Transcript RCRA_Show_2000.ppt

Heritage University
Hazardous Waste Regulatory Review
Course
Conducted by:
Gary F. Lindgren, CHMM
Heritage Environmental Services, LLC
Hazardous Waste Regulatory Program
Overview
Hazardous Waste Regulatory Program
Overview
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Resource Conservation and Recovery Act
(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
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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
Hazardous Waste Regulatory Program
Overview
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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"
Basic Requirements of Hazardous
Waste Generators
Basic Determinations
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Identify Wastestreams
Hazardous Waste Determination
Determination of Regulatory Categories
Container Management Standards
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 Standards (cont’d)
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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.
Container Accumulation Area Standards
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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
(cont’d)
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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
Compliance Documentation
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Contingency Plan
Personnel Training Program & Records
Inspections
Manifests and LDR Forms
Biennial Reports
Waste Analyses/Determinations
Waste Minimization Program
EPA’s “New” Definition of Solid Waste
(40 CFR 261.2)
Any Material
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Disposed of or Abandoned in Lieu of
Disposal
Burned, Incinerated or Recycled
“Inherently Waste-like”
Exclusions
“Materials Which Are Not Solid Wastes”
(40 CFR 261.4(a))
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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
“Solid Wastes Which Are Not Hazardous
Wastes”(40 CFR 261.4(b))
Pertinent Exclusions
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Household Wastes
Fossil Fuel Wastes, Except Provided by
40 CFR 266.112
Cement Kiln Dust, Except Provided by 40
CFR 266.112
Pertinent Exclusions
(cont’d)
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Petroleum-Contaminated
Media
and
Debris (D018-D043 Only) From Regulated
UST Releases
Non-terne plated used oil filters if gravity
hot-drained
Pertinent Exclusions
(cont’d)
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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)
Pertinent Exclusions
(cont’d)
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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)
Pertinent Exclusions
(cont’d)

