Hazardous Waste Facilities: Understanding The Criteria

what constitutes a facility which generates hazardous waste

Hazardous waste is a waste that is dangerous and has harmful effects on human health and the environment. Hazardous waste can be generated from various sources, including industrial manufacturing processes, batteries, and other solid wastes. To determine if a facility generates hazardous waste, it must carefully review the relevant regulations and guidelines, such as the Resource Conservation and Recovery Act (RCRA) in the United States or state-specific regulations like the Virginia Hazardous Waste Management Regulations (VHWMR). Facilities that generate hazardous waste must comply with specific requirements, including proper waste determination, disposal, and storage methods. These regulations aim to balance resource conservation and the protection of human health and the environment.

Characteristics Values
Definition 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.
Forms Liquids, solids, gases, and sludges.
Sources Industrial manufacturing process wastes, batteries, discarded commercial products, etc.
Regulatory Definition EPA has developed a definition and process that identifies specific substances known to be hazardous and provides objective criteria for including other materials in the regulated hazardous waste universe.
Hazardous Waste Identification Generators of wastes should determine if their waste is a solid waste, then investigate if it is a listed or characteristic hazardous waste.
Listed Hazardous Waste Wastes from common manufacturing and industrial processes, specific industries, and discarded commercial products.
Characteristic Hazardous Waste Wastes that exhibit any one or more of the following properties: ignitability, corrosivity, reactivity, or toxicity.
Mixed Waste A waste with both hazardous and radioactive components, regulated under the RCRA and the Atomic Energy Act.
Treatment Processes such as incineration, oxidation, or controlled flame combustion to alter the character or composition of hazardous wastes.
Storage Temporary holding of hazardous wastes in containers, tanks, containment buildings, drip pads, waste piles, or surface impoundments that comply with regulations.
Disposal Permanent containment of hazardous wastes, commonly in landfills designed to protect groundwater and surface water resources.
Regulatory Requirements Requirements vary based on the facility generator category (small or large quantity generators) and state regulations. Facilities must notify the relevant authorities and obtain an EPA Identification number.
Transportation Hazardous waste must be transported by licensed transporters who comply with United States Department of Transportation and EPA regulations.

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Hazardous waste identification

To determine if a facility generates hazardous waste, the following steps can be taken:

  • Review the relevant state and federal laws and regulations: In the United States, the Resource Conservation and Recovery Act (RCRA) and the Atomic Energy Act play a key role in regulating hazardous waste. The Environmental Protection Agency (EPA) has developed a regulatory definition and process for identifying hazardous waste, and state-specific regulations, such as the Virginia Hazardous Waste Management Regulations (VHWMR), may also apply.
  • Assess the type of waste generated: A waste is considered hazardous if it is specifically listed as a known hazardous waste or meets the characteristics of hazardous waste. The EPA has identified four lists (F, K, P, and U) in Title 40 of the Code of Federal Regulations (CFR) that categorise hazardous wastes. The F-list includes wastes from common manufacturing and industrial processes, while the K-list identifies wastes from specific sectors of industry. Characteristic wastes exhibit properties such as ignitability, corrosivity, reactivity, or toxicity. Mixed waste, which contains both hazardous and radioactive components, is regulated by both the RCRA and the Atomic Energy Act.
  • Determine the quantity of hazardous waste generated: Facilities must establish their generator status by determining the amount of hazardous waste produced in a given month. There are typically three categories of generators: large quantity generators, small quantity generators, and very small quantity generators, each with their own requirements and time limits for accumulation (storage).
  • Properly dispose of hazardous waste: Hazardous waste must be disposed of in accordance with regulations. Treatment, Storage, and Disposal Facilities (TSDFs) provide temporary storage and final treatment or disposal, and are stringently regulated to protect human health and the environment. Common disposal methods include landfills, incineration, and oxidation, with specific design and operating requirements outlined in RCRA Subtitle C.
  • Record-keeping and reporting: Facilities must maintain records of waste determinations, generation quantities, transport of waste, and final disposal. Annual reports may be required, and specific forms, such as the uniform hazardous waste manifest, are needed for shipping hazardous waste.

