Environmental / RCRA

RCRA stands for the Resource Conservation and Recovery Act. It is the federal law that creates the framework for proper management of hazardous and non-hazardous solid waste. RCRA gives the EPA authority to control hazardous waste from generation to final disposal ('cradle to grave').

The four characteristics are: (1) Ignitability — flash point below 140°F, (2) Corrosivity — pH less than or equal to 2, or greater than or equal to 12.5, (3) Reactivity — unstable, explosive, or reacts violently with water, (4) Toxicity — contains specific contaminants above regulatory levels as determined by the TCLP test.

The three categories are: (1) Very Small Quantity Generator (VSQG) — generates 100 kg or less per month, (2) Small Quantity Generator (SQG) — generates more than 100 kg but less than 1,000 kg per month, (3) Large Quantity Generator (LQG) — generates 1,000 kg or more per month.

Large Quantity Generators (LQGs) may accumulate hazardous waste on-site for up to 90 days without a RCRA storage permit. After 90 days, the waste must be shipped to a permitted treatment, storage, or disposal facility (TSDF). A 30-day extension may be granted for unforeseen circumstances.

SQGs may accumulate hazardous waste on-site for up to 180 days (or 270 days if the waste must be shipped more than 200 miles to a TSDF). The total quantity on-site must never exceed 6,000 kilograms.

Labels must include: the words 'HAZARDOUS WASTE,' the generator's name and address, the EPA waste code(s), the accumulation start date, the composition/physical state of the waste, and the hazard(s) of the waste (e.g., ignitable, corrosive, reactive, toxic).

The accumulation start date begins when the first drop of waste is placed into the container. This date must be clearly marked on the label and is used to calculate compliance with the 90-day (LQG), 180-day (SQG), or applicable storage time limit.

Satellite accumulation allows generators to accumulate up to 55 gallons of hazardous waste (or 1 quart of acutely hazardous waste) at or near the point of generation under the control of the operator. Once the limit is reached, the waste must be moved to the main accumulation area within 3 days and the 90/180-day clock begins.

An EPA ID number is a unique 12-character identifier assigned to each hazardous waste generator, transporter, and treatment/storage/disposal facility. All generators (except VSQGs in some states) must obtain an EPA ID number before treating, storing, transporting, or disposing of hazardous waste.

The Uniform Hazardous Waste Manifest (EPA Form 8700-22) is a shipping document that accompanies hazardous waste from the generator to the TSDF. It tracks the waste from cradle to grave, requires signatures at each point of transfer, and the generator must receive a signed copy back from the TSDF within 35 days.

If a signed manifest is not received within 35 days, the generator must contact the transporter and/or TSDF to determine the status. If still not received within 45 days, the generator must submit an Exception Report to the EPA Regional Administrator or authorized state agency.

CERCLA stands for the Comprehensive Environmental Response, Compensation, and Liability Act (also known as Superfund). It addresses releases of hazardous substances into the environment and the cleanup of contaminated sites. It also establishes reporting requirements for hazardous substance releases.

A Reportable Quantity is the amount of a hazardous substance that, when released to the environment, must be immediately reported to the National Response Center. RQs range from 1 to 5,000 pounds depending on the substance and are listed in 40 CFR 302.4.

The National Response Center number is 1-800-424-8802. You must call immediately when a release of a hazardous substance meets or exceeds the Reportable Quantity. This applies 24 hours a day, 7 days a week.

EPCRA stands for the Emergency Planning and Community Right-to-Know Act. It requires facilities to report the storage, use, and release of hazardous substances to state and local agencies. It gives communities access to information about chemical hazards in their area.

The four sections are: (1) Emergency planning (Sections 301-303), (2) Emergency release notification (Section 304), (3) Hazardous chemical storage reporting — community right-to-know (Sections 311-312), and (4) Toxic chemical release inventory — TRI reporting (Section 313).

A LEPC is a Local Emergency Planning Committee. LEPCs are required under EPCRA to prepare chemical emergency response plans, review them at least annually, and coordinate with facilities that store extremely hazardous substances above threshold planning quantities.

