and pressure to supply water- gency procedures. In addition, you can help you set up these proce- hose streams, foam-producing must have an emergency coordina- dures. The information on equipment, automatic sprin- tor on the premises or on-call at all Worksheet 1 must be posted near klers, or water spray systems. times, and have basic facility safety your phone. You must ensure that You must test and maintain all information readily accessible. employees are familiar with these equipment to ensure proper opera- procedures. tion. Allow sufficient aisle space to Responding to Emergencies permit the unobstructed movement lthough EPA does not require of personnel, fire protection equip- ASQGs to have a written contin- ment, spill-control equipment, and gency plan, you must be prepared decontamination equipment to any for an emergency at your facility. area of facility operation. Attempt You should also be prepared to to secure arrangements with fire answer a set of “what if” ques- departments, police, emergency tions. For example: “What if there response teams, equipment suppli- is a fire in the area where haz-

14 SQG

Worksheet 1 Fill in and post this information next to your telephone.

EMERGENCY RESPONSE INFORMATION

Emergency Coordinator Spill-Control Materials Name: ______Location(s): ______Telephone: ______Fire Alarm (if present) ______Location(s): ______Fire Extinguisher ______Location(s): ______Fire Department ______Telephone: ______✂ Worksheet 2 Fill in and post this information next to your telephone. Make sure all employees read and are familiar with its contents.

EMERGENCY RESPONSE PROCEDURES

In the event of a spill: Our company name: Contain the flow of hazardous waste ______to the extent possible, and as soon ______as is possible, clean up the haz- ardous waste and any contaminated Our address: materials or soil. ______In the event of a fire: ______Call the fire department and, if safe, Our U.S. EPA identification number: attempt to extinguish the fire using ______a fire extinguisher. Date of accident ______In the event of a fire, explosion, or Time of accident ______other release that could threaten human health outside the facility, or Type of accident (e.g., spill or fire) ______if you know that the spill has Quantity of hazardous waste involved ______reached surface water: Extent of injuries, if any ______Call the National Response Center Estimated quantity and disposition of recovered materials, if any at its 24-hour number (800 424- 8802). Provide the following infor- ______✂ mation:

15 SQG

SHIPPING WASTE OFF SITE

When shipping waste off necessary permits. All TSDFs and Federal regulations allow you to recyclers must have EPA identifica- transport your own hazardous site, SQGs must follow tion numbers. waste to a designated TSDF provid- certain procedures that ed that you comply with DOT rules. Labeling Waste Shipments are designed to ensure Some states, however, do not QGs must properly package, allow this practice. Call DOT and safe transport and proper Slabel, and mark all hazardous your state hazardous waste man- management of the waste. waste shipments, and placard the agement agency regarding applica- vehicles in which these wastes are ble regulations. shipped following Department of Selecting a Treatment, Transportation (DOT) regulations. Storage, and Disposal Most small businesses use a com- Facility (TSDF) mercial transporter to ship haz- QGs may send their waste only ardous waste. These transporters Sto a regulated Treatment, can advise you on specific require- Storage, and Disposal Facility ments for placarding, labeling, (TSDF) or recycler. Most regulated marking, and packaging; however, TSDFs and recyclers will have a you remain responsible for compli- permit from the state or EPA. ance. For additional information, Some, however, may operate under consult the DOT regulations (49 other regulations that do not CFR Parts 172 and 173) or call require a permit. Check with the the DOT hazardous materials infor- appropriate state authorities to be mation line at 202 366-4488 or sure the facility you select has any 800 467-4922.

Package, label, and mark your shipment, and placard the vehicle in which your waste is shipped as specified in DOT regulations. Prepare a hazardous waste manifest to accom- pany your shipment. Include a notice and certification with the first waste shipment. Ensure the proper management of any hazardous waste you ship (even when it is no longer in your possession).

