FDEP � EPA

Industry Meeting









    Insert Product

   Photograph Here

         RCRA 101

       Back to Basics

          Michael X. Redig, EM

RCRA Compliance and Enforcement Section

            850-245-8774

WHAT IS A HAZARDOUS WASTE?

HAZARDOUS WASTE

DETERMINATION

 −Process or product knowledge

 −Material Safety Data Sheets

  (MSDS)

 −Laboratory analysis

  MaterialSafetyDataSheet

                               name, company, Hazard Code

General Information



                               highest to lowest percent

Ingredients



Physical/Chemical Characteristics appearance, BP, MP, VP, SG



                               FP, LEL, UEL, fire fighting

Fire / Explosive Hazard Data



                               Stability, conditions

Reactivity Data



                               Entry route, Acute & Chronic

Health Hazard Data



                               spill, neutralizing, disposal

Safe Handling Precautions



                               protection, ventilation,

Control Measures



                               DOT info

Transportation Data

         Disposal Data



                               name, hazard codes, precautions

         Label Data

Hazardous Waste Determination

� Testing

  � Certified lab (NELAC listing URL)

     � http://www.dep.state.fl.us/labs/cgi-

       bin/aams/index.asp

  � Chain of Custody for samples

  � Retain files for three years (BMP)

Waste Analysis Plan

� Required for Generators if you plan

  to treat your waste on site

� Guidance Manual on WAP’s

  � OSWER 9938.4-03 April 1994



� Six Key Components to the Plan

  � Description of processes, wastes, activities

    and waste management units covered by the

    plan

  � ID the constituents and parameters to be

    sampled and why they were selected for

    before and after treatment takes place.

Waste Analysis Plan

� Key Elements (continued)

  � Describe methods used to collect a

    representative sample

  � Analytical methods used to evaluate

    the waste streams

  � Testing frequency both before and

    after treatment

  � Special procedures � how will the

    generator treat the waste for

    applicable LDR requirements

WAP Example

                  Special Rules

1. Mixture Rule (caveat � the solution

to pollution is not dilution)

  Any amount of         Any amount of

                                        =

                   +                        LISTED HW

  LISTED HW               NON-HW









                                              Must meet

 Any amount of

                        Any amount of

                                        =

                    +                       characteristics

CHARACTERISTIC

                          NON-HW

     HW                                       to be HW

     DOES RCRA APPLY TO YOUR

     OPERATIONS?







� Do you generate hazardous waste?





� How much?

            HOW MUCH?



Generator Status

 � Conditionally Exempt Small Quantity (CESQG)





 � Small Quantity (SQG)





 � Large Quantity (LQG)

REGULATORY BURDEN FOR

HAZARDOUS WASTE GENERATORS

CONDITIONALLY EXEMPT SMALL

QUANTITY GENERATOR

� Generates < 100 kg (220 lbs) of HW per

  month.

� Generates < 1kg (2.2 lbs) of acutely HW per

  month.

� Never accumulates > 1000 kg (2,200 lbs)







             100 kg = approximately 1/2 55-gal drum

 SMALL QUANTITY GENERATOR

� Generates between 100 kg (220 lbs), and 1000

  kg (220 lbs) of HW per month.

� Generates < 1kg (2.2 lbs) of acutely HW per

  month.

� Never accumulates > 6000 kg (13,200 lbs)

  and max of 180 days storage time.









                 to

        (1/2)

LARGE QUANTITY GENERATOR

� Generates > 1000 kg (2200 lbs) of HW per

  month.

� Generates > 1 kg (2.2 lbs) of acutely HW per

  month.

� Never store waste > 90days









                                    or more

      To Determine Size Class

You Must Count HW That Is :

  −Transported Off-Site for

   Treatment, Storage, or Disposal

  −Treated or Disposed of On-Site

  −Accumulated Prior to Recycling,

   Transporting, and Storage,

   Treatment or Disposal

      To Determine Size Class, Cont...

� You Don’t Have to Count:

  � Scrap metal that will be sent off-site

    for recycling

  � Used oil that has not been mixed

    with hazardous waste and is recycled

    on-site or off-site

  � Universal Waste � batteries < 2 lbs

    (RBRC weight limit), recalled

    pesticides, Hg Fluorescent bulbs, Hg

    devices, Universal Pharmaceutical

    Waste

  � Recycled lead acid batteries > 2lbs