Upload
phungthien
View
215
Download
0
Embed Size (px)
Citation preview
ADEQ / MANAGING HAZARDOUS WASTE 1
A HANDBOOK
FOR SMALL BUSINESSES
MANAGING
HAZARDOUS WASTE
ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY
2 MANAGING HAZARDOUS WASTE / ADEQ
CONTENTS
INTRODUCTION .......................................................................................................... 1
DECIDING WHETHER HAZARDOUS WASTE REGULATIONS APPLY TO YOU ............................... 2Defining Hazardous Waste ................................................................... 2Identifying Your Waste: Typical Hazardous Wastes Generated by Businesses .... 3Finding Your Generator Category ........................................................... 4How Many Drums Is That? ................................................................... 5What Do You Measure to Determine Your Generator Category? .................... 6
REQUIREMENTS FOR CONDITIONALLY EXEMPT SMALL QUANTITY GENERATORS .......................... 7
REQUIREMENTS FOR SMALL QUANTITY GENERATORS ........................................................... 8Obtaining an EPA Identification Number ................................................. 8Sample RCRA Subtitle C Site Identification Form ....................................... 9
MANAGING HAZARDOUS WASTE ON-SITE .................................................................... 11Accumulating Your Waste ................................................................... 11Treating Your Waste to Meet the Land Disposal Restrictions (LDRs) ............... 12Hazardous Waste Code Chart .............................................................. 13Responding to Emergencies ................................................................. 17Preventing Accidents ......................................................................... 17Waste Minimization: The Key to Better Waste Management ........................ 18
SHIPPING HAZARDOUS WASTE OFF-SITE ....................................................................... 20Selecting a TSDF............................................................................... 20Labeling Waste Shipments ................................................................... 20Selecting a Transporter or TSDF/Recycler ................................................ 21Preparing Hazardous Waste Manifests .................................................... 21Land Disposal Restrictions (LDR) Reporting Requirements .......................... 21Export Notification ............................................................................ 22
SUMMARY OF REQUIREMENTS FOR LARGE QUANTITY GENERATORS ...................................... 23
FINAL TIPS ............................................................................................................ 24Are You Sure? .................................................................................. 24Can You Use the Universal Waste Rule? ................................................. 24
WHERE TO GET MORE HELP ...................................................................................... 25Appendix A: State Hazardous Waste Management Assistance...................... 25Appendix B: EPA and Other Federal Resource Centers ............................... 25Appendix C: Forms/Invoices from the Hazardous Waste Section .................. 26
ADEQ / MANAGING HAZARDOUS WASTE 1
INTRODUCTION
TIP
Whenever you consult a federal hazard-
ous waste regulation to determine the
regulations that apply to the waste you
are managing, you must also consult the
Arizona hazardous waste statutes and
rules to determine if any additional and/
or different standards also apply.
TIP
You can look up un-
familiar words or
phrases on a list of
definitions found at
the end of this hand-
book.
This handbook has been prepared by theHazardous Waste Section of the Arizona
Department of Environmental Quality (ADEQ)to help small business owners and operatorsunderstand how to best comply with federalhazardous waste management regulations, aswell as Arizona hazardous waste rules andstatutes. This handbook is intended as an over-view and summary of the regulations and statutesto give you a basic understanding of your respon-sibilities in managing your hazardous wasteactivities. It is not to be used as a substitute forthe actual regulations.
Much of the material in this handbook is re-printed from the Environmental ProtectionAgency’s (EPA) handbook entitled, Understand-ing the Hazardous Waste Rules—A Handbook forSmall Business. EPA’s handbook is augmented bymaterial pertaining to hazardous waste manage-ment requirements peculiar to Arizona rules andstatutes. Arizona incorporates most of the federalhazardous waste regulations by reference;therefore, Arizona’s hazardous waste rules aresimilar and consistent with the federal hazardouswaste regulations.
All of the federal hazardous waste regulations arelocated in Title 40 of the Code of Federal Regu-lations (CFR), Parts 260 to 299 which areincorporated by Arizona Administrative Codes(AAC) R18-8-260 to 280. State regulations arelocated in Arizona Revised Statutes 49-901through 49-944.
Federal and state rules definethree categories of hazardous
waste generators based upon thequantity of hazardous waste theygenerate in any calendar month:
1. Conditionally exempt smallquantity generators (CESQGs)that generate less than 220 lb(100 kg) in any calendarmonth.
2. Small quantity generators(SQGs) that generate between 220 lb (100 kg)and 2,200 lb (1,000 kg) in any calendar month.
3. Large quantity generators (LQGs) that generatemore than 2,200 lb (1,000 kg) or more than2.2 lb (1 kg) of acutely hazardous waste in anycalendar month or 220 lb (100 kg) acute spillresidue.
Each category of generator must comply with thehazardous waste rules specific to that category.This handbook is intended primarily for busi-nesses that generate small quantities of hazardouswaste (SQGs and CESQGs) to help them learnabout regulations that apply.
FOR MORE INFORMATION
If you have questions about any part of this
document or the federal hazardous waste
regulations pertaining to Arizona, call the
Hazardous Waste Inspections & Compliance
Unit at (602) 771-4108 or (800) 234-5677.
Proper management of hazardous waste is important to
safeguard human health and the environment.
2 MANAGING HAZARDOUS WASTE / ADEQ
DECIDING WHETHER HAZARDOUS
WASTE REGULATIONS APPLY TO YOU
✔ First, determine if you
generate hazardous waste.
✔ Measure the amount of haz-
ardous waste that you
produce per month.
✔ Determine your generator
category to learn the man-
agement requirements that
apply to you.
DEFINING HAZARDOUS WASTE
A waste is any solid, liquid, or contained gaseousmaterial that is discarded by being disposed of,
burned or incinerated,or recycled. (Thereare some exceptionsfor recycled materi-als.) It can be the by-product of a manu-facturing process orsimply a commercialproduct that you usein your business—such as a cleaningfluid or batteryacid—that is beingdisposed. Even
materials that are recyclable or can be reused insome way—such as burning used oil for fuel—may be considered waste. Hazardous waste canbe one of two types:
■ Listed wasteYour waste is considered hazardous if itappears on one of four lists published in 40CFR Part 261 (as incorporated by AAC R18-8-261) and is not otherwise excluded. Currently,more than 400 wastes are listed. Wastes arelisted as hazardous because they are known tobe harmful to human health and the environ-ment when not managed properly.