16 SQG

Preparing Hazardous Waste mation on the type and quantity of rent manifest form so that the Manifests the waste being transported, same form may be used by waste instructions for handling the handlers nationwide. Other antici- he Hazardous Waste Manifest waste, and signatures of all par- pated changes include improved System is a set of forms, T ties involved in the off-site treat- tracking procedures and an option reports, and procedures designed ments, recycling, storage, or to complete, send, and store the to seamlessly track hazardous disposal process. Each party also mainfest information electronically. waste from the time it leaves the must retain a copy of the mani- generator until it reaches the off- fest. This process ensures critical Land Disposal Restrictions site waste management facility accountability in the transportation (LDR) Reporting that will store, treat, or dispose of and disposal process. Once the Requirements the hazardous waste. The system waste reaches its destination, the allows the waste generator to egardless of where the waste receiving facility returns a signed verify that its waste has been prop- Ris being sent, the initial ship- copy of the manifest to the genera- erly delivered and that no waste ment of waste subject to LDRs tor, confirming that the waste has has been lost or unaccounted for must be sent to a receiving TSDF been received. in the process. or recycler along with an LDR At press time, the Uniform notice. You must send an addition- The key component of this system Hazardous Waste Manifest system al LDR notice if your waste or is the Uniform Hazardous Waste is in the process of being updated receiving facility changes. This Manifest, which is a multipart form and modernized. Please check the notice must provide information prepared by most generators that Internet at www.epa.gov/ about your waste, such as the EPA transport hazardous waste for off- epaoswer/hazwaste/gener/ hazardous waste code and the site treatment, recycling, storage, manifest/index.htm. LDR treatment standard. The pur- or disposal. The manifest is pose of this notice is to let the required by both the DOT and EPA. EPA expects to standardize the TSDF know that the waste must When completed, it contains infor- content and appearance of the cur-

17 SQG

meet treatment standards before it Closure is land disposed. There is no hen you close your facility, required form for this notice, but you must ensure that all haz- your TSDF may provide a form for W ardous waste has been removed you to use. A certification may from your hazardous waste tanks, also be required in specific situa- discharge-control equipment, and tions. Contact the RCRA Call discharge confinement structures. Center, your state agency, or EPA In addition, any contamination you regional office and consult 40 CFR might have caused must be Part 268 for help with LDR notifica- cleaned up and managed under all tion and certification requirements. applicable hazardous waste Export Notification regulations. f you choose to export your haz- Iardous waste, you must notify EPA 60 days before the intended date of shipment to obtain written consent. EPA’s “Acknowledge-ment of Consent” document must accompany the shipment at all times. For more information on how to obtain the consent to export hazardous waste, contact the RCRA Call Center at 800 424- 9346.

18 SQG

MANAGING USED OIL EPA’s used oil management stan- ᮣᮣ Use. Oils used as lubricants, oil. Physical contaminants can dards are a set of “good house- hydraulic fluids, head transfer include dirt, metal scrapings, or keeping” requirements that fluids, buoyants, and for other sawdust. Chemical contami- encourage used oil handlers to similar purposes are consid- nants could include solvents, recycle used oil instead of dispos- ered used oil. Unused oil halogens, or saltwater. ing of it. Used oil can be collected, such as bottom clean-out The following types of businesses refined and recycled, and used waste from virgin fuel oil stor- handle used oil: again—for the same job or a com- age tanks or virgin fuel oil pletely different task. recovered from a spill do not ᮣᮣ Generators are businesses meet EPA’s definition of used that handle used oil through Used oil is defined as “any oil that oil because these oils have commercial or industrial oper- has been refined from crude oil or never been used. EPA’s defini- ations or from the mainte- any synthetic oil that has been tion also excludes products nance of vehicles and used and, as a result of such use, used as cleaning agents or equipment. Examples include is contaminated by physical or solely for their solvent proper- car repair shops, service sta- chemical impurities.” To meet ties, as well as certain petro- tions, government motor EPA’s definition of used oil, a sub- leum-derived products such pools, grocery stores, metal- stance must meet each of the fol- as and kerosene. working industries, and boat lowing criteria: marinas. Farmers who pro- ᮣᮣ Contaminants. To meet EPA’s ᮣᮣ Origin. Used oil must have duce less than an average of definition, used oil must been refined from crude oil or 25 gallons of used oil per become contaminated as a made from synthetic materi- month are excluded from gen- result of being used. This als. Animal and vegetable oils erator status. Individuals who includes residues and contami- are excluded from EPA’s defi- generate used oil through the nants generated from handling, nition of used oil. maintenance of their personal storing, and processing used vehicles and equipment are

SELECTING A TRANSPORTER OR TSDF/RECYCLER

t is important to choose your transporter and your ᮣᮣ The Better Business Bureau or Chamber of ITSDF carefully because you remain responsible for Commerce in the TSDF’s area, which might have the proper management of your hazardous waste a record of any complaints registered against a even after it has left your site. transporter or a facility.