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))
Recycling Exemptions
(40 CFR 261.2)
Five Types of Materials
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Spent Materials
Sludges
Byproducts
Commercial Chemical Products
Scrap Metal
Four Types of Recycling Activities
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Use Constituting Disposal
Burning Waste or Waste Fuels for
Energy Recovery or Using Wastes to
Produce a Fuel
Reclamation of Wastes
Speculative Accumulation
Only Combinations Not Considered Solid
Waste
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Reclamation of Sludges (non-listed)
Reclamation of Byproducts (non-listed)
Reclamation of Commercial Chemical
Products
Speculative Accumulation of Commercial
Products
Note
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Recycling of Scrap Metal Is Excluded
From Regulation at
40 CFR 261.6(a)(3)(ii).
Recycling of Characteristically Hazardous
Used Oil in a Manner Other Than
Blending or Burning Is Excluded From
Regulation at 40 CFR 261.6(a)(4).
Characteristically Hazardous Used Oil
Reclaimed by Blending or Burning Is
Regulated at 40 CFR Part 279.
Materials That Are Used/Reused
(40 CFR 261.2(e)(1))
Materials are Not Solid Wastes Subject
to Regulation When Use/Reuse
Resembles Ordinary Production
Operations or the Use of Commercial
Materials.
Product Use
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Direct Use/Reuse as Ingredient or
Feedstock in Production Processes
Direct Use/Reuse as Effective Substitute
for Commercial Product
Return to Original Production Process in
Which They Were Generated Without First
Being Reclaimed
Exceptions
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Materials Used in a Manner Constituting
Disposal, or Used to Produce Products
that are Applied to the Land
Materials Burned for Energy Recovery,
Used to Produce a Fuel or Contained in
Fuels
Materials Accumulated Speculatively
Exceptions (cont’d)
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Inherently Waste-like Materials Listed at
261.2(d)(1) F020-F023, F026 and F028
No “Reclamation”, as Defined
Solid Waste/Hazardous Waste
Determinations (40 CFR 261.3)
Waste Material
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Excluded From Definition of Solid Waste
(40 CFR 261.4(a) or by Reuse or
Recycling)
Solid Waste
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Excluded from Definition of Hazardous
Waste (40 CFR 261.4(b))
Hazardous Waste
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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)
Lists of Hazardous Wastes
(40 CFR Part 261, Subpart D)
F-list
K-list
P-list
U-list
“Hazardous Wastes from Non-Specific
Sources” (40 CFR 261.31)
“F-List”
Generic Industrial Process Wastes
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Spent Solvents (F001-F005) (Not
Commercial Products or Manufacturing
Process Wastes) - “Solvent Mixture Rule”
Electroplating Wastes (F006, F007, F008,
F009)
Generic Industrial Process Wastes (cont’d)
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Metal Heat-Treating Wastes (F010, F011,
F012)
WWT Sludges from Chemical Conversion
Coating of Aluminum (F019)
Miscellaneous
“Hazardous Wastes from Specific
Sources” (40 CFR 261.32)
“K-List”
Process Wastes from Specified Industries
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Wood Preservation
Inorganic Pigments
Organic Chemicals
Inorganic Chemicals
Pesticides
Explosives
Process Wastes from Specified Industries
(cont’d)
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Petroleum Refining
Iron & Steel
Primary Copper
Primary Lead
Primary Zinc
Primary Aluminum
Process Wastes from Specified Industries
(cont’d)
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Ferroalloys
Secondary Lead
Veterinary Pharmaceuticals
Ink Formulation
Coking
Acute Hazardous (H) Wastes
(40 CFR 261.33(e))
“P-List”
P-List Examples
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Mostly Pesticides, Organic Chemicals,
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)
Toxic (T) Wastes
(40 CFR 261.33(f))
“U-List”
U-List
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Mostly Natural and Synthetic Organics
Listings Include Spill Residues
Note
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.
Characteristics of Hazardous Waste
(40 CFR Part 261, Subpart C)
Ignitability (I) D001
(40 CFR 261.21)
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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
Corrosivity (C) D002
(40 CFR 261.22)
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Aqueous, pH  2 or pH  12.5
Liquid, Corrodes SAE 1020 Steel > 1/4"
Per Year at 130F
Reactivity (R) D003
(40 CFR 261.23)
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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.
Reactivity (R) D003
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EPA Guidance:
Reactive Cyanide (SW8469010): 250 mg HCN/kg
Waste
Reactive Sulfide (SW8469030): 500 mg H2S/kg Waste
NOTE: Guidance retracted in 4/21/98
Internal memo, but not replaced with
alternate test or numeral standards.
Reactivity (R) D003
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Capable of Detonation or
Explosive Reaction
DOT Explosive (Class A or B)
Toxicity (E) D004-D043
(40 CFR 261.24)
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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
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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.
When Does a Solid Waste Become a
Hazardous Waste?
A Waste Becomes Hazardous When . . .
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

Residues from Treatment, Storage, or
Disposal of Listed Hazardous Waste
Remain Hazardous Wastes Unless Delisted
Sludges
 Treatment Residues
 Spill Residues
 Ash
 Air Emission Control Sludge/Dust
 Leachate
(“Derived From” Rule - 40 CFR 261.3(c)(2))
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When Does A Hazardous Waste Cease To
Be A Hazardous Waste?
A Waste Ceases To Be Hazardous When . .
.

Listed Waste, Mixtures With or Derived
From Listed Waste - When It Has Been
Excluded (Delisted) Under 40 CFR 260.20
and 260.22 and Does Not Exhibit Any of
the Characteristics.
A Waste Ceases To Be Hazardous When . .
.