Acutely hazardouswastes are listedwastes that evenwhen managedproperly areextremely danger-ous. Examples ofacutely hazardouswastes includewastes generatedfrom some pesti-cides that can be
Federal and state hazardous waste management regulations apply to most businesses thatgenerate hazardous waste. To determine if these regulations apply to your business, you mustfirst determine if you even generate hazardous waste.
fatal to humans even in low doses. P listed andF020, F021, F022, F023, F026, and F027 areexamples of acutely hazardous wastes.
■ Characteristic wasteIf your waste does not appear on one of thehazardous waste lists, it still might be consid-ered hazardous if it demonstrates one or moreof the following characteristics:
▲It catches fire under certain conditions. This isknown as an ignitable waste. Examples arepaints and certain degreasers and solvents.
▲It corrodes metals or has a very high or verylow pH. This is known as a corrosive waste.Examples are rust removers, acid or alkalinecleaning fluids, and battery acid.
▲It is unstable and explodes or produces toxicfumes, gases, and vapors when mixed withwater or under other conditions, such as heat orpressure. This is known as a reactive waste.Examples are certain cyanides or sulfide-bearing wastes.
▲It is harmful or fatal when ingested or ab-sorbed, or it leaches toxic chemicals into thesoil or ground water when disposed of on land.This is known as a toxic waste. Examples arewastes that contain high concentrations ofheavy metals, such as cadmium, lead, ormercury.
Additionally, a mixture of hazardous waste withsolid waste (e.g., motor oil, trash, debris) maybecome a hazardous waste.
You can determine if your waste is toxic byhaving it tested using the Toxicity Charac-
teristic Leaching Procedure (TCLP), or bysimply knowing that your waste is hazardous orthat your processes generate hazardous waste(called generator knowledge). However, youmust have written documentation if usinggenerator knowledge for both hazardous andnon-hazardous waste.
TIP
One way to help determine if
your waste exhibits a
characteristic is to check the
Material Safety Data Sheet
(MSDS) that comes with all
products containing hazardous
materials. In addition, your
national trade association or its
local chapter might be able to
help you.
ADEQ / MANAGING HAZARDOUS WASTE 3
IDENTIFYING YOUR WASTE
To help you identify some of the waste streamscommon to your business, consult the tablebelow to find a list of typical hazardous wastesgenerated by small businesses. Use the EPAHazardous Waste Codes for Waste StreamsCommonly Generated by Small Quantity Genera-tors list located in the center of this handbook fora more detailed listing of the EPA waste codesassociated with these waste streams to determine
if your waste is hazardous. Commercial chemicalproducts that are discarded might also becomehazardous waste. For a complete listing ofhazardous waste codes, consult 40 CFR Part 261(as incorporated by R-18-8-261).
If your waste is hazardous, you will need tomanage it according to appropriate federal andstate hazardous waste regulations.
D001, D039,
F002
D001, F001-
F005
D001, D002,
F001-F005
D001, D002,
D003, F001-
F005, U211
D001, D002,
D006, D008,
F001-F005
D002, D006,
D008, F001-
F005
D001, D002,
D006, D008,
F001-F005
D001, F001-
F005, U129,
U136, P094,
P123
D001, D002,
F001-F005
Still residues from solvent
distillation, spent filter car-
tridges, cooked powder residue
Ignitable wastes, toxic wastes,
solvent wastes, paint wastes
Ignitable wastes, toxic wastes,
solvent wastes, paint wastes,
used oil, acids/bases
Spent solvents, unused re-
agents, reaction products,
testing samples, contaminated
materials
Acids/bases, solvents, ignitable
wastes, toxic wastes, paint
wastes, batteries
Acids/bases, heavy metal
wastes, solvents, toxic wastes,
ink
Acids/bases, toxic wastes,
ignitable wastes, paint wastes,
solvents
Used/unused pesticides, solvent
wastes, ignitable wastes,
contaminated soil (from spills),
contaminated rinsewater,
empty containers
Ignitable wastes, solvent
wastes, acids/bases, paint
wastes
Commercial dry cleaning processes
Wood cleaning and wax removal, refinishing/
stripping, staining, painting, finishing, brush
cleaning, and spray brush cleaning
Paint preparation and painting, carpentry
and floor work, other specialty contracting
activities, heavy construction, wrecking and
demolition, vehicle and equipment main-
tenance for construction activities
Diagnostic and other laboratory testing
Degreasing, rust removal, paint preparation,
spray booth, spray guns, brush cleaning,
paint removal, tank cleanout, installing lead-
acid batteries
Plate preparation, stencil preparation for
screen printing, photo processing, printing,
cleanup
Degreasing, equipment cleaning, rust re-
moval, paint preparation, painting, paint
removal, spray booth, spray guns, and brush
cleaning
Pesticide application and cleanup
Automobile engine and body repair, metal-
working, graphic arts—plate preparation,
woodworking
Dry Cleaning and
Laundry Plants
Furniture/Wood
Manufacturing
and Refinishing
Construction
Laboratories
Vehicle
Maintenance
Printing and
Allied Industries
Equipment Repair
Pesticide End-
Users/Application
Services
Educational and
Vocational Shops
Type of Business How Generated Types of Wastes
TYPICAL HAZARDOUS WASTES GENERATED BY BUSINESSES
Waste Codes
4 MANAGING HAZARDOUS WASTE / ADEQ
Once you know that you generate hazardouswaste, you need to measure the amount of
waste you produce each calendar month. Theamount of hazardous waste you generate in acalendar month determines your generatorcategory.
Many hazardous wastes are liquids and aremeasured in gallons—not pounds. In order tomeasure your liquid wastes, you will need toconvert from gallons to pounds. To do this, youmust know the density of the liquid. A rough
FINDING YOUR
GENERATOR CATEGORYGENERATION FEES
For generation fees, SQGs are invoiced
annually. The fee is $10 per ton unless
the facility has a Certified Pollution Pre-
vention Plan; then it is $5 per ton.
guide is that 30 gallons (about half of a 55-gallondrum) of waste with a density similar to waterweighs about 220 lb (100 kg); 300 gallons of awaste with a density similar to water weighsabout 2,200 lb (1,000 kg).
