Understanding the Small Quantity GeneratorHazardous Waste Rules

A Handbook for Small Businesses

Tech WRECProgram

Waste Reduction&

Environmental Compliance

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printed on recycled paper

Table of Contents

The Tech WREC Program ................................................................................................... 3

The Resource Conservation and Recovery Act (RCRA)...................................................... 4

What Is a Hazardous Waste?.............................................................................................. 5Listed Wastes ................................................................................................................. 5Characteristic Wastes..................................................................................................... 5Wastes that May Be Hazardous to Health, but Are Not Regulated Under RCRA ............ 5For Assistance and More Information............................................................................ 6

Acutely Hazardous Wastes ................................................................................................ 7

What You Must Do as a Hazardous-Waste Generator ........................................................ 8

Categories of Hazardous Waste Generators ...................................................................... 9Conditionally Exempt Small Quantity Generators (CESQG) ........................................... 9Small Quantity Generators (SQG) ................................................................................... 9Large Quantity Generators (LQG) ................................................................................. 10

Table 1: Typical Waste Streams Generated by Small Quantity Generators ..................... 11

Figure 1: Generator Requirements .................................................................................. 13

Counting Your Hazardous Wastes ................................................................................... 15Do Count ...................................................................................................................... 15Do Not Count ............................................................................................................... 15

Changing Generator Categories ...................................................................................... 16

Obtaining a U.S. EPA Identification Number ................................................................... 17

Figure 2: Notification of Regulated Waste Activity Form ................................................ 18

Pre-transport Rules ......................................................................................................... 20Uniform Hazardous Waste Manifest ............................................................................ 20

Managing Wastes On Site................................................................................................. 21Storing Hazardous Waste On Site ................................................................................ 21Treating Hazardous Waste On Site............................................................................... 22

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Disposing of Hazardous Waste On Site........................................................................ 22Obtaining a Permit to Store, Treat, or Dispose of Hazardous Waste On Site ............... 23Preparing for and Preventing Accidents ...................................................................... 23Planning for Emergencies ............................................................................................ 24

Shipping Hazardous Waste Off Site................................................................................. 26Choosing a Hazardous Waste Hauler and Designated Waste Management Facility ..... 26Preparing Your Hazardous Wastes for Shipment ......................................................... 27The Uniform Hazardous Waste Manifest ..................................................................... 27 Figure 3: Hazardous Waste Manifest.......................................................................... 29

Maintaining a Safe Environment ..................................................................................... 30The Four Most Important Things to Remember About Managing Your Wastes Properly30Reducing Hazardous Waste ......................................................................................... 30Working with Inspectors .............................................................................................. 30Self-Inspections ........................................................................................................... 31

Appendix A:Hazardous Waste Management Offices ........................................................................ 32

Appendix B:EPA Hazardous Waste Numbers for Waste Streams Commonly Generated by SQGs ... 42

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The Tech WREC Program

The Tech Waste Reduction & EnvironmentalCompliance (WREC) Program of the Georgia TechResearch Institute is a voluntary, non-regulatorytechnical assistance program funded by theGeorgia Legislature through the State UniversitySystem of Georgia.

The purpose of this book is to help small busi-ness owners and managers understand how thefederal hazardous waste management laws affecttheir businesses.

Acknowledgments

This booklet was prepared by the Tech WRECProgram using material provided by the UnitedStates Environmental Protection Agency, Office ofSolid Waste and Emergency Response. The Gen-erator Compliance Program of the HazardousWaste Management Branch, Georgia Environmen-tal Protection Division, provided technical review.

If you have any questions about the Tech WRECprogram, or need further assistance, please callthe Georgia Tech WREC program at 404/894-3806,or if you would like additional information re-garding the management of hazardous waste,please contact the Generator Compliance Pro-gram, Hazardous Waste Management Branch, at404/657–8831.

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The Resource Conservation and Recovery Act(RCRA)

In 1976, Congress passed the Resource Conser-vation and Recovery Act (RCRA), directing theU.S. Environmental Protection Agency (EPA) todevelop and implement a program to protecthuman health and the environment from im-proper hazardous waste management practices.The program is designed to control the manage-ment of hazardous waste from its generation toits ultimate disposal—from “cradle to grave.”

EPA first focused on large companies whichgenerated the greatest portion of hazardouswaste. Business establishments producing lessthan 1000 kilograms (2,200 pounds) of hazard-ous waste in a calendar month (small quantitygenerators or SQGs) were exempted from most ofthe hazardous waste management regulationspublished by EPA in May 1980.

In November 1984, the Hazardous Solid WasteAmendments to RCRA were signed into law. Withthese amendments, Congress directed EPA toestablish new requirements that would bringSQGs generating between 100 and 1000 kilo-grams of hazardous waste in a calendar monthinto the hazardous waste regulatory system. EPAissued final regulations for SQGs on March 24,1986, the requirements were effective as ofSeptember 22, 1986.

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What Is a Hazardous Waste?

A waste is any solid, liquid, or contained gas-eous material that you no longer use, and eitherrecycle, throw away, or store until you haveenough to treat and dispose.

As a result of doing business, a company maygenerate wastes that can cause serious problemsif not handled and disposed of carefully. Suchwastes could cause injury, death, or damage, orpollute land, air, or water.

These wastes are considered hazardous, andthey are currently regulated by federal and statepublic health and environmental safety laws.

There are two ways a waste may be brought intothe hazardous waste regulatory system: listingand identification through characteristics.

Listed Wastes

Your waste is considered hazardous if it appearson any one of the four lists of hazardous wastescontained in the RCRA regulations. These wasteshave been listed because they either exhibit oneof the characteristics described below or containany number of toxic constituents that have beenshown to be harmful to health and the environ-ment. The regulations list over 400 hazardouswastes, including wastes derived from manufac-turing processes and discarded commercialchemical products. Many of the listed hazardouswastes that you are likely to generate are in-cluded in Appendix B of this handbook.

Characteristic Wastes

Even if a waste does not appear on one of theEPA lists, it is considered hazardous if it has oneor more of the following characteristics:

• ignitability: it is easily combustible orflammable. Examples are paint wastes,certain degreasers, or other solvents.

• corrosivity: it dissolves metals, othermaterials, or burns the skin. Examples arewaste rust removers, waste acid, alkalinecleaning fluids, and waste battery acid.

• reactivity: it is unstable or undergoes arapid or violent chemical reaction withwater or other materials. Examples arecyanide plating wastes, waste bleaches, andother waste oxidizers.

• toxicity as determined by Toxicity Charac-teristic Leaching Procedure (TCLP): thewaste contains high concentrations ofheavy metals, specific pesticides andherbicides, and organic chemicals thatcould be released into the groundwater.This category contains eight heavy metals,four pesticides, two herbicides, and twenty-five organic chemicals.

Wastes that May Be Hazardous to Health, but AreNot Regulated Under RCRACertain hazardous wastes are not regulatedunder RCRA, but are regulated under other rules.Some of these wastes include PCBs, asbestos,radioactive wastes, and biomedical/infectiouswastes. For more information, contact your stateor federal agency listed in Appendix A.

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For Assistance and More Information

Your industry may generate other hazardouswastes beyond the examples mentioned above. Itis your responsibility to determine whether yourwastes are hazardous. If you need assistance, call:

• your state hazardous waste managementagency, listed in Appendix A

• EPA regional office, listed in Appendix A

• RCRA/Superfund Hotline800/424-9346in Washington DC202/382-3000

• EPA’s Small Business Ombudsman Hotline800/368-5888

• your national trade association or its localchapter

• in Georgia, contact the Georgia Environmen-tal Protection Division Hazardous WasteManagement Branch at 404/657-8831 or theTech WREC program at 404/894-3806.

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Acutely Hazardous Wastes

Some wastes are considered to be “acutely haz-ardous.” These are wastes that EPA has deter-mined to be so dangerous in small amounts thatthey are regulated the same way as are largeamounts of other hazardous wastes. Acutelyhazardous wastes, for example, may be gener-ated using certain pesticides. They also includedioxin-containing wastes.