Characteristic Waste - When It No
Longer Exhibits Any of the
Characteristics and Meets LDR
Treatment Standards (UTS) at 40
CFR 268.48.
NOTE: Many UTS limits are Lower
Than Characteristic Concentrations.
Exceptions To The Mixture Rule
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Specified Wastewater Mixtures
Mixtures of Solid Waste and Hazardous
Waste Listed Solely for a Characteristic
(I,C,R, or E), Where Resulting Mixture No
Longer Exhibits Any Characteristics
(F003).
Exceptions To The "Derived From" Rule
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Lime Stabilized Waste Pickle Liquor
Sludge That Is Not Characteristically
Hazardous
Residues From Burning Certain Exempt
Petroleum Refinery Fuels
Exceptions To The "Derived From" Rule
(cont’d)
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Hazardous Debris Meeting Debris LDR
Treatment Standards Using Extraction Or
Destruction Technologies
Delisted Waste Materials
Regulatory Categories
Regulatory Categories (cont’d)
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Solid Waste/Non-Hazardous Industrial
Waste Generator
Conditionally-Exempt Generator (CESQG
<100 Kg/Mo)
Regulatory Categories (cont’d)
Small Quantity Generator (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: The First Four Categories are
Mutually Exclusive at Any One Point In
Time.
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Regulatory Categories (cont’d)
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Generator/Shipper (to Off-site TSD)
Generator Who Stores On-site Under
RCRA Permit or Interim Status
Generator Who Treats On-site By an
Exempted Method or In an Exempted
Manner
Used Oil Generators, Transporters,
Processors/re-refiners, Burners and
Marketers
Regulatory Categories (cont’d)
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Owner/Operator of Underground
Petroleum Or Hazardous Substance
Storage Tank
Generator Who Treats/Disposes On-Site
Under RCRA Permit or Interim Status
Commercial TSD Facility
Standards For Generators
(40 CFR 262)
Standards For Generators
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Determine if Any Solid Wastes Generated
are Hazardous Wastes. (262.11)
Notify EPA & Obtain an EPA Identification
Number Prior to On-Site T,S,D, or Off-Site
Transportation. (262.12)
Keep Records of Waste Analyses &
Determinations for 3 Years. (262.40)
Generators Who Accumulate
Accumulation Time
(40 CFR 262.34)
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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)
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)
 Hazardous Waste Marking/Labeling
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Accumulation Time
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Preparedness and Prevention (40 CFR
265-Subpart C)
Contingency Plan and Emergency
Procedures (40 CFR 265-Subpart D)
Personnel Training (40 CFR 265.16)
Accumulation Time
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Waste Analysis Plan (40 CFR
268.7(a)(5))
- When Treating in Tanks or
Containers On-Site to Meet LDR
Accumulation Time
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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
Note
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Satellite Accumulation Provisions at 40
CFR 262.34(c).
Small Quantity Generator Provisions at 40
CFR 262.34(d).
Use and Management of Containers
(40 CFR 265, Subpart I)
Use and Management of Containers
Condition of Containers
(40 CFR 265.171)
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Containers Must be in Good Condition
Contents of Leaking Containers Must be
Transferred or Container Overpacked
Use and Management of Containers (cont’d)
Compatibility of Waste with Container
(40 CFR 265.172)
Use and Management of Containers (cont’d)
Management of Containers
(40 CFR 265.173)
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Containers Must be Closed During Storage
Containers Must be Handled so as to Avoid
Rupture or Leakage
Use and Management of Containers (cont’d)
Inspections
(40 CFR 265.174)
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At Least Weekly
Use and Management of Containers (cont’d)
Special Requirements for Ignitable or
Reactive Wastes
(40 CFR 265.176)
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Must be Located at Least 50 Feet from
Property Line
Use and Management of Containers (cont’d)
Special Requirements for Incompatible
Wastes
(40 CFR 265.177)
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Must Not be Placed in Same Container
Must be Separated, or Protected by Dike,
Berm, Wall or Other Devices
Use and Management of Containers (cont’d)
Air Emission Standards

Manage All Hazardous Waste in
Containers in Accordance With Subpart
CC of 40 CFR 265
Preparedness and Prevention
(40 CFR Part 265, Subpart C)
Preparedness and Prevention
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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) :
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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
Preparedness and Prevention (cont’d)