EPA has established three generator categories,each of which is regulated differently:
CONDITIONALLY EXEMPT SMALL QUANTITY
GENERATORS (CESQGS)
You are considered a CESQG if you generate nomore than 220 lb (100 kg) of hazardous waste inany calendar month and do not accumulate over2,200 lb (1,000 kg). You are exempt from hazard-ous waste management regulations provided thatyou comply with the basic requirements de-scribed on page 7.
SMALL QUANTITY GENERATORS (SQGS)
You are considered an SQG if you generatebetween 220 and 2,200 lb (100 and 1,000 kg) ofhazardous waste in any calendar month and donot accumulate over 13,228 lb (6,000 kg). SQGsmust comply with federal and state requirementsfor managing hazardous waste described in thishandbook.
LARGE QUANTITY GENERATORS (LQGS)
You are considered an LQG if you generate morethan 2,200 lb (1,000 kg) of hazardous waste inany calendar month. LQGs must comply withmore extensive hazardous waste rules than thosesummarized in this handbook. See page 23 for anoverview.
Note: If any generator generates or accumulatesmore than 2.2 lb (1 kg) of acutely hazardouswaste in a calendar month or 220 lb (100 kg)acute spill residue, all of the acutely hazardouswaste must be managed according to the regula-tions applicable to LQGs.
WHAT IS YOUR GENERATOR CATEGORY?
For waste management purposes, depending on
your type of business, you might be regulated un-
der different rules at different times. If, for ex-
ample, you generate less than 220 lb (100 kg) of
hazardous waste during the month of June, you
would be considered a CESQG for June and your
June waste would be subject to the hazardous
waste management requirements for CESQGs. If,
in July, you generate between 220 and 2,200 lb
(100 to 1,000 kg) of hazardous waste, your gen-
erator status would change, and you would be
considered an SQG for July. Your July waste and
facility would then be subject to the management
requirements for SQGs.
For annual registration fee purposes, your fee is
based on the maximum amount generated in any
one month of the previous year. Use your monthly
generation amounts to determine your registra-
tion status, not your annual generation total. You
are an SQG if you have generated 220 lb (100 kg)
or more but less than 2,200 lb (1000 kg) of haz-
ardous waste in any calendar month of the previ-
ous year. If this is the case, you are required to
pay an annual registration fee of $100. If you have
generated less than 220 lb (100 kg) of hazardous
waste in any calendar month of the previous year,
you are a CESQG and do not have an annual reg-
istration fee. See Appendix C, Hazardous Waste
Facility Annual Report for CESQGs.
ADEQ / MANAGING HAZARDOUS WASTE 5
HOW MANY DRUMS IS THAT?
KEY:
= 55 gal drum
= 440 lb (water)
= 200 kg (water)
1/2 to 5 drums or
27 to 275 gal or
220 to 2,200 lb or
100 to 1,000 kg
<1/2 drum or
<27 gal or
<220 lb or
<100 kg
LARGE QUANTITY GENERATOR
(LQG)
>5 drums or
>275 gal or
>2,200 lb or
>1,000
SMALL QUANTITY GENERATOR (SQG)
CONDITIONALLY EXEMPT SMALL
QUANTITY GENERATOR (CESQG)
➔
SUBSTANCE
Note: This page is for guidance purposes
only. Not all chemicals have the same
density. This chart shows different
weights per gallon and per drum.
TIP
Water
Lead
Methylene
chloride
Acetone
LB PER DRUM
458.7
5,206.25
612.37
363.275
LB PER GAL
8.340
94.659
11.134
6.605
Per calendar month
Per calendar month
Per calendar month
➔ or more
6 MANAGING HAZARDOUS WASTE / ADEQ
WHAT DO YOU MEASURE
TO DETERMINE YOUR GENERATOR CATEGORY?
DO MEASURE:
For your monthly total, all quantities of listedand characteristic hazardous wastes that are:
✔ Accumulated on the property for any period oftime before disposal or recycling. (Dry clean-ers, for example, must count any residueremoved from machines, as well as spentcartridge filters.)
✔ Packaged and transported away from yourbusiness.
✔ Placed directly in a regulated treatment ordisposal unit at your place of business.
✔ Generated as still bottoms or sludges andremoved from product storage tanks.
DO NOT MEASURE:
Wastes that:
✔ Might be left in the bottom of containers thathave been thoroughly emptied through conven-tional means such as pouring or pumping.
✔ Are left as residue in the bottom of tanksstoring products, if the residue is not removedfrom the product tank.
✔ Are reclaimed continuously on-site withoutstoring prior to reclamation, such as drycleaning solvents.
✔ Are managed in an elementary neutralizationunit, a totally enclosed treatment unit, or awastewater treatment facility without beingstored first. (See definitions at the end of thishandbook for an explanation of thesetypes of units.)
✔ Are discharged directly to publicly ownedtreatment works (POTWs) without beingstored or accumulated first. This discharge to aPOTW must comply with the Clean Water Act.POTWs are public utilities, usually owned bythe city, county, or state that treat industrial anddomestic sewage for disposal.
✔ Have already been counted once during thecalendar month, and are treated on-site orreclaimed in some manner, and used again.
✔ Are regulated under the universal waste rule orhave other special requirements. The federalregulations contain special, limited require-ments for managing certain commonly gener-ated wastes. These wastes can be managedfollowing the less burdensome requirementslisted below instead of the usual hazardouswaste requirements.
Used oil—40 CFR Part 279 (as incorporatedby ARS 49-801-818).
Lead-acid batteries that are reclaimed—40CFR Part 266, Subpart G (as incorporated byR-18-8-266).
Scrap metal that is recycled—40 CFR 261.6(a)(3) (as incorporated by R-18-8-261).
Universal wastes (e.g., certain batteries,recalled and cancelled pesticides, mercury-containing thermostats, and mercury-containing waste lamps)—40 CFR Part 273(as incorporated by R-18-8-273).