For help in choosing a transporter or TSDF, check ᮣᮣ Your state hazardous waste management with the following sources: agency or EPA regional office, which can tell you whether the transporter or TSDF has an EPA ᮣᮣ References from business colleagues who have identification number and a permit, if required. used a specific hazardous waste transporter or Facility information, including types and quanti- TSDF. ties of waste managed and violations ᮣᮣ Trade associations for your that might assessed, can be accessed via the Envirofacts keep a file on companies that handle hazardous Internet site at . waste.

19 SQG

not subject to regulation ᮣᮣ Keep containers and tanks in ᮣᮣ Contain spilled oil using sor- under the used oil manage- good condition. Do not allow bent berms or spreading sor- ment standards. tanks to rust, leak, or deterio- bent over the oil and rate. Fix structural defects surrounding area. ᮣᮣ Collection centers and aggre- immediately. gation points are facilities ᮣᮣ Clean up the used oil and that accept small amounts of ᮣᮣ Never store used oil in any- recycle it as you would have used oil and store it until thing other than tanks and before it was spilled. If recy- enough is collected to ship it storage containers. Used oil cling is not possible, you elsewhere for recycling. also can be stored in units must first make sure the used that are permitted to store oil is not a hazardous waste ᮣᮣ Transporters are companies regulated hazardous waste. and dispose of it appropriate- that pick up used oil from all ly. All used cleanup materials, sources and deliver it to re- Oil Leaks or Spills including rags and sorbent refiners, processors, or burners. ᮣᮣ Take steps to prevent leaks booms, that contain used oil Transfer facilities are any struc- and spills. Keep machinery, must also be handled accord- ture or area where used oil is equipment, containers, and ing to the used oil manage- held for longer than 24 hours tanks in good working condi- ment standards. but not longer than 35 days. tion, and be careful when trans- ᮣᮣ Remove, repair, or replace the ᮣᮣ Re-refiners and processors ferring used oil. Keep sorbent defective tank or container are facilities that blend or materials available at the site. immediately. remove impurities from used ᮣᮣ If a leak or spill occurs, stop oil so the oil can be burned Used oil requirements are detailed the oil from flowing at the for energy recovery or reused. in 40 CFR Part 279. For more source. If a leak can’t be information, contact the Emergency ᮣᮣ Burners burn used oil for stopped, put the oil in another Response Division’s Information energy recovery in boilers, holding container or tank. Hotline at 202 260-2342. industrial furnaces, or in haz- ardous waste incinerators.

ᮣᮣ Marketers are handlers that either a) direct shipments of used oil to be burned as fuel in regulated devices or b) claim that certain EPA specifications are met for used oil to be burned for energy recovery in devices that are not regulated. Although different used oil han- dlers have specific requirements, the following requirements are common to all types of handlers: Storage

ᮣᮣ Label all containers and tanks as Used Oil.

20 LQG

SUMMARY OF REQUIREMENTS FOR LARGE QUANTITY GENERATORS If you are a Large Quantity Generator (LQG) (generating more than 2,200 lbs (1,000 kg) per month), you must comply with the full set of hazardous waste regulations. This table summarizes the federal LQG requirements. This is only a summary and does not include all of the LQG requirements. For more details, contact the RCRA Call Center at 800 424-9346, or TDD 800 553-7672, or see 40 CFR Part 262. Be sure to check with your state as well because certain states have additional or more stringent require- ments than the federal government.

