Masonry Magazine June 1986 Page. 33
EPA HAZARDOUS WASTE REQUIREMENTS
For Small Quantities of 100 to 1000 kg/mo
In 1976, Congress enacted the Resource Conservation and Recovery Act (RCRA) to protect human health and the environment from improper waste management practices. In issuing hazardous waste regulations under RCRA, the Environmental Protection Agency (EPA) first focused on large generators that produce the greatest portion of hazardous waste. Regulations EPA published on May 19, 1980, exempted "small quantity generators"-establishments producing less than 1000 kilograms of hazardous waste in a calendar month-from most of the hazardous waste requirements.
On November 8, 1984, however, the Hazardous and Solid Waste Amendments (HSWA) were signed into law. These amendments to RCRA directed EPA to establish new requirements for small quantity generators that produce between 100 and 1000 kilograms of hazardous waste in a calendar month. EPA issued final regulations for these 100 to 1000 kg/mo generators on March 24, 1986, making the effective date of the requirements September 22. 1986.
In general, the new regulations for 100 to 1000 kg/mo generators are based upon the existing hazardous waste regulatory program. To lessen the burden on the small businesses which are most likely to be affected by these new regulations, EPA has exempted 100 to 1000 kg/mo generators from some of the administrative and paperwork requirements applicable to larger generators (1000 or more kg/mo). Here are answers to some basic questions about the new requirements:
Q Who is affected by these new regulations?
Establishments that generate from 100 to 1000 kilograms (approximately 220 to 2200 pounds) of hazardous waste in any calendar month. (Depending upon the weight of the contents, this amount is approximately one half-full to five full 55-gallon drums.)
Q What kinds of businesses are likely to be 100 to 1000 kg/mo generators?
Vehicle maintenance establishments (such as garages, paint and body shops, and car dealerships), metal manufacturers, printers, laundries and dry cleaners, chemical manufacturers and formulators, laboratories, equipment repair shops, construction firms, textile manufacturers, pesticide applicators, and schools are among establishments likely to produce small quantities of hazardous waste. Based on a March, 1985 survey of small quantity generators, EPA estimates that there are approximately 100,000 businesses which would be affected by the new regulations.
Q What new requirements must 100 to 1000 kg/mo generators meet?
By September 22, 1986, 100 to 1000 kg/mo generators must:
* Obtain a U.S. EPA Identification Number.
* Use the full Uniform Hazardous Waste Manifest system when shipping hazardous waste off-site.
* Offer wastes only to hazardous waste transporters who have U.S. EPA Identification Numbers.
* Accumulate waste on-site for no more than 180 days, or 270 days if the waste is to be shipped more than 200 miles, unless they obtain a hazardous waste permit.
* Ensure that their hazardous waste is managed at a hazardous waste facility with interim status or a permit under RCRA.
Q Are these the only new requirements that 100 to 1000 kg/mo generators must meet?
Not necessarily. While the items listed above briefly identify the basic new federal requirements for 100 to 1000 kg/mo generators, the actual requirements which go into effect on September 22, 1986 are more detailed. In addition, some states may impose more stringent requirements on small quantity generators. For example, four states (California, Louisiana, Minnesota, and Rhode Island) now fully regulate all generators of hazardous waste, 100 to 1000 kg/mo generators as well as larger and smaller generators. To be sure you understand all the requirements, state and federal, that you must meet, contact your state hazardous waste management agency.
Q What is a U.S. EPA Identification Number, and how do I obtain one?
A U.S. EPA Identification Number is a unique, 12-character number that EPA assigns to generators and transporters of hazardous waste, and to owners/operators of facilities that treat, store, or dispose of hazardous waste. The identification numbers help EPA and states compile and maintain a database on hazardous waste activities.
To obtain an EPA Identification Number, you should complete EPA Form 8700-12, "Notification of Hazardous Waste Activity," or a similar form used by your particular state. To request the application form, contact your state hazardous waste management agency or EPA Regional Office. Along with the appropriate application form, you will receive instructions for completing the form and information on where you can get additional assistance.