Don't mix incompatible wastes.
ADEQ / MANAGING HAZARDOUS WASTE 7
If you generate no more than 220 lb (100 kg) of hazardous waste in any month, you are aconditionally exempt small quantity generator (CESQG). You must comply with three basic wastemanagement requirements to remain exempt from the full hazardous waste regulations that applyto generators of larger quantities (SQGs and LQGs). Note: There are different quantity limits foracutely hazardous waste.
First, you must identify all hazardouswaste that you generate and keep documenta-
tion of your waste determination. Second, youmay not store more than 2,200 lb (1,000 kg) ofhazardous waste on-site at any time. Finally, youmust ensure delivery of your hazardous waste toan off site treatment or disposal facility that isone of the following:
■ An Arizona- or federally-regulated hazardouswaste management treatment, storage, or disposalfacility (TSDF).
■ A facility permitted, licensed, or registered byArizona to manage municipal or industrialsolid waste.
■ A facility that uses, reuses, or legitimatelyrecycles the waste (or treats the waste prior touse, reuse, or recycling).
■ A universal waste handler or destinationfacility subject to the universal waste require-ments of 40 CFR Part 273 (as incorporated byR18-8-273) if your waste is universal waste.Universal wastes are wastes such as certainbatteries, recalled and banned pesticides, ormercury-containing thermostats. Note: InArizona, mercury-containing waste lamps areconsidered universal waste and should bemanaged in accordance with R18-8-273.
■ Or, if you treat or dispose of your hazardouswaste on-site, your facility also must also meetthe above definitions.
✔ Identify your hazardous waste.
✔ Comply with storage quantity limits.
✔ Ensure proper treatment and disposal
of your waste.
REQUIREMENTS FOR CONDITIONALLY
EXEMPT SMALL QUANTITY GENERATORS
Good housekeeping procedures can save money.TIP
CESQGs with EPA identifica-
tion numbers must complete
a Facility Annual Report
yearly. See Appendix C.
CESQGs
8 MANAGING HAZARDOUS WASTE / ADEQ
ADEQ records the information on the form andassigns an EPA ID number to the site identifiedon your form. The EPA ID number stays with theproperty when ownership changes. If you moveyour business, you must notify ADEQ of yournew location and submit a new form. If anotherbusiness previously handled hazardous waste atthis location and obtained an EPA ID number,you will be assigned the same number after youhave notified ADEQ that you have moved to thislocation. Otherwise, ADEQ will assign you anew identification number. You must alsodeactivate the old EPA ID number. To deactivatean EPA ID number, submit on company letter-head the facility name, ID number, reason fordeactivation, and the date of deactivation, andmail to ADEQ at the above address.
A revised 8700-12 must be submitted to ADEQ ifownership changes, generator status changes, orthe type of waste generated changes.
✔ Call ADEQ to determine if you need
an EPA ID number.
✔ If you do, obtain a copy of EPA
Form 8700-12.
✔ Fill in the form completely.
✔ Send the form to the ADEQ
Notification Coordinator.
REQUIREMENTS FOR SMALL QUANTITY GENERATORS
OBTAINING AN EPA IDENTIFICATION NUMBER
If your business generates between 220 lb(100 kg) and 2,200 lb (1,000 kg) of hazardous
waste in any calendar month, you are a smallquantity generator (SQG), and must obtain anduse an EPA Identification (ID) Number. EPA andall states use these 12-character numbers tomonitor and track hazardous waste activities.You will need to use your identification numberwhen you send waste off-site to be managed.
To obtain an EPA ID number:
■ Visit the EPA Web site http://www.epa.gov/epaoswer/hazwaste/data/form8700/8700-12.pdfor ADEQ's Web site at www.adeq.state.az.us,click on environmental programs>wasteprograms>haz waste>permits unit>permitsdocuments download>EPA form 8700-12.
■ Call ADEQ at (602) 771-4147 or write toADEQ, Hazardous Waste Section, FacilityAssistance Unit, 1110 W. Washington St.,Phoenix, Arizona, 85007, and request a copy ofEPA Form 8700-12, Rev 5/2002, Notificationof Regulated Waste Activity. You will be sent abooklet that contains a form with instructions.A sample copy of a completed notificationform is shown on pages 9 and 10.
■ Fill in the form as shown in the example. Tocomplete Item IX of the form, you will need toidentify your hazardous waste by its EPAHazardous Waste Code. A list of commonhazardous wastes and their waste codes can befound in the center of this document; for acomplete list of waste codes, you shouldconsult 40 CFR Part 261 (as incorporated byR18-8-261). Complete one copy of the formfor each business site where you generate orhandle hazardous waste. Each site will receiveits own EPA ID number. Make sure you signthe certification in Item X.
■ Send the completed form to the ADEQ hazard-ous waste contact. This address is listed in theinformation booklet that you will receive withthe form.
Treat your hazardous materials with care so they
don't become hazardous waste.
SQGs
ADEQ / MANAGING HAZARDOUS WASTE 9
10 MANAGING HAZARDOUS WASTE / ADEQ
ADEQ / MANAGING HAZARDOUS WASTE 11
Most small businesses accumulate some hazardous waste on-site for a short period of time andthen ship it off-site to a treatment, storage, or disposal facility (TSDF).
ACCUMULATING YOUR WASTE
Accumulating hazardous waste on-site canpose a threat to human health and the
environment, so you may only keep it for a shorttime without a permit. Before shipping the wastefor disposal or recycling, you are responsible forits safe management, which includes safestorage, safe treatment, preventing accidents,and responding to emergencies in accordancewith federal and Arizona regulations.
SQGs can accumulate no more than 13,228 lb(6,000 kg) of hazardous waste on-site for up to180 days without a permit. You can accumulatethis amount of waste for up to 270 days if youmust transport it more than 200 miles away forrecovery, treatment, or disposal. Limited exten-sions may be granted by the ADEQ director. Ifyou exceed these limits, you may be considereda TSDF and may be required to obtain anoperating permit. Special storage requirementsapply to liquid hazardous wastes containingpolychlorinated biphenyls (PCBs).
SQGs must accumulate waste in tanks or con-tainers, such as 55-gallon drums. Your storagetanks and containers must be managed accordingto the following summarized requirements.