LQG Requirements Summary

Hazardous Waste Determination Identify all hazardous wastes you generate. Measure the amount of hazardous waste you (40 CFR Part 262.10) generate per month to determine your generator category (e.g., LQG). Generator Category Determination (40 CFR Part 262.10 (b) and 261.5 (b) and (c))

EPA Identification Numbers Obtain a copy of EPA Form 8700-12, fill out the form, and send it to the contact listed with (40 CFR 262.12) the form. An EPA identification number will be returned to you for your location.

Prepare Hazardous Waste for Shipment Package, label, mark, and placard wastes following Department of Transportation require- Off Site (40 CFR Parts 262.30 - 262.33) ments. Ship waste using hazardous waste transporter.

The Manifest Ship waste to hazardous , storage, disposal, or recycling facility. Ship haz- (40 CFR Parts 262.20 - 262.23, 262.42) ardous waste off site using the manifest system (EPA Form 8700-22) or state equivalent.

Managing Hazardous Waste On Site Accumulate waste for no more than 90 days without a permit. Accumulate waste in contain- (40 CFR Part 262.34) ers, tanks, drip pads, or containment buildings. Comply with specified technical standards for each unit type.

Recordkeeping and Biennial Report Retain specified records for 3 years. Submit biennial report by March 1 of even numbered (40 CFR Parts 262.40 - 262.41) years covering generator activities for the previous year.

Comply with Land Disposal Restrictions Ensure that wastes meet treatment standards prior to land disposal. Send notifications and (40 CFR 268) certifications to TSDF as required. Maintain waste analysis plan if treating on site.

Export/Import Requirements Follow requirements for exports and imports, including notification of intent to export and (40 CFR Subparts E and F) acknowledgement of consent from receiving country.

Air Emissions (40 CFR Part 265, If applicable, use various monitoring and control mechanisms to: Subpart CC) • Control volatile organic compound (VOC) emissions from hazardous waste management activities. • Reduce organic emissions from process vents associated with certain recycling activities and equipment that is in contact with hazardous waste that has significant organic content. • Control VOCs from hazardous waste tanks, surface impoundments, and containers using fixed roofs, floating roofs, or closed-vent systems routed to control devices.

Closure (40 CFR Parts 265.111 and Decontaminate and remove all contaminated equipment, structures, and soil, and minimize 265.114) the need for further maintenance of your site. Meet unit-specific closure standards for tanks, containment buildings, and drip pads.

21 WHERE TO GET MORE HELP EPA and Other Federal Resource Centers Also, see other related sections of For further assistance in RCRA Call Center the Code of Federal Regulations: understanding the haz- U.S. Environmental Protection ᮣ Handling PCBs (40 CFR Part ardous waste regulations Agency 761) 1200 Pennsylvania Ave, NW. applicable to you, contact ᮣ Toxic Release Inventory (TRI) Washington, DC 20460 your state hazardous waste Reporting (40 CFR Part 372) Phone: 800 424-9346, or TDD 800 553-7672. In Washington, ᮣ agency. Other assistance Domestic Sewage Waste DC: 703 412-9810, or resources include the EPA Disposal Reporting (40 CFR TDD 703 412-3323 Part 403) Web: www.epa.gov/epaoswer/hotline Resource Centers (includ- ᮣ Shipping Hazardous Materials Answers questions on matters ing the RCRA Call Center), (49 CFR Parts 171-180) related to solid waste, hazardous or your EPA regional office waste, and underground storage (page 24). tanks. Also can be used to find and order EPA publications.

RCRA in Focus Individual issues of RCRA in • Construction, Demolition & Focus have been written for the Renovation CRA in Focus is a series of following industries: Rshort informational booklets • Metals Manufacturing that describes the RCRA regula- • Dry Cleaning (EPA530-K-99- • Furniture Manufacturing tions as they apply to specific 005) industry sectors. The documents • Pharmaceutical • Leather Manufacturing explain what RCRA is, who is Manufacturing (EPA530-K-00-002) regulated, and what hazardous • waste is; provide a sample life • Motor Freight & Railroad cycle of a RCRA waste in each Transportation (EPA530-K- Copies of RCRA in Focus can be industry; include a quick refer- 00-003) obtained by contacting the RCRA Call Center at 800 424-9346 or ence chart of all applicable • Photo Processing (EPA530- TDD 800 553-7672 and request- RCRA regulations and a series K-99-002) of waste minimization sugges- ing the document numbers list- tions for various specific indus- • Printing (EPA530-K-97-007) ed above. You can also view the documents online at trial processes; and provide • Vehicle Maintenance . will cover: • Wood Preserving/Wood Products

