RCRA

What is hazardous waste? What Subtitle of RCRA are it regulated under?

A RCRA hazardous waste is a waste that either appears on one of three "lists" created by the U.S. Environmental Protection Agency, or, if not on the lists, exhibits one of four "characteristics" of hazardous waste. Hazardous waste is regulated under Subtitle C of RCRA. EPA has developed a comprehensive program to ensure that hazardous waste is managed safely from the moment it is generated to its final disposal (cradle-to-grave).

What is the Basel Convention modeled on? What is the Basel Convention intended to prevent?

Basel Convention is modeled on RCRA - Basel Convention on the Control of Transboundary Movements of Hazardous Waste & their Disposal - Relies on manifest type document - provides global process for informed consent. Packaging & labeling requirements. It is an international treaty that was designed to reduce the movements of hazardous waste between nations, and specifically to prevent transfer of hazardous waste from developed to less developed countries (LDCs). It does not, however, address the movement of radioactive waste. The Convention is also intended to minimize the amount and toxicity of wastes generated, to ensure their environmentally sound management as closely as possible to the source of generation, and to assist LDCs in environmentally sound management of the hazardous and other wastes they generate

What are characteristic wastes? Who has the responsibility for testing to determine what are characteristic wastes? What happens if they are no longer corrosive, ignitable, reactive or toxic?

Characteristic wastes: ignitable, corrosive, reactive or toxic. If no longer exhibits these qualities, then is no longer hazardous waste. Industry burden to test & determine.

What are generators, transporters hazardous waste? What is required of them?

Generators create the waste - Generators - need to determine if is listed (EPA rule) or characteristic (testing) hazardous waste, need to do proper storage & labeling, start the manifest, and keep records of waste generation, tests & reports Transporters - transport the waste to TSD - Hazardous transport handling requirements from EPA & DOT (hazmat); must have proper packaging and labeling, reporting, recordkeeping & manifest updating

What are listed wastes? (EPA lists under rule....) Why is listed waste like the "midas touch" in reverse (think of the mixture rule - what happens to things that are mixed with listed wastes?)

Listed wastes: Listed by EPA regulation as hazardous waste. Routinely contain hazardous wastes/exhibit hazardous qualities. Industry can petition to delist. Too many haz. chemicals for EPA to get to. Listed wastes don't lose designation (like perverse "Midas touch"): Mixture rule: mixture containing listed waste = hazardous waste; Derived from rule: incinerator ash or sludge from treatment of haz waste = hazardous waste, Contained-in policy: whatever contain in (ex. Contaminated soil) becomes hazardous waste

Recycling is a good thing; why is there a concern about "sham recycling" under RCRA?

RCRA is a driver for more recycling in order to avoid having to comply with RCRA, sham recycling may include situations when a secondary material is Ineffective or only marginally effective for the claimed use; its just there to get rid of it

What is solid waste? Can it include liquids? Does it include municipal garbage, irrigation return flows and sewage?

Solid waste = very broad - not just solids, but also liquids & even contained gases Solid waste exemptions: Sewage waste (covered by CWA), Municipal garbage (overburden system & assume local regulation), Irrigation return flows (agriculture), Recycled materials (encourage recycling, but subject to fraud & abuse), Mining waste, Nuclear waste

What are TSDs? What is expected of TSDs? Why are tougher expectations imposed on TSDs?

TSD - The final link in RCRA's cradle-to-grave concept is the treatment, storage, and disposal facility (TSDF) that follows the generator and transporter in the chain of waste management activities. The regulations pertaining to TSDFs are more stringent than those that apply to generators or transporters. Theyre expected to follow disposal standards, monitoring, safety precautions, and detailed record keeping. More strict because they are the end of the line and because they have history of going bankrupt and leaving others holding the bag.

What is a manifest? What do people mean when they say the manifest follows the waste from¬ "cradle to grave"? Why is this piece of paper so important?

The key component of this tracking system is the Uniform Hazardous Waste Manifest, a form required by EPA and the Department of Transportation for all generators who transport, or offer for transport, hazardous waste for off-site treatment, recycling, storage or disposal. Currently, the manifest is a paper document containing multiple copies of a single form. Critical need to document the transmission of hazardous waste from inception (cradle) to transmission (transport, storage) to disposal (grave).

RCRA

Was first enacted in 1976, but didn't really take off until extensive strengthening amendments in 1984. The Resource Conservation and Recovery Act, enacted in 1976, is the principal federal law in the United States governing the disposal of solid waste and hazardous waste.