For containers, you must:
■ Label each container with the words HAZARD-OUS WASTE, and mark each container with thedate waste was first added.
■ Use a container made of, or lined with, amaterial that is compatible with the hazardouswaste to be stored. (This will prevent the wastefrom reacting with or corroding the container.)
■ Keep all containers holding hazardous wasteclosed during storage, except when adding orremoving waste. Do not open, handle, or store(stack) containers in a way that might rupturethem, cause them to leak, or otherwise fail.
■ Inspect areas where containers are stored atleast weekly. Look for leaks and for deteriora-tion caused by corrosion or other factors.
■ Maintain the containers in good condition. If acontainer leaks, put the hazardous waste inanother container, or contain it in some otherway that complies with EPA and state regula-tions.
■ Do not mix incompatible wastes or materialsunless precautions are taken to prevent certainhazards.
MANAGING HAZARDOUS WASTE ON-SITE
✔ Accumulate wastes according to
limits established for SQGs.
✔ Follow the storage and handling pro-
cedures required by federal and
Arizona rules for SQGs.
✔ Follow requirements for equipment
testing and maintenance, access to
communications or alarms, aisle space,
and emergency arrangements with
local authorities as required by
federal and Arizona rules.
Properly store hazardous materials.
SQGs
12 MANAGING HAZARDOUS WASTE / ADEQ
TREATING YOUR WASTE TO MEET THE LAND
DISPOSAL RESTRICTIONS (LDRS)
Most hazardous wastes may not be landdisposed unless they meet treatment
standards. The Land Disposal Restrictions(LDR) program requires that the waste is treatedto reduce the hazardous constituents to levels setby EPA, or that the waste is treated using aspecific technology. It is your responsibility toensure that your waste is treated to meet LDRtreatment standards before it is land disposed.(See page 22 for a description of required LDRnotices.) Most SQGs probably will have theirdesignated TSDF do this treatment. If you chooseto treat your waste yourself to meet LDR treat-ment standards, there are additional require-ments, including waste analysis plans, notifica-tions, and certifications. To learn about theserequirements call the EPA RCRA Hotline(800) 424-9346, the ADEQ Inspections &Compliance Unit (602) 771-4108, or consult 40CFR Part 268 (as incorporated by R18-8-268).
For tanks, you must:
■ Label each tank with the words HAZARDOUSWASTE.
■ Store only waste that will not cause the tank orthe inner liner of the tank to rupture, leak,corrode, or fail.
■ Equip tanks that have an automatic waste feedwith a waste feed cutoff system or a bypasssystem for use in the event of a leak or over-flow.
■ Inspect discharge control and monitoringequipment and the level of waste in uncoveredtanks at least once each operating day. Inspectthe tanks and surrounding areas for leaks orother problems (such as corrosion) once eachoperating day.
■ Use the National Fire Protection Association(NFPA) buffer zone requirements for coveredtanks containing ignitable or reactive wastes.These requirements specify distances consid-ered to be safe buffer zones for various ignit-able or reactive wastes. You can reach theNFPA at (617) 770-3000.
■ Do not mix incompatible wastes or materialsunless precautions are taken to prevent certainhazards.
■ Do not place ignitable or reactive wastes intanks unless certain precautions are taken.
■ Provide at least two feet (60 centimeters) offreeboard (space at the top of each tank) inuncovered tanks, unless the tank is equippedwith a containment structure, adrainage control system, or astandby tank with adequatecapacity.
TIPS
✔ It is good practice never to mix wastes.
Mixing wastes can create an unsafe
work environment and lead to com-
plex and expensive cleanups and dis-
posal.
✔ Clean up spills and leaks quickly to
avoid larger problems.
Safely store hazardous wastes
in suitable containers.
SQGs
ADEQ / MANAGING HAZARDOUS WASTE 13
HAZARDOUS WASTE CODE CHART
PULL OUT AND POST
FOR QUICK REFERENCE
14 MANAGING HAZARDOUS WASTE / ADEQ
SO
LVEN
TS So
lven
ts, s
pent
sol
vent
s, s
olve
nt m
ixtu
res,
or
solv
ent s
till b
otto
ms
are
ofte
n ha
zard
ous.
The
fol
low
ing
are
som
e co
mm
only
use
dha
zard
ous
solv
ents
(al
so s
ee ig
nita
ble
was
tes
for
othe
r ha
zard
ous
solv
ents
, and
40
CFR
261
.31
for
mos
t lis
ted
haza
rdou
s w
aste
solv
ents
):
ACID
S
Aci
ds, b
ases
, or
mix
ture
s ha
ving
a pH
less
than
or
equa
l to
2 or
grea
ter
than
or
equa
l to
12.5
are
cons
ider
ed c
orro
sive
(fo
r a
com
plet
e de
scri
ptio
n of
cor
rosi
ve w
aste
s, s
ee40
CFR
261
.22)
. All
corr
osiv
e m
ater
ials
and
solu
tions
hav
e th
e w
aste
cod
e D
002.
The
follo
win
g ar
e so
me
of th
e m
ore
com
mon
lyus
ed c
orro
sive
s:
Ace
tic A
cid
Am
mon
ium
Hyd
roxi
de O
leum
Chr
omic
Aci
dH
ydro
brom
ic A
cid
Hyd
roch
lori
c A
cid
Hyd
rofl
uori
c A
cid
Nitr
ic A
cid
Ace
tone
F003
Ben
zene
F005
n-B
utyl
Alc
ohol
F003
Chl
orob
enze
neF0
02
Cyc
lohe
xano
neF0
03
Eth
yl A
ceta
teF0
03
LEAD-A
CID
BATTERIE
S
Use
d le
ad-a
cid
batte
ries
sho
uld
bere
port
ed o
n th
e no
tific
atio
n fo
rmon
ly if
they
are
not
rec
ycle
d. U
sed
lead
-aci
d ba
tteri
es th
at a
re r
ecyc
led
do n
ot n
eed
to b
e co
unte
d in
dete
rmin
ing
the
quan
tity
of w
aste
that
you
gene
rate
in a
ny m
onth
. Spe
cial
req
uire
men
ts d
oap
ply
if y
ou r
ecyc
le y
our
batte
ries
on
your
ow
npr
emis
es (
see
40 C
FR 2
66).