22 Small Business Ombudsman RCRA Docket Information Center Information Resource Center Clearinghouse/Hotline (RIC) U.S. Environmental Protection U.S. Environmental Protection U.S. Environmental Protection Agency Agency Agency Headquarters Library Small Business Ombudsman RCRA Docket Information Center 1200 Pennsylvania Ave, NW. (1230C) (5305W) IRC (3404) 1200 Pennsylvania Ave, NW. 1200 Pennsylvania Ave, NW. Washington, DC 20460 Washington, DC 20460 Washington, DC 20460 Phone: 202 260-5922 Phone: 800 368-5888 or Phone: 703 603-9230 Fax: 202 260-5153 202 260-1211 Fax: 703 603-9234 E-mail: public-access@ Fax: 202 401-2302 E-mail: RCRA-Docket@ epamail.epa.gov Web: www.epa.gov/sbo epamail.epa.gov Web: www.epa.gov/natlibra/hairc Web: www.epa.gov/epahome/ Helps private citizens, small busi- Maintains environmental reference dockets.htm nesses, and smaller communities materials for EPA staff and the with questions on all program Provides public access to all regu- general public, including books, aspects within EPA. latory materials on solid waste and journals, abstracts, newsletters, distributes technical and nontech- and audio-visual materials generat- Department of Transportation nical information on solid waste. ed by government agencies and (DOT) Hotline the private sector. Office of Hazardous Materials Protection Information Standards (DOT) Clearinghouse (PPIC) Methods Information Research and Special Programs U.S. Environmental Protection Communication Exchange (MICE) Administration Agency U.S. Environmental Protection 400 7th Street, SW. 1200 Pennsylvania Ave, NW. Agency Washington, DC 20590-0001 Washington, DC 20460 OSW Methods Team Phone: 202 366-4488 or Phone: 202 260-4659 1200 Pennsylvania Ave, NW. 800 467-4922 Fax: 202 260-0178 (5307W) Fax: 202 366-3753 E-mail: [email protected] Washington, DC 20460 Web: http://hazmat.dot.gov Web: www.epa.gov/opptintr/ Phone: 703 676-4690 or library/libppic.htm 703 308-8855 Answers questions on matters Fax: 703 318-4682 or related to DOT’s hazardous materi- Provides a library and an electronic 703 308-0511 als transportation regulations. bulletin board (accessible by any E-mail: [email protected] PC equipped with a modem) dedi- Web: www.epa.gov/sw-846 cated to information on .

23 EPA Regional Offices EPA Region 3 EPA Region 6 DC, DE, MD, PA, VA, WV AR, LA, NM, OK, TX EPA Region 1 1650 Arch Street 1445 Ross Avenue CT, MA, ME, NH, RI, VT Philadelphia, PA 19103-2029 Suite 1200 1 Congress Street 215 814-5000 or Dallas, TX 75202-2733 Suite 1100 800 438-2474 in Region 3 214 665-2200 or Boston, MA 02114-2023 Library: 215 814-5254 800 887-6063 in Region 6 617 918-1111 or Library: 214 665-6424 800 372-7431 in Region 1 EPA Region 4 Library: 888 372-5427 or AL, FL, GA, KY, MS, NC, SC, TN EPA Region 7 617 918-1990 Atlanta Federal Center IA, KS, MO, NE 61 Forsyth Street, SW 901 North 5th Street EPA Region 2 Atlanta, GA 30303-3104 Kansas City, KS 66101 NJ, NY, PR, VI 404 562-9900 913 551-7000 or 290 Broadway 800 241-1754 in Region 4 800 223-0425 in Region 7 26th Floor Library: 404 562-8190 Library: 913 551-7241 New York, NY 10007-1866 212 637-3000 EPA Region 5 EPA Region 8 Library: 212 637-3185 IL, IN, MI, MN, OH, WI CO,MT,ND,SD,WY,UT 77 West Jackson Boulevard One Denver Place Chicago, IL 60604 999 18th Street 312 353-2000 or Suite 500 800 621-8431 in Region 5 Denver, CO 80202-2466 303 312-6312 or 800 227-8917 in Region 8 EPA Region 9 AS, AZ, CA, GU, HI, MH, MP, NV 75 Hawthorne Street San Francisco, CA 94105 415 744-1305 Library: 415 744-1510 EPA Region 10 AK, ID, OR, WA 1200 Sixth Avenue Seattle, WA 98101 206 553-1200 or 800 424-4372 in Region 10 Library: 206 553-1289