If your business generates more than 1 kilogram(approximately 2.2 pounds) of acutely hazardouswastes in a calendar month or stores more thanthat amount for any period of time, you aresubject to all of the regulations that apply togenerators that generate more than 1000 kilo-grams of hazardous waste per calendar month.Contact one of the sources of information listedin Appendix A for more information aboutacutely hazardous wastes.

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What You Must Do as a Hazardous-WasteGenerator

Once your company determines that it is gener-ating hazardous wastes, you should

• determine your generator status;

• notify your state environmental office, forexample the Georgia Environmental Protec-tion Division (GA EPD), of the hazardouswaste activities;

• obtain an EPA Identification Number (inGeorgia, obtain a Generator IdentificationNumber [GIN]) if your company generates220 pounds or more of hazardous waste ina calendar month;

• comply with pre-transport rules;

• manifest and maintain accuraterecordkeeping and reporting;

• make an ongoing effort to minimize waste.

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Categories of Hazardous Waste Generators

In March 1986, the federal rules for hazardouswaste management were modified to bringbusinesses that generate small amounts ofhazardous waste into the regulatory system.Previously, these small quantity generators thatgenerate less than 1000 kilograms (or about2,200 pounds) of hazardous waste in a calendarmonth had been exempt from most hazardouswaste regulations.

The 1986 rules set new requirements specificallyfor those generators that generate between 100and 1000 kilograms of hazardous waste in acalendar month. There are three categories ofhazardous waste generators:

• conditionally exempt small quantity genera-tors (CESQG) generate no more than 100kilograms/month;

• small quantity generators (SQG) generate 100or more and less than 1000 kilograms/month;

• large quantity generators (LQG) generate1000 kilograms or more in a month.

Key: 1 barrel = approximately 200 kilo-grams of hazardous waste, which isabout 55 gallons. This representationassumes the waste is water based(weighs 8.3 pounds per gallon). Your

waste could weigh significantly more or lessdepending on the density of the waste.

Conditionally Exempt Small Quantity Generators(CESQG)

If you generate no more than 100 kilo-grams (about 220 pounds) of hazardouswaste and no more than 1 kilogram(about 2 pounds) of acutely hazardous

waste in any calendar month, you are a CESQG.Federal hazardous waste laws require you to:

• identify all hazardous wastes you generate

• send this waste to a hazardous wastefacility or a landfill or other facility ap-proved by the state for industrial or munici-pal wastes

• never accumulate more than 1000 kilogramsof hazardous waste on your property.

Small Quantity Generators (SQG)

If you generate more than 100 and less than1000 kilograms (between 220 and 2,200 pounds)of hazardous waste and no more than 1 kilogram(about 2 pounds) of acutely hazardous waste inany month, you are a SQG. Federal laws requireyou to:

• comply with the 1986 rules for managinghazardous waste, including the accumula-tion, treatment, storage, disposal require-ments described in this handbook.

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For a listing of hazardous waste streams typi-cally generated by SQGs, see Table 1.

Large Quantity Generators (LQG)

If you generate 1000 kilograms (about 2,200pounds or 300 gallons) or more of hazardouswaste, or more than 1 kilogram (about 2 pounds)of acutely hazardous waste in any month, youare a LQG. Federal laws require you to:

• comply with all applicable hazardous wastemanagement rules and submit hazardouswaste reduction plans with biennial re-ports.

See Figure 1 on generator requirements.

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Table 1: Typical Waste Streams Generated by Small Quantity Generators

Industry Waste Stream

Building Cleaning and Maintenance Acid/Bases, Solvents

Chemical Manufacturers Acids/Bases, Cyanide Wastes, Heavy Metals/Inorganics,Ignitable Wastes, Reactives, Solvents

Cleaning Agents and Cosmetics Acids/Bases, Heavy Metals/Inorganics, Ignitable Wastes,Pesticides, Solvents

Construction Acids/Bases, Ignitable Wastes, Solvents

Educational and Vocational Shops Acids/Bases, Ignitable Wastes, Pesticides,Reactives, Solvents

Equipment Repair Acids/Bases, Ignitable Wastes, Lead Acid, Batteries,Solvents

Formulators Acids/Bases, Cyanide Wastes, Heavy Metals/Inorganics,Ignitable Wastes, Pesticides, Reactives, Solvents

Funeral Services Solvents (formaldehyde)

Furniture/Wood Manufacturing Ignitable Wastes, Solvents

& Refinishing

Laboratories Acids/Bases, Heavy Metals/Inorganics,

Ignitable Wastes, Reactives, Solvents

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Industry Waste StreamLaundries and Dry Cleaners Dry Cleaning Filtration, Residues, Solvents

Metal Manufacturing Acids/Bases, Cyanide Wastes, Heavy Metals/Inorganics,Ignitable Wastes, Reactives, Solvents, Spent Plating Wastes

Motor Freight Terminals and Railroad Acids/Bases, Heavy Metals/Inorganics,Transportation Ignitable Wastes, Lead Acid Batteries, Solvents

Other Manufacturing Heavy Metals/Inorganics, Solvents(textiles, plastics, leather)

Pesticide End Users/Application Heavy Metals/Inorganics, Pesticides, SolventsServices

Printing and Allied Industries Acids/Bases, Heavy Metals/Inorganics,Ink Sludges, Spent Plating Wastes, Solvents

Vehicle Maintenance Acids/Bases, Heavy Metals/Inorganics, Ignitable Wastes,Lead Acid Batteries, Solvents

Wood Preserving Preserving Agents

Additional information on typical waste streams is found in Appendix B.

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Figure 1: Generator Requirements

LQG SQG CESQG

Identify the hazardous wastes present ✔ ✔ ✔

Obtain an EPA Generator Identification Number (GIN) ✔ ✔

Package wastes in DOT-approved containers includingproper labels, markings, and accumulation start date ✔ ✔

Store the wastes on-site for no longer than 90 days ✔

Store the wastes on-site for no longer than 180 days(270 days if transporting to a disposal facility more than200 miles away) ✔

Never accumulate more than 13,200 pounds of hazardouswaste (or 2.2 pounds of acutely hazardous waste) on theproperty ✔

Never accumulate more than 2,200 pounds of hazardouswaste materials (or 2.2 pounds of acutely hazardous wastes)on the property ✔

Inspect container storage area weekly and/or inspect tanksdaily and weekly ✔ ✔

Manifest all hazardous wastes using the Uniform HazardousWaste Manifest ✔ ✔

Attach a Land Disposal Restriction (LDR) notification formto each hazardous waste manifest to notify the TSD of landdisposal restriction requirements for the waste. ✔ ✔

A Large Quantity Generator (LQG) generates more than 2,200 pounds of hazardouswaste in a calendar month. A Small Quantity Generator (SQG) generates between 220and 2,200 pounds of hazardous waste in a calendar month. A Conditionally ExemptSmall Quantity Generator (CESQG) generates less than 220 pounds of hazardous wasteor less than 2.2 pounds of acutely hazardous waste in a calendar month.

Following are some of the rules for generators of hazardous wastes. Thisis not a comprehensive listing of all regulations for generators.

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Figure 1: Generator Requirementscontinued

Designate an emergency coordinator and devise contingency,hazard prevention, and personnel training plans ✔ ✔

Retain copies of all signed manifests for at least three yearsfrom the date of transport ✔ ✔

Retain copies of any test results, waste analyses, or otherdeterminations for at least three years from the dateof transport ✔ ✔

Retain copies of LDR determinations, notifications, and wasteanalyses for at least five years from the date of transport ✔ ✔

Submit a report every two years summarizing the typesand quantities of hazardous wastes used, methods ofdisposal employed, and efforts made towards wasteminimization and the results of those efforts ✔

Dispose of all hazardous wastes at an EPA-permittedTreatment, Storage, and Disposal (TSD) facility ✔ ✔

Send the wastes to an EPA-permitted TSD facility or to alandfill or other facility approved by the state for industrialor municipal wastes ✔

LQG SQG CESQG

requires writtenplan

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Counting Your Hazardous Wastes

Do Count

Count all quantities of “listed” and “characteris-tic” hazardous wastes as defined earlier that you:

• accumulate on site for any period of timeprior to subsequent management;

• package and transport off site;

• place directly in a regulated on-site treat-ment or disposal unit;

• generate as still bottoms or sludges andremove from product storage tanks.