Ben
zene
F005
Car
bon
Dis
ulfi
deF0
05C
arbo
n Te
trac
hlor
ide
F001
Chl
orob
enze
neF0
02C
reso
lsF0
04C
resy
lic A
cid
F004
O-D
ichl
orob
enze
neF0
02E
than
olD
001
2-E
thox
yeth
anol
F005
Eth
ylen
e D
ichl
orid
eD
001
Isob
utan
olF0
05Is
opro
pano
lD
001
Ker
osen
eD
001
Met
hyl E
thyl
Ket
one
F005
Met
hyle
ne C
hlor
ide
F001
, F00
2N
apht
haD
001
Nitr
oben
zene
F004
2-N
itrob
enze
neF0
04
Lea
d D
ross
D00
8Sp
ent A
cids
D00
2L
ead-
Aci
d B
atte
ries
D00
8
IGN
ITABLE W
ASTES
Igni
tabl
e w
aste
s ar
e an
y liq
uids
that
hav
e a
flas
hpoi
nt le
ss th
an14
0°F,
any
non
-liq
uids
that
are
cap
able
of
caus
ing
a fi
re th
roug
hfr
ictio
n, a
bsor
ptio
n of
moi
stur
e, o
r sp
onta
neou
s ch
emic
al c
hang
e, o
ran
y ig
nita
ble
com
pres
sed
gas
as d
escr
ibed
in 4
9 C
FR 1
73.3
00 (
for
aco
mpl
ete
desc
ript
ion
of ig
nita
ble
was
tes,
see
40
CFR
261
.21)
.E
xam
ples
are
spe
nt s
olve
nts,
sol
vent
stil
l bot
tom
s, e
poxy
res
ins
and
adhe
sive
s,an
d w
aste
inks
con
tain
ing
flam
mab
le s
olve
nts.
Unl
ess
othe
rwis
e sp
ecif
ied,
all
igni
tabl
e w
aste
s ha
ve th
e w
aste
cod
e D
0
PESTIC
IDES The
pes
ticid
es li
sted
bel
ow a
reha
zard
ous.
Was
tes
mar
ked
with
an a
ster
isk
(*)
have
bee
n de
sig-
nate
d ac
utel
y ha
zard
ous.
For
am
ore
com
plet
e lis
ting,
see
40
CFR
261
.32
for
spec
ific
list
ed p
estic
ides
, and
othe
r w
aste
s, w
aste
wat
ers,
slu
dges
, and
by-
prod
ucts
fro
m p
estic
ide
form
ulat
ors.
EPA
HAZARD
OU
S W
ASTE
CO
DES F
OR
WASTE S
TREAM
S
CO
MM
ON
LY
GEN
ERATED B
Y S
MALL
QU
AN
TIT
Y
GEN
ERATO
RS
Eth
yl B
enze
neF0
03E
thyl
Eth
er00
3E
thyl
ene
Dic
hlor
ide
D00
1M
etha
nol
F003
Met
hyl I
sobu
tyl K
eton
e F0
03Pe
trol
eum
Dis
tilla
tes
D00
1X
ylen
eF0
03
Petr
oleu
m S
olve
nts
D00
1 (
Flas
hpoi
nt le
ss th
an 1
40°F
)Py
ridi
neF0
051,
1,1-
Tri
chlo
roet
hane
F001
, F00
21,
1,2-
Tri
chlo
roet
hane
F002
Tetr
achl
oroe
thyl
ene
F001
, F00
2 (
Perc
hlor
oeth
ylen
e)To
luen
eF0
05T
rich
loro
ethy
lene
F001
, F00
2T
rich
loro
fluo
rom
etha
neF0
02T
rich
loro
trif
luor
oeth
ane
(Val
clen
e)F0
02W
hite
Spi
rits
D00
1
ADEQ / MANAGING HAZARDOUS WASTE 15
WO
OD P
RESERVIN
G A
GEN
TS
The
was
tew
ater
trea
tmen
t slu
dges
fro
m w
aste
wat
er tr
eatm
ent o
pera
-tio
ns a
re c
onsi
dere
d ha
zard
ous.
Bot
tom
sed
imen
t slu
dges
fro
m th
etr
eatm
ent o
f w
aste
wat
er p
roce
sses
that
use
cre
osot
e an
d pe
ntac
hlo-
roph
enol
hav
e th
e w
aste
cod
e K
001.
In
addi
tion,
unl
ess
othe
rwis
ein
dica
ted,
spe
cifi
c w
ood
pres
ervi
ng c
ompo
unds
are
:
Chr
omat
ed C
oppe
r Ars
enat
eD
004
Cre
osot
eU
051
Ars
enic
D00
4B
ariu
mD
005
Cad
miu
mD
006
Chr
omiu
mD
007
HEAVY M
ETA
LS/I
NO
RG
AN
ICS
Hea
vy m
etal
s an
d ot
her
inor
gani
c w
aste
mat
eria
ls a
re c
onsi
dere
dha
zard
ous
if th
e ex
trac
t fro
m a
rep
rese
ntat
ive
sam
ple
of th
e w
aste
has
any
of th
e sp
ecif
ic c
onst
ituen
t con
cent
ratio
ns a
s sh
own
in 4
0C
FR 2
62.2
4, T
able
1. M
ater
ials
may
incl
ude
dust
s, s
olut
ions
, was
te-
wat
er tr
eatm
ent s
ludg
es, p
aint
was
tes,
and
was
te in
ks. T
he f
ollo
win
gar
e co
mm
on h
eavy
met
als/
inor
gani
cs:
Lea
dD
008
Mer
cury
D00
9Se
leni
umD
010
Silv
erD
011
CD
ASH
G
INK S
LUD
GES C
ON
TAIN
ING C
HRO
MIU
M A
ND L
EAD
Thi
s ca
tego
ry in
clud
es s
olve
nt w
ashe
s an
d sl
udge
s, c
aust
ic w
ashe
san
d sl
udge
s, a
nd w
ater
was
hes
and
slud
ges
from
cle
anin
g tu
bs a
ndeq
uipm
ent u
sed
in th
e fo
rmul
atio
n of
ink
from
pig
men
ts, d
rier
s,so
aps,
and
sta
biliz
ers
cont
aini
ng c
hrom
ium
and
lead
. All
ink
slud
ges
have
the
was
te c
ode
K08
6.