24 Worksheet 3 These questions are geared toward the federal requirements for SQGs but may be helpful for other hazardous waste generators. Use them to help prepare for a visit from a federal, state, or local agency.

Yes No

❑ ❑ Do you have documentation on the amount and kinds of hazardous waste that you generate and on how you determined that they are hazardous?

❑ ❑ Do you have a U.S. EPA identification number?

❑ ❑ Do you ship wastes off site?

❑ ❑ If so, do you know the name of the transporter and the designated TSDF that you use?

❑ ❑ Do you have copies of completed manifests used to ship your hazardous wastes over the past 3 years?

❑ ❑ Are they filled out correctly?

❑ ❑ Have they been signed by the designated TSDF and transporter?

❑ ❑ If you have not received your signed copy of the manifest from the TSDF, have you filed an exception report?

❑ ❑ Is your hazardous waste stored in proper containers or tanks?

❑ ❑ Are the containers or tanks properly dated and/or marked?

❑ ❑ Have you complied with the handling requirements described in this handbook?

❑ ❑ Have you designated an emergency coordinator?

❑ ❑ Have you posted emergency telephone numbers and the location of emergency equipment?

❑ ❑ Are your employees thoroughly familiar with proper waste handling and emergency procedures?

❑ ❑ Do you understand when you need to contact the National Response Center?

❑ ❑ Do you store your waste for no more than 180 days, or 270 days if you ship your waste more than 200 miles?

25 ACRONYMS AND DEFINITIONS

Byproduct DOT—Department of Incompatible Waste Transportation A material that is not one of the A hazardous waste that can cause primary products of a production Federal agency that oversees all corrosion or decay of containment process. Examples of byproducts national transportation systems materials, or is unsuitable for co- are process residues such as slags and regulates the transport of mingling with another waste or or distillation column bottoms. hazardous materials. material because a dangerous reaction might occur. See 40 CFR CESQG—Conditionally Elementary Neutralization Part 265, Appendix V for more Exempt Small Quantity Unit examples. Generator A tank, tank system, container, LDR—Land Disposal A business that generates less transport vehicle, or vessel (includ- Restrictions than 220 lbs (100 kg) per month ing ships) that is designed to con- of hazardous waste. tain and neutralize corrosive The LDR program ensures that waste. toxic constituents present in haz- CFR—Code of Federal ardous waste are properly treated Regulations Implementing Agency before hazardous waste is dis- The CFR is a codification of the EPA regional office or state agency posed of in the land (such as in a general and permanent rules pub- responsible for enforcing the haz- ). lished in the Federal Register by ardous waste regulations. the Executive departments and agencies of the federal govern- ment. The CFR is divided into 50 “titles,” which represent broad areas subject to federal regulation. Each title is divided into chapters, which usually bear the name of the issuing agency.

Commercial Chemical Product A chemical substance that is man- ufactured or formulated for com- mercial or manufacturing use.

Container Any portable device in which a material is stored, transported, treated, disposed of, or otherwise handled.