Do Not Count

Do not count wastes that:

• are specifically exempted from counting,such as spent lead-acid batteries and usedoil that will be sent off site for reclamationand have not been mixed with hazardouswaste;

• may be left in the bottom of containers thathave been completely emptied throughconventional means, for example, by pour-ing or pumping (containers that held anacutely hazardous waste must be morethoroughly cleaned);

• are left as residue in the bottom of productstorage tanks, if the residue is not removedfrom the product tank;

• you reclaim continuously on site withoutstoring the waste prior to reclamation, suchas dry cleaning solvents (you do have tocount any residue removed from the ma-chine as well as spent cartridge filters);

• you manage in an elementary neutralizationunit, a totally enclosed treatment unit, forexample a solvent still, or a wastewatertreatment unit (an elementary neutraliza-tion unit is a regulated tank, container, ortransport vehicle [including a ship] which isdesigned to contain and neutralize corro-sive wastes);

• are discharged directly to a publicly-ownedtreatment works (POTW) without beingstored or accumulated first (this dischargeto a POTW must comply with the CleanWater Act; POTWs are public utilities,usually owned by the city, county, or state,that treat industrial and domestic sewagefor disposal);

• you have already counted once during thecalendar month and treated on site orreclaimed in some manner, and used again.

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Changing Generator Categories

Under the federal hazardous waste managementsystem, you may be regulated under differentrules at different times, depending on theamount of hazardous waste you generate in agiven month. For example, if in June you gener-ate 100 kilograms or less of hazardous waste,you would be a CESQG for June. If in July yourwaste totals more than 100 kilograms but lessthan 1000 kilograms, your status changes andyour July wastes would be subject to the require-ments for SQG. If in September you generate1000 kilograms or more of hazardous waste,your September waste would be subject to allapplicable hazardous waste management regula-tions, as would all other hazardous waste yougenerated in previous months and mixed withyour September wastes.

If, after counting your wastes, you have deter-mined that you never generate more than 100kilograms/month of hazardous waste, you donot need to read the remainder of this booklet.You are a CESQG and must:

• identify your wastes as hazardous;

• dispose of them in a hazardous wastefacility, or a landfill, or other facility ap-proved by the state for industrial or mu-nicipal wastes;

• never accumulate more than 1000kilograms of hazardous waste at yourfacility, or you become subject to all of the

requirements for 100 to 1000 kilograms/month generators.

If, however, you do generate between 100 and1000 kilograms of hazardous waste in a month,the remainder of this booklet will explain whatyou must do to handle your hazardous wastessafely and legally.

Remember, many states have different generatorcategories and requirements. If you have anyquestions about your generator status, call yourstate agency listed in Appendix A.

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Obtaining a U.S. EPA Identification Number

If your business generates more than 100 kilo-grams of hazardous waste in any calendarmonth, you will need to obtain a U.S. EPA Identi-fication Number. Transporters and facilities thatstore, treat, or dispose of regulated quantities ofhazardous waste must also have U.S. EPA Identifi-cation Numbers. These twelve-character identifi-cation numbers used by the EPA and states arepart of a national data base on hazardous wasteactivities.

To obtain your U.S. EPA Identification Number,call or write your state hazardous waste manage-ment agency or EPA regional office (see AppendixA) and ask for a copy of EPA Form 8700-12,“Notification of Regulated Waste Activity.” Youwill be sent a booklet containing the two-pageform and instructions for filling it out. Figure 2provides a copy of a notification form. Note: Afew states use a form that is different from theform shown in Figure 2. Your state will send youthe appropriate form to complete.

The information from this form will be recordedby the EPA and the state, and you will be as-signed a U.S. EPA Identification Number. Thisnumber will be unique to the site identified onyour form. Use this number on all hazardouswaste shipping papers.

The U.S. EPA Identification Number will stay withthe business site or location. If you move yourbusiness to another location, you must notify the

EPA or the state of your new location and submita new form. If hazardous waste was previouslyhandled at the new location, and it already has aU.S. EPA Identification Number, you will beassigned that number for the site after you havenotified EPA.

Some states have their own identification num-bers. In Georgia, LQGs and SQGs are required toobtain a Generator Identification Number (GIN).Check with your state regulatory office for yourrequirements.

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Figure 2: Notification of Regulated Waste Activity Form

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Pre-transport Rules

As a generator, you must comply with the EPAand the Department of Transportation (DOT)pre-transport requirements. This means thehazardous wastes must be put in proper contain-ers that are marked and labeled properly (includ-ing an accumulation start date), and the trans-porting vehicle must be properly placarded.Your hauler should be able to assist you. Youcan also consult the requirements for packagingand labeling wastes found in the DOT regula-tions (49 CFR Part 172).

You must have a Uniform Hazardous WasteManifest (an EPA standardized form) to serve asdocumentation from origin to destination of thewastes.

Uniform Hazardous Waste Manifest

A hazardous waste manifest is a multicopyshipping document that you must fill out anduse to accompany your hazardous waste ship-ments. These forms are available from threesources and are discussed in more detail later inthis booklet.

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Managing Wastes On Site

The three most important things you must knowabout managing your hazardous wastes on site:

• comply with storage time, quantity, andhandling requirements for containers andtanks;

• obtain a storage, treatment or disposalpermit if you store, treat, or dispose ofhazardous waste on site in a manner re-quiring a permit;

• take adequate precautions to preventaccidents, and be prepared to handle themproperly in the event that they do occur.

Storing Hazardous Waste On Site

SQGs may store no more than 6000 kilograms ofhazardous waste on your site for up to 180 daysor for up to 270 days if the waste must beshipped to a treatment, storage, or disposalfacility that is located over 200 miles away. Ifyou exceed these time or quantity limits, youwill be considered a storage facility and mustobtain a storage permit and meet all of the RCRAstorage requirements. These time limits onstorage are longer than the 90 days allowed togenerators of 1000 kilograms per month ormore. You are allowed to store your waste for aslong as 180 or 270 days so that you will havetime to accumulate enough hazardous waste toship it off site for treatment or disposal eco-nomically.

You can store hazardous waste in 55-gallondrums, tanks, or other containers suitable for thetype of waste generated if you follow certaincommon sense rules that are meant to protecthuman health and the environment and reducethe likelihood of damages or injuries caused byleaks or spills of hazardous wastes.

If you store your wastes in containers, you must:• clearly mark each container with the words

“HAZARDOUS WASTE” and with the dateyou began to collect waste in that con-tainer;

• keep containers in good condition, handlethem carefully, and replace any leakingones;

• not store hazardous waste in a container ifit may cause rupture, leaks, corrosion, orother failure;

• keep containers closed except when you fillor empty them;

• inspect the container for leaks or corrosionevery week;

• make sure that if you are storing ignitableor reactive wastes, containers are placed asfar as possible from your facility propertyline to create a buffer zone;

• NEVER store wastes in the same containerthat could react together to cause fires,leaks, or other releases (see 40 CFR Section265.177 and 40 CFR Part 265 Appendix Vfor examples of incompatible wastes);

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• make sure that the stored waste is taken offsite or treated on site within 180 days, or270 days if you are taking it to a facilitymore than 200 miles away.