It is important to note that hazardous waste identification may vary depending on the specific state and industry, and it is recommended to refer to the relevant regulatory bodies for detailed guidelines.

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Treatment, storage, and disposal facilities

Hazardous waste treatment, storage, and disposal facilities (TSDFs) are facilities that treat, store, and/or dispose of hazardous waste. These facilities are subject to stringent regulations and require permits to operate.

Treatment

Treatment processes aim to alter the character or composition of hazardous wastes, making them less harmful or reducing their volume. Common treatment methods include incineration, oxidation, blending, and neutralization. Incineration uses controlled flame combustion to destroy toxic organic constituents and reduce waste volume, potentially enabling energy or material recovery. Industrial furnaces, such as cement kilns, are another example of enclosed units that use thermal treatment to recover materials or energy from hazardous waste. Boilers are similar devices that recover and export energy in the form of steam, heated fluids, or gases. Some treatment processes enable waste recovery and reuse in manufacturing. Land treatment units utilize natural soil microbes and sunlight to treat hazardous waste by applying it directly to the soil surface or incorporating it into the upper layers.

Storage

Storage facilities temporarily hold hazardous waste before treatment or disposal. Common storage methods include containers, tanks, containment buildings, drip pads, waste piles, or surface impoundments. Containers are mobile units that can be used for storage, transportation, and disposal, while tanks are stationary devices constructed of non-earthen materials like steel, plastic, or concrete. They accommodate large volumes of waste and are structurally strong. Containment buildings are completely enclosed structures with four walls, a roof, and a floor, used for storing non-containerized hazardous waste. Drip pads are unique to the wood preservation industry, collecting dripping preservatives from treated wood. Waste piles are non-containerized piles of solid, non-liquid hazardous waste used for temporary storage or treatment.

Disposal

Disposal facilities permanently contain hazardous wastes, with landfills being the most common type. Landfills are carefully constructed units designed to protect groundwater and surface water resources. They are excavated or engineered sites where non-liquid hazardous waste is deposited and covered to prevent the release of hazardous waste into the environment. Disposal facilities must comply with design and operating requirements established by regulatory bodies to safeguard human health and the environment from the risks posed by hazardous waste.

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Regulatory requirements

The regulatory requirements for hazardous waste management are stringent and comprehensive, aiming to protect human health and the environment. These regulations are based on the facility's generator category, with specific provisions for small and large quantity generators. Here are the key regulatory requirements:

Waste Determination and Classification

Facilities must determine if their waste is hazardous by reviewing relevant codes and regulations. Waste can be classified as hazardous if it is specifically listed as a known hazardous waste or meets certain characteristics, including ignitability, corrosivity, reactivity, or toxicity.

Record-Keeping and Reporting

Generators must establish their generator status and determine the quantity of hazardous waste generated monthly. Proper record-keeping is essential, and facilities must maintain records of waste determinations, generation quantities, transportation, and final disposal. Small and large quantity generators are often required to file annual reports with the relevant authorities.

Storage and Treatment

Hazardous waste must be stored in containers, tanks, or containment buildings that comply with regulations, such as the Resource Conservation and Recovery Act (RCRA). Treatment processes, such as incineration or oxidation, are used to alter the composition of hazardous waste, reduce its volume, or enable recycling and reuse.

Transportation

When transporting hazardous waste, licensed hazardous waste transporters must be used, and specific regulations, such as the United States Department of Transportation's hazardous materials regulations, must be followed. Transporters must have valid EPA identification and the required transportation licenses.

Disposal

Disposal facilities, such as landfills, are designed to permanently contain hazardous wastes and protect groundwater and surface water resources. Specific design and operating requirements are established to manage hazardous waste safely and in compliance with regulations.

State and Federal Regulations

State regulatory requirements may differ and can be more stringent than federal programs. Facilities must comply with state-specific hazardous waste management regulations, such as the Virginia Hazardous Waste Management Regulations (VHWMR) or Wisconsin's hazardous waste regulations, in addition to federal regulations.