DRY C
LEAN
ING
FIL
TRATIO
N R
ESID
UES
Coo
ked
pow
der
resi
due
(per
-ch
loro
ethy
lene
pla
nts
only
), s
till
resi
dues
, and
spe
nt c
artr
idge
filte
rs c
onta
inin
g pe
rchl
oro-
ethy
lene
or
valc
lene
are
haz
ard-
ous
and
have
the
was
te c
ode
F00
2. S
till
resi
dues
con
tain
ing
petr
oleu
m s
olve
nts
with
afl
ashp
oint
less
than
140
°F a
re c
onsi
dere
dha
zard
ous
and
have
the
was
te c
ode
D00
1.
REACTIV
ES R
eact
ive
was
tes
incl
ude
mat
eria
ls o
rm
ixtu
res
that
are
uns
tabl
e, r
eact
viol
ently
with
or
form
exp
losi
vem
ixtu
res
with
wat
er, g
ener
ate
toxi
cga
ses
or v
apor
s w
hen
mix
ed w
ith w
ater
(or
whe
nex
pose
d to
pH
con
ditio
ns b
etw
een
2 an
d 12
.5 in
the
case
of
cyan
ide
or s
ulfi
de-b
eari
ng w
aste
s), o
rar
e ca
pabl
e of
det
onat
ion
or e
xplo
sive
rea
ctio
nw
hen
heat
ed o
r su
bjec
t to
shoc
k (f
or a
com
plet
ede
scri
ptio
n of
rea
ctiv
e w
aste
s, s
ee 4
0 C
FR26
1.23
). U
nles
s ot
herw
ise
spec
ifie
d, a
ll re
activ
ew
aste
s ha
ve th
e w
aste
cod
e D
003.
The
fol
low
ing
mat
eria
ls a
re c
omm
only
con
side
red
to b
e re
activ
e:
SPEN
T P
LATIN
G A
ND C
YAN
IDE W
ASTES
Spen
t pla
ting
was
tes
cont
ain
clea
ning
sol
utio
ns a
nd p
latin
g so
lutio
nsw
ith c
aust
ics,
sol
vent
s, h
eavy
met
als,
and
cya
nide
s. C
yani
de w
aste
sm
ay a
lso
be g
ener
ated
fro
m h
eat t
reat
men
t ope
ratio
ns, p
igm
ent
prod
uctio
n, a
nd m
anuf
actu
ring
of
anti-
caki
ng a
gent
s. P
latin
g w
aste
sge
nera
lly h
ave
the
was
te c
odes
F00
6-F
009 ,
with
F00
7 an
d F
009
cont
aini
ngcy
anid
e. C
yani
de h
eat t
reat
ing
was
tes
gene
rally
hav
e th
e w
aste
cod
es F
010-
F01
2(s
ee 4
0 C
FR 2
61.3
1 fo
r a
mor
e co
mpl
ete
desc
ript
ion
of p
latin
g w
aste
s).
Pent
achl
orop
heno
lF0
27
Ace
tyl C
hlor
ide
Chr
omic
Aci
dC
yani
des
Hyp
ochl
orite
sO
rgan
ic P
erox
ides
Perc
hlor
ates
Perm
anga
nate
sSu
lfid
es
Ald
icar
b*P0
70A
mitr
ole
U01
11,
2-D
ichl
orop
rope
neU
084
Hep
tach
lor*
P059
Lin
dane
U12
9M
ethy
l Par
athi
on*
P071
Para
thio
n*P0
89Ph
orat
e*P0
94
Perc
hlor
ic A
cid
Phos
phor
ic A
cid
Pota
ssiu
m H
ydro
xide
Sodi
um H
ydro
xide
Sulf
uric
Aci
d
This list can b
e u
sed a
s a g
uid
e for
small
quantity
genera
tors
to d
ete
rmin
e w
hic
h o
f th
eir
wast
es, if any, are
hazard
ous, a
nd to d
ete
rmin
e
the E
PA w
ast
e c
odes
ass
ocia
ted w
ith e
ach
wast
e. It is
not in
tended to p
rovid
e a
com
pre
hensive list of all w
ast
e c
odes
and w
ast
e
stre
am
s th
at sm
all b
usiness
es
could
genera
te.
Except fo
r th
e p
est
icid
e a
nd w
ood p
rese
rvin
g
cate
gories, this list does
not in
clu
de w
ast
e c
odes
for
com
merc
ial chem
ical pro
ducts
that are
hazard
ous
when d
iscard
ed u
nuse
d. These
wast
es, a
s w
ell a
s all o
thers
not list
ed h
ere
, can
be found in T
itle
40 o
f 40 C
FR P
art
261. If y
ou
have a
ny q
uest
ions, c
onta
ct AD
EQ
at
(602) 771-4
108 o
r (8
00) 234-5
677, th
e R
CRA
Hotlin
e a
t (8
00) 424-9
346 o
r
TD
D (800) 533-7
672 fro
m o
ther
locations.
16 MANAGING HAZARDOUS WASTE / ADEQ
ADEQ / MANAGING HAZARDOUS WASTE 17
IF YOU THINK YOU HAVE AN EMERGENCY, IMMEDIATELY
CALL THE NATIONAL RESPONSE CENTER AT
(800) 424-8802 AND ADEQ AT (602) 771-2330OR (800) 234-5677.
In the event of a fire, explosion, or other release of
hazardous waste that could threaten human health
outside the facility, or if you think that a spill has
reached surface water, call the National Response
Center to report the emergency. The Response Center
will evaluate the situation and help you make appro-
priate emergency decisions. In many cases, you will
find that the problem you faced was not a true emer-
gency, but it is better to call if you are not sure. Stiffpenalties exist for failing to report emergencies.