If you store your waste in tanks, you must:• not store hazardous waste in a tank if it

may cause rupture, leaks, corrosion, orotherwise cause the tank to fail;

• keep a tank covered or provide at least twofeet of freeboard (space at the top of thetank) in uncovered tanks;

• provide waste feed cutoff or bypass sys-tems to stop the flow in case of problems ifyour tanks have equipment that allow thewaste to flow into them continuously;

• inspect any monitoring or gauging systemson each operating day and inspect thetanks themselves for leaks or corrosionevery week;

• make sure that the stored waste is taken offsite or treated on site within 180 (or 270 ifgoing more than 200 miles away) days;

• use the National Fire ProtectionAssociation’s (NFPA) buffer zone require-ments for tanks containing ignitable orreactive wastes. These requirementsspecify distances considered as safe bufferzones for various liquids based on thecharacteristics of all combustible andflammable liquids. Call your local firedepartment or EPA regional office (seeAppendix A) if you need help.

Treating Hazardous Waste On Site

You may treat your hazardous wastes on yoursite without a special permit providing:

• you treat the accumulated hazardous wastewithin 180 days;

• you comply with the container and tankregulations described above;

• you take steps to prepare for and preventaccidents as described below;

• you treat the hazardous waste in the accu-mulation tank or container.

If you do not meet each of these requirementsand you treat your hazardous waste on your site,you must obtain a hazardous waste treatmentpermit.

Disposing of Hazardous Waste On Site

You may not dispose of your hazardous waste onyour site unless you have obtained a disposalpermit. Under certain circumstances, it may belegal to dispose of certain types of hazardouswaste on your site without a permit. For ex-ample, farmers may dispose of their own wastepesticide provided they triple rinse the emptypesticide container and dispose of the pesticideresidue on their own farm in a manner consistentwith the instructions on the pesticide label. Evenif you are not a farmer, you may be allowed todispose of certain hazardous wastes by discharg-ing them directly into your sewer drain. How-ever, this is not considered good managementpractice and in many communities it may be

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Preparing for and Preventing Accidents

Whenever you generate hazardous waste andstore it on site, you must take the precautionsand steps necessary to prevent any sudden oraccidental release to the environment. Thismeans that you must carefully operate andmaintain your facility to reduce the possibility offire, explosion, or release of hazardous waste.

Your facility must have appropriate types ofemergency communication and fire equipmentfor the kinds of waste handled at your site. Youmust also attempt to make arrangements withlocal fire, police, or hospital officials as neededto ensure that they will be able to respond to anypotential emergencies that could arise. Some ofthe steps you may need to take to prepare foremergencies at your facility include:

• installing and maintaining emergencyequipment such as an alarm, a telephone ora two-way portable radio, fire extinguishers(using water, foam, inert gas, or dry chemi-cals as appropriate to your waste type),hoses, automatic sprinklers, or sprayequipment in your plant so that it is imme-diately available to your employees if thereis an emergency;

• providing enough room for emergencyequipment and response teams to get intoany area in your facility in the event of anemergency;

• writing to local fire, police, and hospitalofficials or state or local emergency re-sponse teams explaining the types of

illegal. For more information concerning wasteswhich may be disposed of in this manner, contactyour local wastewater or sewage treatment officeor your state hazardous waste managementagency (see Appendix A).

Obtaining a Permit to Store, Treat, or Dispose ofHazardous Waste On Site

If you store, treat, or dispose of your hazardouswaste on site in any manner other than thosepermissible as described above, you must obtaina permit. Obtaining a permit to store, treat, ordispose of your hazardous wastes on site can bea costly and time consuming process. The pro-cess is described in Title 40 of the Code of Fed-eral Regulations (40 CFR) Part 270. To obtain sucha permit you must:

• notify EPA or your state regulatory agencyof your hazardous waste activity;

• complete Part A of the permit application;

• comply with the interim status standards asdescribed in 40 CFR Part 265;

• complete Part B of the permit application;

• comply with the standards described in 40CFR parts 264 and 266.

If you are not sure whether you need such apermit, or if you are interested in finding outmore about it, call your state hazardous wastemanagement agency or EPA regional office (seeAppendix A) for help.

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wastes you handle and asking for theircooperation and assistance in handlingemergency situations;

• training employees in the proper use ofequipment and procedures to use in theevent of an accident or emergency.

Planning for Emergencies

A contingency plan is a plan that attempts tolook ahead and prepare for any accidents thatcould possibly occur. It can be thought of as aset of answers to a series of “what if” questions.For example, “What if there is a fire in the areawhere the hazardous waste is stored?” or “What ifI have a spill of hazardous waste or one of mycontainers leaks?” While a specific written con-tingency plan is not required, it is a good idea tomake a list of these questions and answer themon paper. This also may be helpful in informingyour employees about their responsibilities inthe event of an emergency.

Follow these guidelines if you have anemergency:

• In the event of a fire, call the fire depart-ment or attempt to extinguish it using theappropriate type of fire extinguisher.

• In the event of a spill, contain the flow ofhazardous waste to the extent possible andnotify the National Response Center. TheCenter operates a 24-hour toll free number:800/424-8802, or in Washington D.C. call202/426-2675. As soon as possible, clean

up the hazardous waste and any contami-nated materials or soil.

• In the event of a fire, explosion, or otherrelease, immediately notify the NationalResponse Center as required by Superfundregulations. (Superfund is the law that dealswith the cleanup of spills and leaks ofhazardous waste at abandoned hazardouswaste sites).

Post emergency phone numbers and locations ofemergency equipment near telephones andinform all employees of the proper waste han-dling and emergency procedures. You mustappoint an employee to act as emergency coordi-nator to ensure that the appropriate proceduresare carried out in the event an emergency arises.The responsibilities of the emergency coordina-tor are generally that he/she be available 24hours a day (at the facility or by phone) andknow who to contact and what steps to follow inan emergency. For most small businesses, theowner or operator may already perform thesefunctions. You do not need to hire a new em-ployee to fill this role. As stated in 40 CFR Sec-tion 265.55:

“The emergency coordinator must bethoroughly familiar with all aspects ofthe facility’s contingency plan, all opera-tions and activities at the facility, thelocation and characteristics of wastehandled, the location of all recordswithin the facility, and the facility lay-out. In addition, this person must have

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the authority to commit the resourcesneeded to carry out the contingencyplan.”

Avoid potential risks in this area. If you have aserious emergency and you have to call yourlocal fire department or you have a spill thatextends outside your plant or that could reachsurface waters, immediately call the NationalResponse Center at 800/424–8802 and give themthe information they ask for. If you didn’t need tocall, they will tell you so. However, anyone whois supposed to call and does not is subject to a$10,000 fine, a year in jail, or both. An owner ormanager of a business who fails to report arelease also may have to pay for the entire costof repairing any damage, even if the facility wasnot the single or the main cause of the damage.

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Shipping Hazardous Waste Off Site

The three most important things you shouldremember about shipping your hazardous wasteoff site are:

• choose a hauler and facility which haveU.S. EPA identification numbers

• package and label your wastes for shipping

• prepare a hazardous waste manifest form.

Under federal regulations, if you are a 100 to1000 kilograms/month generator, you areallowed to accumulate your hazardous wasteson your premises without a permit for up to 180days (or 270 days if you must ship it more than200 miles) as long as you never accumulatemore than 6000 kilograms. These limits are setso that a small business can accumulate enoughwaste to make shipping and disposal moreeconomical.

Choosing a Hazardous Waste Hauler and DesignatedWaste Management Facility

Carefully choosing a hauler and designating awaste management facility is important. Thehauler will be handling your wastes beyond yourcontrol while you are still responsible for theirproper management. Similarly, the waste man-agement facility will be the final destination ofyour hazardous waste for treatment, storage, ordisposal. Before choosing a hauler or designat-ing a facility, check with the following sources:

• your friends and colleagues in businesswho may have used a specific hazardouswaste hauler or designated facility in thepast;

• your trade association(s) which may keep afile on companies that handle hazardouswastes;

• your Better Business Bureau or Chamber ofCommerce to find out if any complaintshave been registered against a hauler orfacility;

• your state hazardous waste managementagency or EPA regional office (see AppendixA), which will be able to tell you whether ornot a company has a U.S. EPA IdentificationNumber, and may know whether or not thecompany has had any problems.

