Environmental Insights

Hazardous wastes are substances that you may have used or produced at your facility or in your business and no longer need or want. They can cause serious problems if not properly handled and disposed of, and have the potential to:

• Cause injury or death, or
• Damage or pollute land, air, or water.

Simply defined, a hazardous waste is a waste with properties that make it dangerous or capable of having a harmful effect on human health or the environment. EPA’s hazardous waste rules focus on preventing waste from reaching the environment.

 

HAZARDOUS WASTE GENERATION

Under the Resource Conservation and Recovery Act (RCRA), all generators must determine if their waste is hazardous and must oversee the fate of the waste. Generators must ensure and fully document that the hazardous waste that they produce is properly identified, managed, and treated prior to recycling or disposal. The degree of regulation that applies to each generator depends on the amount of waste that a generator produces.

If a waste meets the definition of a solid waste, the generator must investigate whether the waste is a listed or characteristic hazardous waste, or whether the waste is specifically excluded from regulation as a solid or hazardous waste.

 

LISTED HAZARDOUS WASTE

Listed hazardous waste is waste which:

• Is listed on any of the four lists of hazardous wastes contained in the RCRA regulations, or
• Exhibits one of the characteristics described below, or
• Contains any toxic constituents that have been shown to be harmful to health and evironment.

 

CHARACTERISTIC HAZARDOUS WASTE

Even if a waste does not appear on one of EPA’s lists, it is considered hazardous if the waste possesses one or more of the following characteristics:

• IGNITIBILITY: easily combustible or flammable, such as paint wastes, degreasers, or other solvents;
• CORROSIVITY: dissolves metals, other materials, or burns the skin, such as waste rust removers, waste acid or alkaline cleaning fluids, and waste battery acids;
• REACTIVITY: unstable, undergoes rapid or violent reaction with water or other materials, such as cyanide plating wastes, waste bleaches, and other waste oxidizers; and
• TOXICITY: harmful or fatal when swallowed or in contact with skin, or which pollutes groundwater if it is improperly disposed of on land. Wastes are tested for toxicity using the Toxicity Characteristic Leachate Procedure (TCLP). 

 

LARGE QUANTITY GENERATOR (LQG)

• A large quantity generator (LQG) of hazardous waste is a generator that meets any one of the following criteria:
• Produces over 1000 kg of hazardous waste per month;
• Produces over 1 kg of acute hazardous waste per month;
• Produces over 100 kg of residue or contaminated soil from the cleanup of an acute hazardous waste spill; OR
• Accumulates more than 6000 kg of hazardous waste on-site.

 

SMALL QUANTITY GENERATOR (SQG)

A small quantity generator (SQG) of hazardous waste is a generator that:

• Produces at least 100 but no more than 1000 kg of hazardous waste per month;
• Produces no more than 1 kg of acute hazardous waste per month; AND
• Accumulates no more than 6000 kg of hazardous waste on-site.

Some states have different generator and accumulation categories, and many states allow storage for shorter periods of time and smaller quantities of hazardous waste. An SQG may accumulate hazardous waste on-site for up to 180 days, or 270 days if the waste is to be shipped over 200 miles away for treatment, storage, or disposal.

 

SATELLITE ACCUMULATION

A hazardous waste generator may accumulate up to 55 gallons of hazardous waste or 1 kg of solid acute hazardous waste in a satellite accumulation area (SAA) that is:

• At or near the point of hazardous waste generation, and
• Under the control of the operator of the process generating the waste.

The advantage to using an SAA is that the waste generated there does not have an accumulation time limit.

During accumulation in the SAA, containers must be marked with the words “Hazardous Waste” and include an indication of why the waste is hazardous (e.g., ignitable, corrosive, reactive, toxic). Once the generator accumulates more 55 gallons of hazardous waste or 1 kilogram of solid acute hazardous waste, the generator must mark the container with the date the excess began accumulating. Within three days, the generator must move the excess waste from the SAA to a central accumulation area or send it offsite for treatment or disposal.

 

MANIFEST

The hazardous waste manifest system is a set of forms, reports, and procedures that track hazardous waste from the time it leaves the generating facility until it reaches the off-site waste management facility that will store, treat, or dispose of the hazardous waste.The manifest is required by both DOT and EPA and contains:

• Information on the type and quantity of the waste being transported,
• Instructions for handling the waste, and
• Signature lines for all parties involved in the disposal process.

Each party that handles the waste signs the manifest and retains a copy for themselves. This ensures accountability in the transportation and disposal processes. Once the waste reaches its destination, the receiving facility returns a signed copy of the manifest to the generator, confirming that the waste has been received by the designated facility. Shippers may use paper forms or may opt in to EPA’s electronic manifest system (e-Manifest).