GENERATOR REQUIREMENTS KEY TERMS Generator EPA identification number
GENERATOR REQUIREMENTS
KEY TERMS • Generator • EPA identification number • Manifest • Small quantity generator • Conditionally exempt small quantity generator • Tank • Container • Satellite accumulation area 2
KEY CONCEPTS • Applicability • Site-specific • Scope of regulation • Co-generators 3
APPLICABILITY • Produce hazardous waste • First cause hazardous waste to become subject to regulation • Import hazardous waste • Initiate waste shipment to a treatment, storage, or disposal facility 4
HAZARDOUS WASTE IDENTIFICATION • Generators are required to: - Determine if waste is excluded from regulation as a hazardous waste under 40 CFR § 261. 4 - Determine if the waste is listed as hazardous waste in Subpart D of 40 CFR Part 261 - Test a representative sample of the waste to determine if the waste exhibits any of the hazardous waste characteristics in Subpart C of 40 CFR Part 261. 5
GENERATOR SCENARIO: WASTE IDENTIFICATION HIERARCHY • A textile manufacturer who does not normally produce hazardous waste begins to manufacture a new product (tennis shoes) • The new process generates a physically different waste stream than previously generated • All process waste streams are sent for disposal What steps must the manufacturer take to characterize the waste and comply with RCRA? 6
GENERATOR CLASSIFICATION • Large Quantity Generator (LQG) – >1000 kg/mo or >1 kg/mo acute waste • Small quantity generator (SQG) – 100 -1000 kg/mo and < 1 kg/mo acute waste • Conditionally exempt small quantity generator (CESQG) – < 100 kg/mo and < 1 kg/mo acute waste 7
QUANTITY DETERMINATION • All wastes generated at a site (EPA I. D. #) per calendar month • This includes waste in satellite accumulation • Every hazardous waste stream is counted 8
QUANTITY DETERMINATION Wastes not counted: • Wastes excluded from definitions of solid and hazardous wastes under § 261. 4 • Wastes in units exempt under § 264. 1 • Recycled wastes • Wastes used, recycled, and reused on-site without accumulation prior to recycling • Wastes produced from on-site treatment • Hazardous waste shipped off-site if previously counted (§ 261. 5(d)) 9
GENERATOR SCENARIO: CESQG • Plasticland generates 70 kg of F 002 each month and mixes their hazardous waste with their solid waste in a roll-off box • The amount of waste in the roll-off box is 200 kg • The resulting mixture is shipped off-site for disposal Which regulations apply to this generator? 10
ACCUMULATION STANDARDS • LQG - 90 days without a permit • SQG - 180 days without a permit –same labeling, dating, container, requirements as LQG – 270 days for 200 mile transport –On-site accumulation never exceeds 6000 kg • CESQG –On-site accumulation never exceeds 1000 kg 11
ACCUMULATION STANDARDS • Accumulation start date – begins when waste first placed in container/tank • Satellite Accumulation – at or near point of generation – 55 gallons waste or 1 quart acute waste • Satellite waste in excess of 55 gallons or 1 quart must go to regular storage within 3 days 12
GENERATOR SCENARIO: SATELLITE ACCUMULATION • University of Montana’s Chemistry Department is studying a chemical reaction that results in the generation of small amounts of spent solvent • These spent solvents meet the definition of F 005 and are accumulated at the lab workstation until more than 55 gallons are accumulated, at which time the waste is moved to a central storage facility • In addition to the Chemistry Department’s waste, the Biology Department generates 25 kg/month of F 005 (satellite accumulation) and the Physics Department generates 165 kg/month of U 030 When calculating the amount of hazardous waste generated each month, should the University include the waste in the satellite accumulation areas? 13
TREATMENT IN TANKS • Generators can treat in tanks/containers without a permit • Must meet labeling, storage requirements • Must have a WAP and meet LDR for land disposal 14
GENERATOR SCENARIO: ACCUMULATION TIME/ TANK CONTAINER REGULATIONS • Dunn Chemical manufactures laboratory chemicals for commercial use in a process involving a series of tanks, columns, and reactors • Spent materials are periodically cleaned out from the bottom of the process tanks • The spent materials exhibit the characteristic of corrosivity • Upon removal from the tank they are stored for 3 days in a drum, and then transported to an elementary neutralization unit on-site With which regulations must the generator comply regarding this waste? 15
DOCUMENTATION • EPA identification number • Manifest system 16
GENERATOR SCENARIO: SAFETY KLEEN/ MANIFEST/ RECORDKEEPING • Roscoe’s Auto Body Shop leases a parts washer from Safety Kleen • The washer consists of a sink attached to a drum of solvent • The solvent is drawn into the sink through a hose and discharged back into the drum after use • Periodically, Safety Kleen exchanges a fresh unit for the drum of contaminated solvent, and transports the contaminated unit to a Safety Kleen facility for recycling Is a manifest required for transporting the spent unit? If not, what recordkeeping requirements is Roscoe’s subject to? 17
RECORDKEEPING AND REPORTING • Biennial report – generators that ship waste off-site • Exception reporting • Exports and imports of hazardous waste 18
FEDERAL REQUIREMENTS • Number of copies • Pre-transport requirements • Under DOT: – 49 CFR Parts 173, 178, and 179 – 40 CFR Part 172 – 49 CFR § 172. 304 – 49 CFR Part 172 Subpart F 19
SUMMARY • Applicability of Requirement • Standards of Accumulation • Submission of Biennial Reports 20
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