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Hazardous waste generators

To comply with regulations, generators must first determine if their waste meets the definition of solid waste and then establish whether it is listed or characteristic hazardous waste. Listed wastes are those specifically mentioned as known hazardous wastes, while characteristic wastes exhibit properties such as ignitability, corrosivity, reactivity, or toxicity.

Generators of hazardous waste must adhere to specific regulatory requirements, which can vary depending on the generator category and state laws. There are generally three categories of hazardous waste generators: small quantity generators, large quantity generators, and very small quantity generators. Small and large quantity generators are required to notify relevant authorities, such as the Department of Natural Resources (DNR), and obtain an EPA Identification Number. They also need to maintain records of waste determinations, generation quantities, transportation, and final disposal for annual reporting.

The storage and disposal of hazardous waste are crucial aspects of waste management. Generators may store their waste temporarily, following specific guidelines and using appropriate containers, tanks, or containment buildings that comply with regulations like the Resource Conservation and Recovery Act (RCRA). For disposal, hazardous waste is typically transported to specialised facilities that can recycle, treat, or permanently dispose of the waste. Treatment processes can include incineration, oxidation, or industrial furnaces, aiming to reduce the volume of waste or enable its reuse.

To ensure the safe management of hazardous waste, regulations have been established, such as the RCRA and the EPA's hazardous waste regulations. These regulations aim to balance resource conservation with the protection of human health and the environment. Additionally, state-specific regulations, such as the Virginia Hazardous Waste Management Regulations (VHWMR), may also apply.

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Hazardous waste transportation

Hazardous waste is a waste that poses a danger to human health or the environment. It can come in many forms, including liquids, solids, gases, and sludges, and is generated from a variety of sources, including industrial manufacturing processes and batteries. To encourage recycling and protect health and the environment, the EPA has developed regulations for the safe management and transportation of hazardous waste.

Once a generator determines that their waste is hazardous, it must be transported to a facility for recycling, treatment, storage, or disposal. The transportation of hazardous waste is strictly regulated to ensure the safety of the public and the environment. In the United States, the Department of Transportation's hazardous materials regulations and the EPA's hazardous waste regulations apply to the transport of hazardous waste on public roads, highways, rails, and waterways.

Transporters of hazardous waste must comply with specific requirements, including obtaining a valid EPA ID number and a hazardous waste transportation service license. The specific regulations vary depending on the state and the quantity of hazardous waste being transported. For example, in Wisconsin, large quantity generators and small quantity generators have different requirements and time limits for the accumulation (storage) of hazardous waste. Additionally, a very small quantity generator may self-transport hazardous waste without a transportation license or manifest.

The safe transportation of hazardous waste is crucial to prevent spills, leaks, fires, and contamination of soil and drinking water. Treatment, Storage, and Disposal Facilities (TSDFs) play a vital role in the management of hazardous waste. These facilities provide temporary storage and final treatment or disposal, ensuring that hazardous waste is handled and disposed of properly to minimize risks to human health and the environment.

Frequently asked questions

Hazardous waste is any waste that has properties that can be harmful to human health or the environment. It can come in many forms, including liquids, solids, gases, and sludges.

To determine if your facility generates hazardous waste, you must carefully review the relevant state and federal laws and regulations. In the US, the Resource Conservation and Recovery Act (RCRA) and the Atomic Energy Act are the key pieces of legislation regulating hazardous waste. You should also refer to your state's specific requirements, as they may be more stringent than federal regulations.

Hazardous waste can be generated from various sources, including industrial manufacturing processes, specific industries, discarded commercial products, and household sources. Examples include batteries, lamps, pesticides, mercury-containing equipment, and pharmaceutical waste.

There are typically three categories of hazardous waste generators: Small Quantity Generators (SQGs), Large Quantity Generators (LQGs), and Very Small Quantity Generators (VSQGs). The specific definitions and thresholds for each category may vary depending on the state and federal regulations.

Facilities that generate hazardous waste must comply with stringent regulations for the handling, storage, treatment, and disposal of such waste. This includes obtaining permits, using licensed transporters, maintaining records, and adhering to specific design and operating requirements for hazardous waste management units to protect human health and the environment.

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