After checking these sources, contact the haulerand designated hazardous waste managementfacility directly to verify that they have U.S. EPAIdentification Numbers. Some waste manage-ment facilities are permitted to handle onlycertain types of wastes. Always verify thatany waste management facility you workwith is permitted to handle your waste. Alsomake sure that they have the necessary permitsand insurance and that the hauler’s vehicles arein good condition. Checking sources and choos-ing a hauler and designated facility may takesome time—try to begin checking well ahead ofthe time you will need to ship your waste. Care-ful selection is very important.

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Preparing Your Hazardous Wastes for Shipment

When you prepare hazardous wastes for ship-ment, you must put the wastes in containersacceptable for transportation and make sure thecontainers are properly labeled. Your haulershould be able to assist you. If you need addi-tional information, consult the requirements forpackaging and labeling hazardous wastes foundin the Department of Transportation (DOT)regulations (49 CFR Part 172). To find out whatthe regulations are for your wastes, contact yourstate hazardous waste management agency forthe name and telephone number of your statetransportation agency. Your state transportationagency, your hauler, or your designated facilitycan help you understand the DOT requirements.

The Uniform Hazardous Waste Manifest

A hazardous waste manifest is a multicopyshipping document that you must fill out anduse to accompany your hazardous waste ship-ments.

The manifest form is designed so that hazardouswaste shipments can be tracked from their pointof generation to their final destination—the socalled “cradle to grave” system. The hazardouswaste generator, the hauler, and the designatedfacility must each sign this document and keep acopy. The designated facility operator also mustsend a copy back to you so that you can be surethat your shipment arrived. Keep this copy,which will be signed by the hauler and desig-nated facility, on file for three years.

If you do not receive a signed copy from thedesignated hazardous waste management facilitywithin 30 days, it is a good idea for you to findout why and, if necessary, let the state or EPAknow. Remember: just because you have shippedthe hazardous waste off your site and it is nolonger in your possession, your liability has notended. You are potentially liable under Super-fund for any mismanagement of your hazardouswaste. The manifest will help you to track yourwaste during shipment and make sure it arrivesat the proper destination.

You can obtain blank copies of the manifest fromthree sources:

• the state to which you are shipping: usethis source if the state to which you areshipping has its own manifest form. Con-tact the hazardous waste managementagency of that state (see Appendix A), yourhauler, or the designated facility you intendto use for manifest forms.

• the state in which the waste was generated:use this source if the state to which you areshipping your hazardous waste does nothave its own manifest. Contact your hauleror your state hazardous waste agency forblank forms.

• “General” Uniform Hazardous Manifest—EPAForm 8700-22: use this source if neitherstate requires a state-specific manifest.Copies are available from some haulers anddesignated hazardous waste managementfacilities, or may be purchased from somecommercial printers.

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and liability requirements under the FederalMotor Carrier Act, but you may be exempt fromthese if you:

• use a vehicle with a Gross Vehicle WeightRating of less than 10,000 pounds (van orpickup truck);

• transport your wastes for commerce withinyour state in non-bulk shipments (i.e.,containers of less than 3,500 gallons);

• transport hazardous wastes which meet the“limited quantity exclusion” requirementsof Section 172.101 of the DOT regulations.

If you decide to transport your own hazardouswastes, call your state hazardous waste manage-ment agency (see Appendix A) to find out whatstate regulations apply to you. Not all states willallow you to transport your own hazardouswastes. You should also note that if you have anaccident during transport, you are responsiblefor the clean up.

A sample copy of a hazardous waste manifesthas been filled out for you in Figure 3. When yousign the certification in Item 16 you are person-ally confirming that:

• the manifest is complete and accuratelydescribes the shipment;

• the shipment is ready for transport;

• you have considered whether, given yourbudget, your waste management arrange-ments are the best to reduce the amountand hazardous nature of your wastes.

States, haulers, recyclers, and designated facili-ties may require additional information; checkwith them before you prepare a hazardous wasteshipment. Your hazardous waste hauler oftenwill be the best source for packaging and ship-ping information and will help in completing themanifest. EPA has also prepared some industry-specific information to help you complete themanifest. This information is available from EPARegional Offices and a number of trade associa-tions. If you have any trouble obtaining, fillingout, or using the manifest, ask your hauler, yourdesignated facility operator, or one of the con-tacts listed in Appendix A.

Federal regulations allow you to haul yourhazardous waste to a designated facility your-self. You must, however, obtain an EPA trans-porter identification number and comply withapplicable DOT requirements for packaging,labeling, marking, and placarding your ship-ment. There are also financial responsibilities

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Figure 3: Hazardous Waste Manifest

30

Maintaining a Safe Environment

The Four Most Important Things to Remember AboutManaging Your Wastes Properly

• reduce the amount of your hazardous waste

• cooperate with state and local inspectors

• conduct your own self-inspection

• call your state hazardous waste manage-ment agency or the U.S. EPA with yourquestions.

Good hazardous waste management can bethought of as simply “good housekeeping” prac-tices, such as: using and reusing materials asmuch as possible; recycling or reclaiming waste;treating waste to reduce its hazards; and reduc-ing the amount of waste you generate.

Reducing Hazardous Waste

• Do not mix nonhazardous wastes withhazardous wastes. For example, do not putnonhazardous cleaning agents or rags inthe same container as a hazardous solventor the entire contents become subject tothe hazardous waste regulations.

• Avoid mixing several different hazardouswastes. Doing so may make recycling verydifficult, if not impossible, or make dis-posal more expensive.

• Avoid spills or leaks of hazardous products.The materials used to clean up such spills

or leaks also will become hazardous.

• Make sure the original containers of hazard-ous products are completely empty beforeyou throw them away. Use all the product.

• Avoid using more of a hazardous productthan you need. For example, use no moredegreasing solvent or pesticide than youneed to do the job. Also, do not throw awaya container with unused solvent or pesti-cide in it.

If you reduce your hazardous waste, you willsave money on raw materials and reduce thecosts to your business of managing and dispos-ing of hazardous wastes.

Note: Large Quantity Generators of hazardouswaste in Georgia are required to develop hazard-ous waste reduction plans and submit them tothe Georgia Environmental Protection Divisionwith their biennial reports.

Working with Inspectors

Another aspect of good housekeeping is cooper-ating with inspection agencies and using a visitby an inspector as an opportunity to identify andcorrect problems. Accompany your state or localinspectors on a tour of your facility so you canask any questions you may have and receiveadvice on more effective ways of handling yourhazardous wastes. In addition, guide the inspec-tors through your property and explain opera-tions to help them to be more sensitive to theparticular problems or needs of your business.Inspectors can also serve as a valuable source of

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information on recordkeeping, manifests, andsafety requirements specific to your facility.

Self-Inspections

The best way to prepare for a visit from aninspector is to conduct your own self-inspection.Make sure that you can correctly answer thefollowing questions, and make sure you havemet the requirements.

• Do you have some documentation on theamounts and kinds of hazardous waste yougenerate and on how you determined thatthey are hazardous?

• Do you have a U.S. EPA Identification Num-ber (or equivalent state required number,such as the GIN)?

• Do you ship waste off site? If so, by whichhauler and to which designated hazardouswaste management facility?

• Do you have copies of manifests used toship your hazardous waste off site? Arethey filled out correctly? Have they beensigned by the designated facility?

• Is your hazardous waste stored in theproper containers?

• Are the containers properly dated andmarked?

• Have you designated an emergency coordi-nator?

• Have you posted emergency telephone

numbers and the location of emergencyequipment?

• Are your employees thoroughly familiarwith proper waste handling and emergencyprocedures?

• Do you understand when you may need tocontact the National Response Center?

