RCRA

Employer obligations under the act:

1. Identify all hazardous wastes in the work place. 2. Determine the amount of hazardous waste generated monthly. 3. Properly manage the temporary strage of waste. 4. periodically transport or arrange for transport of waste to a disposal site. 5. Have emergency response plans for leaks and spills. 6. Train employees properly handling hazardous waste. 7. Train employees their responsibilities under the RCRA. 8. Maintain paperwork on hazardous material from the time they are generated until they are recycled, treated or legally disposed of.

Rules for satellite accumulation:

1. The satellite accumulation container must be located at the point of generation and be under control of the operator. 2. Containers must be labeled "hazardous waste" and follow labeling requirements. 3. Accumulation date is not put onto container until moved to storage area. 4. Container must be moved within 3 days of being filled. 5. Container must be approved and kept closed for filling. 6. Do not mix waste in a container.

How long is a generator of hazardous waste responsible for the waste?

30 Years

Determine the amount of waste generated

A generator must do this on a monthly basis.

Ignitability

A liquid having a flashpoint below 140 degrees Fahrenheit A non-liquid capable of spontaneous combustion

Product

A manufactured chemical or compound which has a specific purpose. A Product is not a Hazardous Waste New paint in a can is a product Unused paint in an aerosol can that will be used again is a product.

How does a hazardous product differ from hazardous waste?

A product is a manufactured chemical or compound which has a specific purpose. A hazardous waste is part of a product that is left over or not used, or enters the environment as part of a prodct.

Waste

A waste is that part of a product that is left over or not used, or enters the environment not as part of a product. Over spray paint on spray booth filters Unused paint in an aerosol can that is discarded.

A Container is Empty When:

All wastes are removed No more than one inch remains at bottom of container No more than 3% of product remains in containers greater than 110gal in size Aerosol cans have no more than atmospheric pressure

Characteristic Waste

Characteristic Wastes have one or more specific physical characteristics:

Things that apply to small quantity generators:

Create between 220-2200lbs or 25-300gal of hazardous wastes per month Must comply with all rules for managing wastes Most automotive repair shops may fall within this category, but it should be avoided

Conditionally Exempt Small Quantity Generators

Create less than 220lb or 25gal of wastes per month Best category to be in Is the least expensive and easiest program to administer Protects the environment to the maximum

Things that apply to a large quantity generator:

Creates more than 2200lb or 300gal of hazardous wastes in one month Most expensive status Automotive repair shop does not normally fall within this category

The "K" list

Designated a waste from a specific industry activity, usually associated with manufacturing.

The "P" and "U" list.

Designates a comercial product waste, sush as a commercial chemical discarded after a specific industrial activity.

The "F" list

Designates wastes generated through a non-specific industrial activity or process.

Listed Waste

EPA Hazardous Waste Lists- F,P,K,U F list designates wastes as generated through a non-specific industrial activity or process The majority of automotive repair shop wastes fall under this category (solvents, thinners, cleaners) P and U lists designates a commercial product waste (discarded after a specific industrial activity) Air-conditioning refrigerant is U listed P list chemicals are considered acutely hazardous and are strictly regulated. (SQGs and CESQGs can generate no more than 2.2 lb of p-list wastes) K list designates a waste from a specific industrial activity, usually associated with manufacturing.

An empty container is not considered this.

Hazardous waste.

Rules for Conditionally Exempt

Identify all hazardous wastes on site Determine pounds of generation and accumulation monthly Do not generate more than 220lbs/25gal/mo Never store more than 2200lb at one time Dispose of through a licensed treatment storage disposal

Three Catagories of Hazardous Waste

Listed Characteristic Mixtures

Hazardous Mixture Rule 1

Mixture of a listed or characteristic waste with any other non-hazardous media makes the entire mixture hazardous Hazardous wastes mixed with non-hazardous media increases the amount of hazardous waste, as well as the disposal costs Do not let rain or melting snow mix with stored wastes Contain leaks with the minimum of absorbent

Waste Mixtures

Mixtures of a listed or characteristic waste with any other non-hazardous media makes the entire mixture hazardous.

Hazardous Mixture Rule 2

Never mix different wastes in a container Different wastes may react with each other, causing a release of hazardous wastes into the environment, poisonous fumes, fire, or explosion Mixing makes treatment or recycling very difficult, and increases the cost for doing so If a P-listed waste is mixed with anything else, the company will become a LQG and expenses will increase dramatically

Reactivity

Normally unstable and reacts violently Reacts violently with water Forms an explosive mixture with water Generates toxic gases when mixed with water

Rules for Small Quantity Generators

Register with the EPA and obtain an EPA ID# Identify all hazardous wastes on site Determine generation and accumulation monthly Do not generate more than 2200lbs/300gal per month nor store more than 13,200 lbs Never store any container for more than 180 days, 270 if transportation is over 200 miles

Rules for Large Quantity Generators

Register with the EPA and obtain an EPA ID# Identify all hazardous wastes on site Determine generation and accumulation monthly May accumulate any quantity of waste in containers, tanks, drip pans, and containment buildings for up to 90 days without a permit Complying with "preparedness and prevention" requirements in case of emergencies

The majority of shops fall under this listed waste

The "F" list.

Any substance that is acutely hazardous would be put under this list.

The "P" list

Cradle to Grave

The company is leagally liable for their waste up to 30 years after its generation and disposal.

Hazardous Waste Can Be Minimized by:

Utilizing all the product Recycling Reusing - filtering solvents Recycling batteries and fluids (antifreeze treated and reused) Substituting a hazardous product with a non-hazardous product (replacing solvent based parts washing with detergent based parts washing) Good Housekeeping, have drip pans ready Minimize wastes by maximizing product usage, recycling, substitution and good housekeeping.

Exempt Waste

Wastes that do not count toward the monthly generation and accumulation amounts Lead - acid batteries sent off site for recycle Used oil sent off-site for recycling Universal Wastes: batteries, mercury lamps, fluorescent bulbs

Corrosivity

corrodes steel at a rate greater than one-quarter inch per year

Universal Waste

do not have to be counted for accumulation or storage quantities (collection and recycling of certain widely generated hazardous wastes, examples - batteries, bulbs, lamps)

Toxicity

existing in concentrations above the designated regulatory limit Metals found in filters Pesticides Semi-volatile and volatile organic compounds Found in paints

Oil that is sent off-site or burned locally for energy reclamation is an example of what kind of waste?

recycled

Hazardous waste containers must be checked fro leaks and corrosion:

weekly