26 LQG—Large Quantity NFPA—National Fire Reclaimed Material Generator Protection Association Material that is regenerated or A business that generates more NFPA’s mission is to reduce the processed to recover a usable than 2,200 lbs (1,000 kg) per worldwide burden of fire and other product. Examples are the recov- month of hazardous waste. hazards on the quality of life by ery of lead values from spent bat- providing and advocating scientifi- teries and the regeneration of MICE—Methods Information cally based codes and standards, spent solvents. Communication Exchange research, training, and . Recovered Material The MICE service provides NFPA has specific rules for storing answers to questions about test hazardous wastes. A material or byproduct that has methods used to determine been recovered or diverted from PBT—Persistent, whether a waste is hazardous. It solid waste. Does not include Bioaccumulative, and Toxic also takes comments on technical materials or byproducts generated issues regarding EPA’s methods Persistent chemicals are those from, and commonly used within, manual known as Test Methods for that don’t readily break down in an original manufacturing process. Evaluating Solid Waste: the environment and can be trans- Physical/Chemical Methods (SW- ferred among air, water, soils, and Recycled Material 846). sediments. Bioaccumulative chemi- A material that is used, reused, or cals are those that concentrate in reclaimed. MSDS—Material Safety Data animal and plant tissues as a Sheets result of uptake from the surround- Reused Material ing environment or as a result of Chemical manufacturers and A material that is employed as an one organism consuming another. importers prepare detailed techni- ingredient in an industrial process Toxic chemicals, in this context, cal bulletins called Material Safety to make a product, or is used as are those that are hazardous to Data Sheets about the hazards of an effective substitute for a com- human health and the environ- each chemical they produce or mercial product. import. Your suppliers must send ment. EPA has been tasked with focusing on reducing the toxicity of you an MSDS at the time of the Spent Material first shipment of a chemical and wastes in addition to the quantity Any material that has been used any time the MSDS is updated of waste, and its Waste and, as a result of contamination, with new and significant informa- Minimization National Plan focuses can no longer serve the purpose tion about the hazards. MSDSs on reducing PBT wastes. for which it was produced without include information about compo- POTW—Publicly Owned first processing it. nents and contaminants, including Treatment Works exposure limits, physical data, fire SQG—Small Quantity and explosion hazard, toxicity, and A municipal wastewater treatment Generator health hazard data. It also discuss- plant that receives wastewater es emergency and first aid proce- through the public sewer from A business that generates dures and information about households, office buildings, facto- between 220 and 2,200 lbs (100 storage and disposal, and spill or ries and industrial facilities, and and 1,000 kg) per month of haz- leak procedures. other places where people live and ardous waste. work.

27 Sludge Totally Enclosed Treatment TSDF—Treatment, Storage, Facility and Disposal Facility Any solid, semi-solid, or liquid waste generated from a municipal, A facility for the treatment of Refers to a facility that treats, commercial, or - hazardous waste that is directly stores, or disposes of hazardous water treatment plant, water supply connected to an industrial produc- waste; TSDFs have specific treatment plant, or tion process and that is construct- requirements under RCRA. control facility, exclusive of the ed and operated to prevent the treated effluent from a wastewater release of hazardous waste into VOCs—Volatile Organic treatment plant. the environment during treatment. Compounds An example is a pipe in which VOCs are highly evaporative organ- Still Bottom waste acid is neutralized. ic gases that can be produced dur- Residue or byproduct of a distilla- ing the manufacture or use of TCLP—Toxicity tion process such as solvent chemicals such as paints, sol- Characteristic Leaching recycling. vents, and cleaners. Various pollu- Procedure tion control devices can prevent Tank A testing procedure used to deter- the release of VOCs both outdoors A stationary device designed to mine whether a waste is haz- and indoors. contain an accumulation of haz- ardous. The procedure identifies Wastewater Treatment Unit ardous waste and that is con- waste that might leach hazardous structed primarily of nonearthen constituents into ground water if A tank or tank system that is sub- materials (e.g., wood, concrete, improperly managed. ject to regulation under either steel, plastic). Section 402 or 307(b) of the Clean Water Act, and that treats or stores an influent wastewater that is hazardous waste, or that treats or stores a wastewater treatment sludge that is hazardous.

28 1EPA United States Environmental Protection Agency (5305W) Washington, DC 20460

Official Business Penalty for Private Use $300