Testing and Maintenance of Equipment
(265.33)
Aisle Space Required to Allow
Emergency Response (265.35)
Preparedness and Prevention (cont’d)

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
Contingency Plans
(40 CFR Part 265, Subpart D)
Contents
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Actions of Facility Personnel in Response
to HW Emergencies
Arrangements Made With Local
Authorities
List of Emergency Coordinators
Emergency Equipment List
Evacuation Plan
Personnel Training
(40 CFR 265.16)
Personnel Training
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Who Gets Trained?
What Should the Training Consist of and
Accomplish?
Who Performs the Training?
How Often Is Training Performed?
What Constitutes Appropriate
Documentation?
Note

Compliance With RCRA HWM Training
Requirements Is Not Adequate Training
for OSHA Hazard Communication
Standard or DOT HM-126F Compliance,
and May Not Be Adequate for Compliance
With the OSHA Hazardous Waste and
Emergency Response Operations
Standard.
Requirements for 100-1000 Kg/Month
Small Quantity Generators (40 CFR
262.34(d))
Effective September 22, 1986
Requirements
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Notify and Obtain U.S. EPA ID Number
Accumulate No More Than 6,000 Kg OnSite 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
Requirements (cont’d)
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Follow Container Storage or Tank
Accumulation Requirements
Preparedness and Prevention
Requirements
Emergency Planning and Notification of
Releases
Requirements (cont’d)
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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
Satellite Accumulation
(40 CFR 262.34(c))
Effective June 20, 1985
Satellite Accumulation Points
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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.
Satellite Requirements

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
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.
Satellite Requirements (cont’d)

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Containers Must Be Marked With the
Words "Hazardous Waste" or Other
Words That Identify the Contents of the
Containers.
Accumulation Limit of 55 Gallons of HW (1
Qt. Of Acutely HW) Per Satellite Area.
Satellite Requirements (cont’d)
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
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.
Satellite Requirements (cont’d)

Authorized States Are Not Required to
Adopt the Satellite Accumulation Rules.
Some States Have Set Time Limitations
on the Satellite Accumulation Period
Recycled Used Oil Management
Standards
(40 CFR 279)
Final Rule
 September 10, 1992: Federal Register
(57 FR 41565-41626)
 March 8, 1993: 40 CFR Part 279
Used Oil

Means Any Oil That Has Been Refined
From Crude Oil, or Any Synthetic Oil, That
Has Been Used and As a Result of Such
Use Is Contaminated by Physical or
Chemical Impurities
Categories of Used Oil

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
Lubricants
Hydraulic Fluid
Metalworking Fluid
Insulating Fluid or Coolant
Used Oil Does Not Include

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
Oil or Petroleum-based Products
Virgin Oils
Used Oil Residues or Sludges Resulting
From the Storage, Processing, or Rerefining of Used Oils
Used Oil That Fails the Rebuttal
Listed Oily Hazardous Waste
Regulation of Used Oil


Used Oil Destined for Recycling Is Not
Regulated As Hazardous Waste
EPA Decided Not to List Used Oil
Destined for Either Disposal or Recycling
Used Oil Management Standards


Hazardous Waste and Contaminated
Used Oil Cannot Be Burned in Nonindustrial Boilers
Quality Specifications Are Established for
Used Oil; If Used Oil Cannot Meet These
Specifications, It Is Subject to the
Administrative Controls and Cannot Be
Burned in Non-industrial Boilers
Used Oil Management Standards (cont’d)

Used Oil That Contains More Than 1,000
ppm of Total Halogens (TX) Will
Automatically Be Assumed to Have Been
Mixed With Spent Solvents. This
"Rebuttable Presumption" Will Make the
Used Oil a Listed Hazardous Waste
(F001/F002) Unless It Can Be Proved
Otherwise.
Used Oil Management Standards (cont’d)

Rebutting the F001/F002 Listing
Presumption Could Include Any or All of
the Following Items:


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
MSDS Indicating the Presence of Halogenated
Additives in Virgin Oil
Toxic Organic Management Plan and Other
Evidence of Proper and Adequate Segregation
Practices
Demonstration That Halogenated Solvents
Came From Non-listed Sources
GC/MS Analysis Indicating <100 ppm of Each
Individual F001/F002 Constituent
Used Oil Management Standards (cont’d)



Standards for Used Oil Burners Who Burn
Off-specification Used Oil for Energy
Recovery
Standards for Used Oil Fuel Marketers
Technical Standards for Burning of
Hazardous Waste in Boilers and Industrial
Furnaces Are Codified at 40 CFR Part
266, Subpart H
Used Oil Management Standards (cont’d)
Used Oil Fuel Specification(279.11)
Constituent or Property
Allowable Level
Arsenic
5 ppm max
Cadmium
2 ppm max
Chromium
10 ppm max
Lead
100 ppm max
Flashpoint
100ºF minimum
Total Halogens
4,000 ppm max
Used Oil Management Standards (cont’d)


Under PCB Regulations, Used Oils
Containing PCBs Between 1-50 ppm
(Prior to Dilution) Are Considered OffSpecification
Unanalyzed Used Oils Are Considered to
Be Off-Specifications for PCBs. (40 CFR
761.2(e)(1) & (2) and 40 CFR 279.10(i))
Used Oil Participants






Generators
Collection Center and Aggregation Points
Transporter and Transfer Facilities
Processors and Re-Refiners
Burners of Off-Spec Used Oil
Fuel Marketers
Used Oil Prohibitions




Management in Unpermitted Surface
Impoundments or Waste Piles
Use As Dust Suppressant
Burning Off-spec Used Oil Fuel in NonSpecified Devices
Mixing With Hazardous Waste
Rebuttable Presumption

For Used Oil (SW 846 and 40 CFR 261
Appendix VIII Halogenated Hazardous
Constituents)
Standards for Generators




Mixing Prohibition
Rebuttable Presumption
Comply With SPCC and UST Regulations,
As Applicable
Store Only in Tanks, Containers, or RCRA
Permitted Units
Standards for Generators (cont’d)




Containers/Tanks Must Be in Good
Condition, Not Leaking and
Marked/labeled "Used Oil"
Label/mark Fill Pipes to USTs
Respond to Releases
Use Transporters With EPA Identification
Numbers
Standards for Transporters and Transfer
Facilities





Notify and Obtain EPA Identification Number
Store Used Oil in Labeled Containers/Tanks
Within Secondary Containment With Impervious
Floor for Less Than 35 Days
Track Incoming and Outgoing Used Oil
Determine Total Halogen Content of Used Oil for
Rebuttable Presumption Purposes
Respond to Releases and Properly Manage
Residues
Standards for Processors
and Re-refiners



Notify and Obtain EPA Identification
Number
Determine Total Halogen Content of Used
Oil for Rebuttable Presumption Purposes
Store/process in Containers/tanks That
Are Labeled and in Good Condition Within
Secondary Containment With an
Impervious Floor
Standards for Processors
and Re-refiners (cont’d)




Respond to Releases and Properly
Manage Residues
Preparedness and Prevention
Contingency Plan
Written Analysis Plan
Standards for Processors
and Re-refiners (cont’d)



Operating Record/Tracking Log
Biennial Report
Closure Requirements
A Practical Approach to Land Disposal
Restrictions (40 CFR 268)
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.
General Outline (cont’d)

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.
General Outline (cont’d)


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.
General Outline (cont’d)

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).
General Outline (cont’d)

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.
General Outline (cont’d)

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 NonWastewater for Each Waste Code
Generator Requirements
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
Eight Elements for LDR Compliance (cont’d)



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 Storage Time Limitations.
Eight Elements for LDR Compliance (cont’d)



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.
Universal Waste Rule
(40 CFR 273)
Universal Waste Rule