Remember: if you are still uncertain about howto handle your hazardous waste, or have anyquestions concerning the rules for generators of100 to 1000 kilograms/month, there are sourceslisted in Appendix A that you can contact foranswers. In addition, in Georgia you can contactthe Tech WREC program at 404/894–3806. Tak-ing responsibility for proper handling of hazard-ous waste will not only ensure a safer environ-ment and workplace for everyone, but will saveyour business money.

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Appendix A

U.S. EPA Regions

EPA Region I

Connecticut, Massachusetts, Maine, New Hamp-shire, Rhode Island, Vermont

EPA Region II

New Jersey, New York, Puerto Rico, Virgin Islands

EPA Region III

Delaware, Maryland, Pennsylvania, Virginia, WestVirginia, District of Columbia

EPA Region IV

Alabama, Florida, Georgia, Kentucky, Mississippi,North Carolina, South Carolina, Tennessee

EPA Region V

Illinois, Indiana, Michigan, Minnesota, Ohio,Wisconsin

EPA Region VI

Arkansas, Louisiana, New Mexico, Oklahoma,Texas

EPA Region VII

Iowa, Kansas, Missouri, Nebraska

EPA Region VIII

Colorado, Montana, North Dakota, South Dakota,Utah, Wyoming

EPA Region IX

Arizona, California, Hawaii, Nevada, AmericanSamoa, Guam, Trust Territories of the Pacific

EPA Region X

Alaska, Idaho, Oregon, Washington

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EPA Region VI

Hazardous Waste Management DivisionFirst Interstate Bank Tower1445 Ross Avenue, Suite 1200Dallas TX 75202–2733214/665–6444

EPA Region VII

RCRA Branch726 Minnesota AvenueAttn: ART Division/RCRAKansas City KS 66101913/551–7654

EPA Region VIII

Hazardous Waste Management DivisionMC8HWM999 18th Street, Suite 500Denver CO 80202–2405303/294–1361

EPA Region IX

Hazardous Waste Management Division75 Hawthorne Street, H–3–4San Francisco CA 94105415/744–2074

EPA Region X

Waste Management Branch1200 Sixth AvenueSeattle WA 98101206/553–1200

U.S. EPA Regional Offices

EPA Region 1

RCRA Support SectionJFK Federal BuildingBoston, Massachusetts 02203–2211617/573–5750

EPA Region II

Air and Waste Management Division290 Broadway, 20th FloorNew York NY 10007–1866212/637–3725

EPA Region III

RCRA Programs Branch841 Chestnut StreetPhiladelphia PA 19107215/597–1230 (PA, DC)215/597–3884 (VA, WV, DE, MD)

EPA Region IV

Hazardous Waste Management Branch345 Courtland Street NEAtlanta GA 30365404/347–3016

EPA Region V

RCRA ActivitiesPO Box A3587Chicago IL 60690312/886–4001

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State Hazardous Waste Management Agencies

Alabama

Land DivisionAlabama Department of EnvironmentalManagement1751 Cong. Wm. L Dickinson DriveMontgomery AL 36130334/271–7730

Alaska

Department of Environmental Conservation555 CordovaAnchorage AK 99501Program Manager: 907/269–7500fax: 907/269–7652Northern Regional Office (Fairbanks):

907/451–2360Southeast Regional Office (Juneau):

907/789–3151

American Samoa

Environmental Quality CommissionGovernment of American SamoaPago Pago, American Samoa 96799Overseas OperatorCommercial Call: 684/663–2304

Arizona

Hazardous Waste Compliance UnitArizona Department of Environmental Quality3033 N Central AvenuePhoenix AZ 85012Hazardous Waste Management: 602/207–4108

Arkansas

Department of Pollution Control and EcologyPO Box 89138001 National DriveLittle Rock AR 72219–8913501/570–2872

California

Region I:Department of Toxic Substances ControlPO Box 806Sacramento CA 95812–0806916/255–3618

Region II:Department of Toxic Substances Control700 Heinz AvenueSuite 200Berkeley CA 94710510/540–3739

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Delaware

Department of Natural Resources andEnvironmental ControlDivision of Air and Waste ManagementHazardous Waste Management BranchPO Box 1401, 89 Kings HighwayDover DE 19903302/739–4791

District of Columbia

Department of Consumer and Regulatory AffairsEnvironmental Regulation AdministrationHazardous Waste Branch2100 Martin Luther King Jr., Avenue, S.E.Washington DC 20020202/645–6080

Florida

Hazardous Waste Regulation SectionDepartment of Environmental RegulationTwin Towers Office Building2600 Blair Stone RoadTallahassee FL 32399–2400904/488–0300

Georgia

Hazardous Waste Management BranchSuite 1154, East Tower205 Butler Street SEAtlanta GA 30334404/656–7802

Region III:Department of Toxic Substances Control1011 N Grantview AvenueGlendale CA 91201818/551–2830

Region IV:Department of Toxic Substances Control245 West BroadwaySuite 425Longbeach CA 90802310/590–4968

Colorado

Colorado Department of Public Health &Environment

4300 Cherry Creek Drive, SouthHMWMD-HWC-B2Denver CO 80222–1530303/692–3300

Connecticut

Hazardous Material Management UnitDepartment of Environmental ProtectionState Office Building79 Elm StreetHartford CT 06106203/424–3372

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Guam

Guam Environmental Protection AgencyHarmon PlazaComplex Unit B–107103 Orjas StreetHarmon Guam 96911671/646–7579

Hawaii

Department of HealthSolid and Hazardous Waste BranchFive Waterfront Plaza, Suite 250500 Ala Moana BoulevardHonolulu HI 96813

Idaho

Department of Environmental Quality1410 N Hilton, Third FloorBoise ID 83706208/334–5879

Illinois

Environmental Protection AgencyDivision of Land Pollution Control2200 Churchill RoadSpringfield IL 62706217/785–8452

Indiana

Department of Environmental Management100 N Senate AvenuePO Box 6015Indianapolis IN 46206–6015317/232–8925

Iowa

US EPA Region VIIRCRA Branch726 Minnesota AvenueKansas City KS 66101913/551–7646

Kansas

Department of Health and EnvironmentHazardous Waste SectionForbes Field, Building 740Topeka KS 66620913/296–1600

Kentucky

Department of Environmental ProtectionCabinet for Natural Resources and Environmental

ProtectionDivision of Waste ManagementFort Boone Plaza, Building #214 Reilly RoadFrankfort KY 40601502/564–6716

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Louisiana

Department of Environmental QualityDepartment of Solid and Hazardous WastePO Box 82178Baton Rouge LA 70884–2178504/765–0332

Maine

Bureau of Oil and Hazardous Materials ControlDepartment of Environmental ProtectionState House Station #17Augusta ME 04333207/287–2651

Maryland

Maryland Department of the EnvironmentWaste Management AdministrationHazardous Waste Program2500 Broening HighwayBaltimore MD 21224410/631–3343410/631–3344

Massachusetts

Division of Solid and Hazardous WasteDepartment of Environmental ProtectionOne Winter Street, 7th FloorBoston MA 02108617/292–5854

Michigan

Waste Management DivisionMichigan Department of Natural ResourcesBox 30241Lansing MI 48909517/373–2730

Minnesota

Hazardous Waste DivisionPollution Control Agency520 LaFayette Road, NorthSt. Paul MN 55155612/297–8330

Mississippi

Department of Environmental QualityPO Box 10385Jackson MS 39289–0385601/961–5171

Missouri

Hazardous Waste Management ProgramDepartment of Natural ResourcesJefferson Building205 Jefferson StreetJefferson City MO 65101314/751–3176Missouri Hotline: 800/334–6946

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Montana

Solid and Hazardous Waste BureauDepartment of Health and EnvironmentalSciencesPO Box 200901Helena MT 59620–0901406/444–1430

Nebraska

Department of Environmental QualityHazardous Waste Management SectionState House StationPO Box 98922Lincoln NE 68509–8922402/471–2186

Nevada

Division of Environmental ProtectionWaste Management ProgramBureau of Waste Management, Permits Branch333 West Nye LaneCarson City NV 89710702/687–5872