TCLP stands for the Toxicity Characteristic Leaching Procedure. It is a laboratory test used to determine if a waste exhibits the toxicity characteristic by simulating leaching in a landfill. If contaminant concentrations in the extract exceed regulatory levels, the waste is classified as hazardous.

Listed wastes are wastes that appear on one of four EPA lists: F-list (wastes from non-specific sources), K-list (wastes from specific industries), P-list (acutely hazardous discarded commercial chemical products), and U-list (other hazardous discarded commercial chemical products).

The mixture rule states that any mixture of a listed hazardous waste with a non-hazardous solid waste is itself a hazardous waste, regardless of the concentration. The entire mixture must be managed as hazardous waste unless it qualifies for an exclusion.

The derived-from rule states that any waste generated from the treatment, storage, or disposal of a listed hazardous waste is also a hazardous waste. For example, ash from incinerating a listed hazardous waste is still considered hazardous.

LQGs must provide hazardous waste management training to all personnel who handle waste within 6 months of employment or assignment, with annual refresher training thereafter. Training must cover emergency procedures, waste handling, and relevant regulations. Records must be kept until facility closure.

A contingency plan is a document that describes actions to take in response to fires, explosions, or unplanned releases of hazardous waste. LQGs are required to have a contingency plan that includes emergency procedures, coordinator contact information, and evacuation plans. It must be submitted to local emergency responders.

Containers storing hazardous waste must have secondary containment capable of holding 10% of the total volume of all containers or 100% of the volume of the largest container, whichever is greater. The containment must be free of cracks and impervious to the stored materials.

Pollution prevention is reducing or eliminating waste at the source before it is generated, rather than treating or disposing of it after creation. P2 is the highest priority in the EPA's waste management hierarchy and includes process modifications, material substitutions, and improved housekeeping.

From most to least preferred: (1) Source Reduction/Prevention, (2) Recycling/Reuse, (3) Treatment, (4) Disposal. Source reduction is the most preferred because it eliminates waste before it is created.

TSDF stands for Treatment, Storage, and Disposal Facility. These are permitted facilities authorized to receive hazardous waste for treatment (to reduce toxicity), storage (temporary holding), or disposal (permanent placement in a landfill or other unit).

The Land Disposal Restrictions program prohibits the disposal of hazardous waste on land unless it has been treated to meet specific treatment standards. LDR ensures that hazardous constituents are destroyed or immobilized before land disposal to protect groundwater.

Closure requires removing all hazardous waste and residues, decontaminating all equipment and structures, sampling soil and groundwater to verify no contamination, and certifying closure to the EPA or authorized state agency. If contamination is found, corrective action is required.

LQGs must inspect hazardous waste storage areas at least weekly, looking for leaking containers, deterioration, proper labeling, adequate aisle space, and functioning containment systems. Inspection logs must be maintained for at least 3 years.

Acutely hazardous wastes are P-listed wastes that are extremely dangerous in small quantities. A generator of more than 1 kg of acutely hazardous waste per month is classified as an LQG regardless of total waste volume. The satellite accumulation limit for acute waste is only 1 quart.

The generator must: (1) obtain an EPA ID number, (2) properly characterize and identify the waste, (3) package, label, mark, and placard the waste per DOT regulations, (4) prepare a Uniform Hazardous Waste Manifest, and (5) use only permitted/licensed transporters.

A characteristic waste is hazardous because it exhibits one or more of the four characteristics (ignitability, corrosivity, reactivity, toxicity). A listed waste is hazardous because it appears on one of the EPA's four lists (F, K, P, U), regardless of whether it exhibits any characteristic.

Cradle to grave is the RCRA concept that tracks hazardous waste from the point of generation (cradle) through transportation and treatment to final disposal (grave). The manifest system, EPA ID numbers, and recordkeeping requirements ensure accountability at every step.

Universal wastes include batteries, pesticides, mercury-containing equipment, and lamps (fluorescent bulbs). They are common hazardous wastes with streamlined collection and management requirements to encourage recycling and reduce the amount sent to landfills.

An EMS is a systematic framework (based on ISO 14001) for managing environmental responsibilities. DoD installations use EMS to set environmental objectives, implement programs, monitor performance, and ensure compliance with environmental laws including RCRA, CERCLA, and EPCRA.