The Universal Waste Rule Establishes
"Streamlined" Hazardous Waste
Regulations for the Management of
Specific Waste Types Identified by EPA As
"Universal Wastes".
Universal Waste Rule (cont’d)

Universal Wastes Include
 Hazardous Waste Batteries;
 Mercury-containing Thermostats; and
 Hazardous Waste Pesticides Recalled
by the Manufacturer or Collected
During a Pesticide Collection Program.
Universal Waste Rule (cont’d)


Lamps(Fluorescent Light Bulbs) will be
added to Federal VW rules on
01/06/2000.
Generators of Universal Wastes and
Facilities That Store or Manage Universal
Wastes Without Performing Treatment,
Recycling or Disposal Are "Handlers" and
Are Subject to the certain Provisions.
Universal Waste Rule (cont’d)


There Are Management Standards for
Each Type of Universal Waste. In
General, These Standards Require
Management in a Way That Prevents
Releases Into the Environment.
Large Quantity Handlers (Accumulating
5,000 Kg or More at One Time) Must Notify
the USEPA and Receive an EPA ID
Number.
Universal Waste Rule (cont’d)

Handlers May Ship to Other Handlers or to
a Treatment, Recycling, or Disposal
Facility Without Hazardous Waste
Manifests or Land Disposal Restrictions
Notifications. DOT Shipping Papers Must
Accompany DOT Hazardous Materials
Shipments. Small Quantity Handlers Are
Not Required to Track Their Shipments.
Large Quantity Handlers Must Retain a
Record of Each Shipment Received And/or
Sent Off-site and for at Least 3 Years.
Universal Waste Rule (cont’d)

Handlers May Accumulate Universal
Wastes for up to One Year. Must Be Able
to Demonstrate the Length of Time the
Universal Waste Has Been Accumulated.
Universal Waste Rule (cont’d)


Maintaining an Inventory System On-site
Identifying the Date Each Universal Waste
Became a Waste;
Maintaining an Inventory System On-site
Identifying the Earliest Date That Any
Single Waste in a Group of Wastes or
Containers Became a Waste;
Universal Waste Rule (cont’d)
Placing a Waste in a Specific
Accumulation Area and Identifying the
Earliest Date That Any Waste in the
Area Became a Waste; or
 Any Other Method That Clearly
Demonstrates the Length of
Accumulation Time.
Handlers Must Provide Basic Employee
Training.


Universal Waste Rule (cont’d)


Handlers Must Label Universal Wastes
With the Required Wording to Identify the
Waste Type.
Handlers Are Specifically Prohibited From
Diluting or Disposing of Universal Wastes.
Permissible Management Activities for
Handlers Are Specified in Subparts B and
C of Part 273.
Universal Waste Rule (cont’d)


Handlers Must Manage Universal Wastes in
a Way That Prevents Releases. Any
Releases Must Be Contained Immediately.
More Detailed Management Requirements
Are Specified for Each Universal Waste
Type.
The Universal Waste Rule Also Specifies
Requirements
for
Universal
Waste
Transporters
and
Universal
Waste
"Destination Facilities".
Universal Waste Rule (cont’d)


States Are Not Required to Adopt the
Universal Waste Rule, So Even After One
State Adopts the Rule, Wastes That Are
Regulated As Universal Wastes in That
State May Still Be Regulated As Hazardous
Wastes in Other States.
Current state rules for Mercury-containing
lamps are an example of this.
EPA/DOT Regulatory Requirements
Generators Shipping Hazardous Wastes
Off-Site



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 (cont’d)

Verify That Transporter and Designated
TSD Facility Have Valid EPA Identification
Numbers and Relevant Permits
Generators Shipping Hazardous Wastes
Off-Site (cont’d)

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 (cont’d)


Offer the Transporter Appropriate
Placards.
Sign and Date Manifest, Certifying
Shipment Meets EPA and DOT Pretransportation 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 (cont’d)


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 (cont’d)




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.