New Hampshire

Division of Public Health ServicesOffice of Waste ManagementBureau of Hazardous Waste Classification and

ManifestsDepartment of Health and Welfare6 Hazen DriveConcord NH 03301–6527603/271–2900

New Jersey

Department of Environmental ProtectionSolid Hazardous Waste Manifest Section120 South Stockton Street, CN–421Trenton NJ 08625–0421609/292–8341

New Mexico

Hazardous Waste Bureau333 West Nye LaneCarson City NM 89710505/827–1536

New York

Department of Environmental ConservationSolid and Hazardous Waste Manifest Section50 Wolfe Road, Room 426Albany NY 12233518/457–6858

North Carolina

Solid and Hazardous Waste Management BranchDivision of Health ServicesDepartment of Human ResourcesPO Box 27687Raleigh NC 27611–7687919/733–2178

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North Dakota

Department of HealthDivision of Waste Management1200 Missouri AvenuePO Box 5520Bismarck ND 58506–5520701/328–5166

Northern Mariana Islands, Commonwealth of

Department of Public Health and EnvironmentalServices

Division of Environmental QualitySaipan, Commonwealth of Mariana Islands 96950Overseas Call: 676/234–6984

Ohio

Ohio EPADivision of Hazardous Waste Management1800 Watermark DriveColumbus OH 43215–1099614/644–2977

Oklahoma

Department of Environmental QualityHazardous Waste Quality Management Service1000 Northeast 10th StreetOklahoma City OK 73117–1212405/271–5338

Oregon

Oregon Department of Environmental QualityHazardous Waste Operations811 Southwest 6th AvenuePortland OR 97204503/229–5356

Pennsylvania

Pennsylvania Department of EnvironmentalProtection

Bureau of Waste ManagementLand, Recycling, & Waste ManagementRachel Carlson State Office BuildingHarrisburg PA 17105–8471717/787–6239

Puerto Rico

Environmental Quality BoardLand Pollution Control AreaInspection, Monitoring, and SurveillancePO Box 11488Santurce PR 00910–1488809/722–0439

Rhode Island

Solid Waste ProgramDepartment of Environmental Management291 Promenade StreetProvidence RI 02908401/277–2797

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South Carolina

Bureau of Solid and Hazardous WasteManagement

Department of Health and Environmental Control2600 Bull StreetColumbia SC 29201803/734–5214

South Dakota

Department of Environment and NaturalResources

Office of Waste Management Programs523 East Capital AvenuePierre SD 57501–3181605/773–3153

Tennessee

Division of Solid Waste ManagementTennessee Department of Public Health401 Church StreetLNC Tower, 5th FloorNashville TN 37243–1535615/532–0780

Texas

Industrial and Hazardous Waste DivisionWaste Evaluation SectionPO Box 13087, Capitol StationAustin TX 78711–3087512/239–2334

Utah

Division of Solid and Hazardous WasteDepartment of Environmental QualityPO Box 144880Salt Lake City UT 84114–4880801/538–6170

Vermont

Hazardous Materials DivisionAgency of Environmental ConservationW Office Building103 South Main StreetWaterbury VT 05671–0404802/241–3888

Virgin Islands

Department of Planning and Natural ResourcesDivision of Environmental ProtectionSuite 231Nisky Center CenterSt. Thomas Virgin Islands 00802809/774–3320

Virginia

Virginia Department of Waste ManagementMonroe Building, 11th FloorRichmond VA 23219804/786–0000

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Washington

Department of EcologyPO Box 47658Olympia WA 98504–7658360/407–6000

West Virginia

Department of Commerce, Labor, andEnvironmental Protection

Division of Environmental ProtectionOffice of Waste Management1356 Hansford StreetCharleston WV 25301

Wisconsin

Department of Natural ResourcesBureau of Solid & Hazardous Waste ManagementPO Box 7921Madison WI 53707608/266–1327

Wyoming

EPA Region VIIIHazardous Waste Management Division

(8HWM–ON)999 18th StreetSuite 500Denver CO 80202–2405303/294–1361

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Appendix B

EPA Hazardous Waste Numbers for WasteStreams Commonly Generated by SQGs

Many SQGs are small businesses and may not befamiliar with how hazardous waste materials areidentified. Appendix B is designed to help SQGsdetermine the EPA Hazardous Waste Numbers fortheir wastes. These numbers are needed tocomplete the “Notification of Regulated WasteActivity” Form 8700–12. Acutely hazardouswastes are marked with an asterisk (*).

The industries and waste streams described heredo not provide a comprehensive list. Except forthe pesticide category, this appendix does notinclude EPA Hazardous Waste Numbers forcommercial chemical products that are hazard-ous when discarded unused. You can find thesechemicals and their EPA Hazardous Waste Num-bers in 40 CFR 261.33. If you are unclear whatHazardous Waste Number should be applied toyour waste stream, consult 40 CFR Part 261.

In those cases where more than one HazardousWaste Number is applicable, all should be used.For example, benzene would have a HazardousWaste Number of D001 if it has a flash point lessthan 140°F; a Hazardous Waste Number of D018if its concentration as a contaminant for thetoxicity characteristic is greater than 0.5 milli-grams per liter; a number of F005 if the waste isgenerated from a non-specific source; and aHazardous Waste Number of U019 if it is a dis-

carded commercial chemical product. Therefore,waste benzene as a discarded commercial chemi-cal product and having a flash point of less than140°F would have the Hazardous Waste NumbersU019 and D001. Soil contaminated with a smallamount of benzene may just be a D018 if theconcentration exceeds 0.5 milligrams per liter,but has a flash point greater than 140°F.

Acids/Bases

Acids, bases or mixtures having a pH less than orequal to 2 or greater than or equal to 12.5, orliquids that corrode steal at 0.25 inches per yearor greater are considered to be corrosive (for acomplete description of corrosive wastes, see 40CFR 261.22, Characteristic of Corrosivity). Allcorrosive materials and solutions have the EPAHazardous Waste Number of D002. The follow-ing are some examples of the more commonlyused corrosives:

Acetic AcidAmmonium HydroxidePerchloric AcidChromic AcidPhosphoric AcidHydrobromic AcidPotassium HydroxideHydrochloric AcidSodium HydroxideHydrofluoric AcidSulfuric AcidNitric AcidOleum

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Contaminant EPA Regulatory levelHW No. (mg/L)

Arsenic D004 5.0Barium D005 100.0Cadmium D006 1.0Chromium D007 5.0Lead D008 5.0Mercury D009 0.2Selenium D010 1.0Silver D011 5.0

Ignitable Wastes

Ignitable wastes include any flammable liquids,nonliquids, and contained gases that have aflashpoint less than 140°F (for a complete de-scription of ignitable wastes, see 40 CFR 261.21,Characteristics of Ignitability). Examples arespent solvents (see also solvents), solvent stillbottoms, ignitable paint wastes (paint removers,brush cleaners and stripping agents), epoxyresins and adhesives (epoxies, rubber cements,and marine glues), and waste inks containingflammable solvents. Unless otherwise specified,all ignitable wastes have an EPA Hazardous WasteNumber of D001.

Some commonly used ignitable compounds are:

mineral spiritslacquer thinneralcohol mixtures greater than 24% alcohol with a

flash point of les than 140°F.

Dry Cleaning Filtration Residues

Cooked powder residue (perchloroethyleneplants only), still residues, and spent cartridgefilters containing perchloroethylene or valcleneare hazardous and have an EPA Hazardous WasteNumber of F002.

Still residues containing petroleum solvents witha flash point less than 140°F are also consideredhazardous, and have an EPA Hazardous WasteNumber of D001.

