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Hazardous Waste inYour Community

United StatesEnvironmental ProtectionAgencyEPA530-E-00-001aOctober 2000www.epa.gov/oswSolid Wasteand Emergency Response(5306W)

Generators

A generator is any business or individualwho initiates the production of a haz-ardous waste or who first causes thewaste to become subject to RCRA regula-tions (e.g.,by importing hazardous wastefrom a foreign country into the UnitedStates,or by cleaning up a site contami-nated with a hazardous waste).A wide variety of facilities,common inmost communities,can be hazardouswaste generators. For example,smallbusinesses such as dry cleaners and gasstations,or large-scale operations suchas chemical manufacturing plants,mightproduce hazardous waste as a result of normal business operations. RCRA’s gen-erator regulations are based on EPA’sunderstanding that these businesses arenot heavily involved in hazardous wastemanagement. EPA requires generators tocomply with various “good housekeeping”rules that ensure the waste is properlyidentified and managed but do not overlyburden the generators’ business prac-tices.RCRA regulations also recognize that notall businesses produce the same quanti-ties of hazardous waste. Since managing

azardous wastes are generated and managed in a variety of different set-tings,possibly even in your own community. In order to meet the goals of RCRA and to safeguard human health and the environment in all settings,EPA has established a “cradle-to-grave” waste management system,wherehazardous wastes are regulated by EPA from the point they are first created(“cradle”) until they reach final disposal (“grave”). This fact sheet will help youunderstand what requirements must be met under RCRA in order to manage haz-ardous waste in a safe and protective manner.The three parties involved in the cradle-to-grave lifecycle of a hazardous waste are:generators; transporters; and treatment,storage,or disposal facilities (TSDFs).

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The mission of the U.S.Environmental ProtectionAgency (EPA) is to protect human health and safeguard the environment.One way EPA helps fulfill its mission is by regulat- ing the management and disposal of hazardouswastes under the Resource Conservationand Recovery Act (RCRA).RCRA has the following three general goals: To protect human health and the environment  To reduce waste while con- serving energy and natur- al resources • To reduce or eliminate the generation of hazardous waste.

a larger volume of waste can present a greater risk,per-sons or facilities that generate larger volumes are subject to more stringent regulations. Under RCRA,EPAidentifies three classes of generators based on theamount of waste they produce in a calendar month:large quantity generators (LQGs),small quantity genera-tors (SQGs),and conditionally exempt small quantitygenerators (CESQGs).Of the three generator categories,LQGs are subject tothe most rigid regulations,including the following:•Obtain an EPA identification number prior to manag-ing hazardous waste. These are unique numbersused to track generators’ activities.•Comply with manifest requirements when shippinghazardous waste off site. The manifest is a docu-ment that accompanies the shipment and serves asa tracking mechanism.•Limit the accumulation of hazardous waste to 90days or less.•Accumulate hazardous waste only in specified units:containers,tanks,drip pads,and containment buildings.•Develop a personnel training program,contingencyplans,and emergency procedures.•Submit a “Biennial Report” to EPA every other yeardescribing hazardous waste generation and manage-ment activities.SQGs follow less stringent standards,but they alsohave restrictions on their waste management processesand must comply with the following:•Obtain an EPA identification number prior to manag-ing hazardous waste.•Comply with manifest requirements when shippinghazardous waste off site.•Limit waste accumulation to no more than 180 days(or 270 days if the receiving facility is more than200 miles from the generator).•Accumulate hazardous waste only in tanks orcontainers.•Never accumulate more than 6,000 kg of hazardouswaste on site at any one time.•Designate an emergency coordinator and follow limit-ed emergency response procedures.CESQGs are subject to minimal regulation,including thefollowing:•Never accumulate more than 1,000 kg of hazardouswaste on site at a given time.•Ensure proper delivery of the hazardous waste to afacility that is registered under RCRA to recycle,treat,store,or dispose of solid or hazardous waste.

Transporters

Hazardous waste transporters are responsible forhauling waste between generation and treatmentfacilities by highway,air,water,or rail. In order toensure consistent requirements,EPA’s transporterregulations have been developed jointly with theU.S. Department of Transportation (DOT). DOT hasestablished extensive standards for the transporta-tion of hazardous materials,including containerlabeling,vehicle placarding,emergency response,and packaging standards.In addition to the DOT transportation requirements,EPA has added the following provisions under RCRA:

Hazardous Waste Generator Classification

LQGs:•>1,000 kg (2200 lbs.) hazardous waste•> 1 kg (2.2 lbs.) acute hazardous waste•> 100 kg (220 lbs.) spill cleanup materialcontaining acute hazardous wasteSQGs:•Between 100 and 1,000 kg hazardous wasteCESQGs:•<100 kg hazardous waste•<1 kg acute hazardous waste•<100 kg spill cleanup material containingacute hazardous waste

Treatment,Storage,andDisposal Facilities

TSDFs provide temporary storage and final treatment ordisposal for hazardous wastes. Since they managelarge volumes of waste and conduct activities that maypresent a higher degree of risk,TSDFs are regulatedmore stringently than generators. Some common exam-ples of TSDFs that could exist in your communityinclude hazardous waste landfills,incinerators,and stor-age yards. The RCRA requirements that all TSDFs mustmeet are listed below:•Obtain a permit from EPA detailing how the facilitywill be operated and what types of activities the facil-ity is allowed to perform. TSDFs that were estab-lished prior to RCRA,or that have recently becomesubject to RCRA because of changes in regulations,are allowed to operate without a permit until theirpermit applications are processed. These facilitiesare called interim status facilities.•Obtain an EPA identification number.•Test all hazardous waste to ensure it is acceptableunder individual facility standards.•Maintain security systems,as well as perform routineinspections and provide adequate personnel training.•Adopt measures tominimize and pre-vent accidents,suchas fires or spills,and develop anemergency contin-gency plan.•Meet recordkeepingand reportingrequirements,including the manifest regulations totrack waste. TSDFs also must maintain an operatingrecord that details all waste receipts,treatment meth-ods,and dates of treatment,storage,and disposal.•Submit a “Biennial Report” to EPA detailing the facili-ty’s hazardous waste management activities.In addition to these general facility standards,eachTSDF must also comply with specific design and operat-ing requirements for each hazardous waste manage-ment unit at the facility. A hazardous wastemanagement unit is any unit acceptable under RCRA tostore,treat,or dispose of hazardous waste. Acceptablewaste management units could include tanks,contain-ers,containment buildings,drip pads,surface impound-ments,and waste piles. Acceptable hazardous wastedisposal units are land treatment units,landfills,sur-face impoundments,and waste piles. The degree of reg-ulation varies according to the unit’s purpose (whether•Obtain an EPA identification number before legallytransporting hazardous waste.•Do not accept a shipment of hazardous waste for off-site transportation unless it is accompanied by a man-ifest. Rail and water transporters may carry a shippingpaper instead of a manifest; the manifest will be for-warded to the next highway carrier or the TSDF.•In the event that hazardous waste is dis-charged or spilled during transporta-tion,take immediate action toprotect human health and the envi-ronment. These response actionsmust include notifying appropri-ate authorities and blocking off the discharge area.•Store hazardous waste only tem-porarily for up to 10 days duringthe normal course of transportationat a transfer facility (e.g.,loadingdocks,parking areas).

TSDF ComplianceCategories

•Permitting•General facility standards•Specific unit standards•Financial assurance•Closure•Ground-water monitoring

Main Hazardous Waste Transporter Requirements

•Obtaining an EPA identification number.•Ensuring that a manifest accompanies offsiteshipments of hazardous waste.•Managing hazardous waste spills.

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