Heavy Metals/Inorganics

Heavy metals and other inorganic waste materi-als exhibit the characteristic of Toxicity Charac-teristic Leaching Procedure (TCLP) and are con-sidered hazardous if the extract from a represen-tative sample of the waste has any of the specificconstituent concentrations in milligrams per literas shown in 40 CFR 261.24, Table 1. This mayinclude dusts, solutions, wastewater treatmentsludges, paint wastes, waste inks and other suchmaterials which may contain heavy metals/inorganics (note that wastewater treatmentsludges from electroplating operations contain-ing nickel and cyanide, are identified as F006).The following table lists TCLP Toxic contami-nants, their EPA hazardous waste (HW) number,and the regulatory level in milligrams per liter:

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Ink Sludges Containing Chromium and Lead

This includes solvent washes and sludges, caus-tic washes and sludges, or water washes andsludges from cleaning tubs and equipment usedto form ink from pigments, driers, soaps, andstabilizers containing chromium and lead. Allink sludges have an EPA Hazardous Waste Num-ber of K086.

Lead Acid Batteries

Used lead batteries should be reported on thenotification form only if they are not recycled.Used lead batteries that are recycled do not needto be counted in determining the quantity ofwaste that you generate per month, nor do theyrequire a hazardous waste manifest whenshipped off your premises. (Note: Special re-quirements do apply if you recycle your batterieson your own premises — see 40 CFR Part 266.)

Lead Dross D008Spent Acids D002Lead Acid Batteries D008, D002

Organic Wastes

Organic Waste materials exhibit the characteris-tic of TCLP Toxicity and are considered hazard-ous if the extract from a representative sample ofthe waste has any of the specific constituentconcentrations in milligrams per liter as shownin 40 CFR 261.24. The following are TCLP toxic:

Contaminant EPA Regulatory levelHW No. (mg/L)

Arsenic D004 5.0Barium D005 100.0Benzene D018 0.5Cadmium D006 1.0Carbon tetrachloride D019 0.5Chlordane D020 0.03Chlorobenzene D021 100.0Chloroform D022 6.0o-Cresol D023 200.0m-Cresol D024 200.0p-Cresol D025 200.0Cresol D026 200.02,4-D D016 10.01,4-Dichlorobenzene D027 7.51,2-Dichloroethane D028 0.51,1-Dichloroethylene D029 0.72,4-Dinitrotoluene D030 10.13Endrin D012 0.02Heptachlor D031 0.008 (and epoxide)Hexachlorobenzene D032 10.13Hexachlorobutadiene D033 0.5Hexachloroethane D034 3.0Lead D008 5.0

Lindane D013 0.4Mercury D009 0.2Methoxychlor D014 0.2Methoxychlor D014 10.0Methyl ethyl ketone D035 200.0Nitrobenzene D036 2.0Pentrachlorophenol D037 100.0Pyridine D038 15.0

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Contaminant EPARegulatory levelHW No. (mg/L)

Selenium D010 1.0Silver D011 5.0Tetrachloroethylene D039 0.7Toxaphene D015 0.5Trichloroethylene D040 0.52,4,5-Trichlorophenol D041 400.02,4,6-Trichlorophenol D042 2.02,4,5-TP (Silvex) D017 1.0Vinyl chloride D042 0.21 Quantitation limit is greater than the calculated

regulatory level. The quantitation level thenbecomes the regulatory level.

Pesticides

Pesticides, pesticide residues, washing andrinsing solutions, and dips which contain con-stituent concentrations at or above ToxicityCharacteristic regulatory levels are hazardouswaste. The following pesticides would be hazard-ous waste if they are technical grade, unused anddisposed. For a more complete listing, see 40CFR 261.32–33 for specific listed pesticides,discarded commercial chemical products, andother wastes, wastewaters, sludges, and byproducts from pesticide production. Acutelyhazardous wastes are indicated with an asterisk(*).

(Note that while many of these pesticides are nolonger in common use, they are included here forthose cases where they may be found in storage.)

*Aldicarb P070

*Aldrin P004Amitrole U011*Arsenic Pentoxide P011*Arsenic Trioxide P012Cacodylic Acid U136Carbamic Acid, Methylnitroso-Ethyl Ester U178Chlordane U036*Copper Cyanides P0291,2-Dibromo-3-Chloropropane U0661,2-Dichloropropane U0831,3-Dichloropropene U0842,4-Dichlorophenoxy Acetic Acid U240DDT U061*Dieldrin P037*Dimethoate P044Dimethylcarbamoyl Chloride U097*Dinitrocresol P047*Dinoseb P020Disodium Monmomethane

arsonate D004*Disulfoton P039*Endosulfan P050*Endrin P051Ethylmercuric Chloride D009*Famphur P097*Nepthachlor P059Hexachlorobenzene U127Kepone U142Lindane U1292-Methoxy Mercuric Chloride D009Methoxychlor D014*Methyl Parathion P071Monosodium Methanearsonate D004*Nicotine P075

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*Parathion P089Pentachloronitrobenzene U185Pentachlorophenol U242Phenylmercuir Acetate D009*Phorate P094*Strychnine P1082,4,5-Trichlorophenoxy

Acetic Acid U2322-(2,4,5-Trichlorophenoxy)-

Propionic Acid U233*Thallium Sulfate P115Thiram U244*Toxaphene P123Warfarin U248

Solvents

Spent solvents, solvent still bottoms, or mixturescontaining solvents are often hazardous. Thisincludes solvents used in degreasing and paintbrush cleaning, and distillation residues fromreclamation. The following are some commonlyused hazardous solvents (see also ignitablewastes for other hazardous solvents, and 40 CFR261.31 for most listed hazardous waste sol-vents):

Benzene D018Carbon Disulfide F005Carbon Tetrachloride F001Chlorobenzene F002Cresols F004Cresylic Acid F0040-Dichlorobenzene F002Ethanol D001

Ethylene Dichloride D001Isobutanol F005Isopropanol D001Kerosene D001Methyl Ethyl Ketone F005Methylene Chloride

(Sludges) F001(Still bottoms) F002

Naphtha D001Nitrobenzene F004Petroleum Solvents (Flash-

point less than 140°F) D001Pyridine F0051,1,1-Trichloroethane

(Sludges) F001(Still Bottoms) F002

Tetrachloroethylene(Sludges) F001(Still Bottoms) F002

Toluene F005Trichloroethylene

(Sludges) F001(Still Bottoms) F002

Trichlorofluoromethane F002Trichlorotrifluoroethane F002White Spirits D001

Reactives

Reactive wastes include reactive materials ormixtures which are unstable, react violently withor form explosive mixtures with water, generatetoxic gases or vapors when mixed with water (orwhen exposed to pH conditions between 2 and

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12.5 in the case of cyanide or sulfide bearingwastes), or are capable of detonation or explo-sive reaction when irritated or heated (for acomplete description of reactive wastes, see 40CFR 261.23, Characteristics of reactivity). Un-less otherwise specified, all reactive wastes havean EPA Hazardous Waste Number of D003. Thefollowing materials are commonly considered tobe reactive:

Acetyl Chloride D003Chromic Acid D003Cyanides D003Organic Peroxides D003Perchlorates D003Permanganates D003Hypochlorites D003Sulfides D003Crystalline picric acid D003

Spent Plating and Cyanide Wastes

Spent plating wastes contain cleaning solutionsand plating solutions with caustics, solvents,heavy metals, and cyanides. Cyanide wastes mayalso be generated from heat treatment opera-tions, pigment production, and manufacturingof anti-caking agents. Cyanide wastes areacutely hazardous wastes. Plating wastes aregenerally Hazardous Waste Numbers F006–F009.Heat treatment wastes are generally HazardousWaste Numbers F010–F012. See 40 CFR 261.31for a more complete description of platingwastes.

Wood Preserving Agents

Compounds or mixtures used in wood preserv-ing, including the wastewater treatment sludgefrom wastewater treatment operations, areconsidered hazardous. Bottom sediment sludgesfrom the treatment of wastewater processes thatuse creosate or pentachlorphenol are hazardous,and have an EPA Hazardous Waste Number ofK001. Unless otherwise indicated, specific woodpreserving components are:

Chromated Copper Arsenate D004Creosate K001Pentachlorophenol K001Wastewaters from wood preserving processes F032

F034F035

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