RESPONDING TO EMERGENCIES
You must be prepared for an emergency atyour facility. One way is to develop a
contingency plan. A contingency plan usuallyanswers a set of “what if” questions. For ex-ample: “What if there is a fire in the area wherehazardous waste is stored?” or “What if I spillhazardous waste, or one of my hazardous wastecontainers leaks?” Although EPA does not requireSQGs to develop a written contingency plan, incase of a fire, explosion, or toxic release, havingsuch a plan would provide an organized andcoordinated course of action. EPA does requireSQGs to establish basic safety guidelines andresponse procedures to follow in the event of anemergency.
Worksheets 1 and 2 (see page 19) can help youset up these procedures. The information onWorksheet 1 must be posted near your phone. Youmust ensure that employees are familiar withthese procedures. Keep information current.
Whenever you store hazardous waste on-site, you must minimize the potential
risks from fires, explosions, or other accidents.
All SQGs that store hazardous waste on-sitemust be equipped with:
■ An internal communications or alarm systemcapable of providing immediate emergencyinstruction (voice or signal) to all personnel.
■ A device, such as a telephone (immediatelyavailable at the scene of operations) or a hand-held, two-way radio, capable of summoningemergency assistance from local police andfire departments or emergency response teams.
■ Portable fire extinguishers, fire control devices(including special extinguishing equipment,such as that using foam, inert gas, or drychemicals), spill control materials, and decon-tamination supplies.
■ Water at adequate volume and pressure tosupply water hose streams, foam-producingequipment, automatic sprinklers, or waterspray systems.
You must test and maintain all equipment toensure proper operation. Allow sufficient aislespace to permit the unobstructed movement ofpersonnel, fire protection equipment, spillcontrol equipment, and decontamination equip-
ment to any area of facility opera-tion. Attempt to secure arrangementswith fire departments, police, emer-gency response teams, equipmentsuppliers, and local hospitals, asappropriate, to provide services inthe event of an emergency. Ensurethat personnel handling hazardouswaste have immediate access to analarm or emergency communicationsdevice.
PREVENTING ACCIDENTSSQGs
18 MANAGING HAZARDOUS WASTE / ADEQ
WASTE MINIMIZATION: THE KEY TO BETTER WASTE MANAGEMENT
The easiest and most cost-effective way ofmanaging any waste is not to generate it in
the first place. You can decrease the amount ofhazardous waste your business produces bydeveloping a few good housekeeping habits.Good housekeeping procedures generally savebusinesses money, and they prevent accidentsand waste. To help reduce the amount of wasteyou generate, try the following practices at yourbusiness.
■ Do not mix wastes. Do not mix nonhazardouswaste with hazardous waste. Once you mixnonhazardous waste with hazardous waste, youmay increase the amount of hazardous wastecreated, as the whole batch may becomehazardous. Mixing waste can also makerecycling very difficult, if not impossible. Atypical example of mixing wastes would beputting nonhazardous cleaning agents in acontainer of used hazardous solvents.
■ Recycle and reuse manufacturing materials.Many companies routinely put useful compo-nents back into productive use rather thandisposing of them. Items such as oil, solvents,acids, and metals are commonly recycled andused again. In addition, some companies havetaken waste minimization actions, such asusing fewer solvents to do the same job, usingsolvents that are less toxic, or switching to adetergent solution.
■ Change materials, processes, or both. Busi-nesses can save money and increase efficiencyby replacing a material or a process withanother that produces less waste. For example,you could use plastic blast media for paintstripping of metal parts rather than conven-tional solvent stripping.
■ Safely store hazardous products and containers.You can avoid creating more hazardous wasteby preventing spills or leaks. Store hazardousproduct and waste containers in secure areas,and inspect them frequently for leaks. Whenleaks or spills occur, materials used to cleanthem up also become hazardous waste.
Recycle and reuse manufacturing materials.
Employee training helps prevent waste.
SQGs
ADEQ / MANAGING HAZARDOUS WASTE 19
Fill in and post this information next to your telephone. REQUIRED.
✃
EMERGENCY RESPONSE INFORMATION
WORKSHEET 1
EMERGENCY COORDINATOR
Name:______________________________
________________________________________Telephone:__________________________
FIRE EXTINGUISHER
Location(s):_________________________
_______________________________________
_______________________________________
SPILL CONTROL MATERIALS
Location(s):________________________
_______________________________________
FIRE ALARM (IF PRESENT)Location(s): _______________________
_______________________________________
FIRE DEPARTMENT
Telephone: ________________________
Fill in shaded area and post this information next to your telephone. Makesure all employees read and are familiar with its contents.
WORKSHEET 2
EMERGENCY RESPONSE PROCEDURES
In the event of a spill:
Contain the flow of hazardous waste tothe extent possible, and as soon as ispossible, clean up the hazardous wasteand any contaminated materials or soil.
In the event of a fire:
Call the fire department and, if safe,attempt to put out the fire using a fireextinguisher.
In the event of a fire, explosion, or otherrelease that could threaten human healthoutside the facility, or if you know thatthe spill has reached surface water:Call the National Response Center at its24-hour number (800) 424-8802 andADEQ at its 24-hour number(800) 234-5677 or (602) 771-2330.Provide the following information:
Our company name:__________________________
_________________________________________
Our address:________________________________
__________________________________________
Our U.S. EPA ID number: _____________________
Date of accident:____________________________
Time of accident:____________________________
Type of accident (e.g., spill or fire):_______________
Quantity of hazardous waste involved:____________
Extent of injuries, if any:______________________
Estimated quantity and disposition of recovered
materials, if any:____________________________
✃
SQGs
20 MANAGING HAZARDOUS WASTE / ADEQ
SELECTING A TSDF
SQGs may send their waste only to a regulatedTSDF or recycler. Most regulated TSDFs andrecyclers will have a permit from the state orEPA. Some, however, may operate under otherregulations that do not require a permit. Checkwith the appropriate state authorities to be surethe facility you select has any necessary permits.All TSDFs and recyclers must have EPA IDnumbers.
LABELING WASTE SHIPMENTS
SQGs must properly package, label and mark allhazardous waste shipments, and placard thevehicles in which these wastes are shippedfollowing DOT regulations. Most small busi-nesses use a commercial transporter to shiphazardous waste. These transporters can adviseyou on specific requirements for placarding,labeling, marking, and packaging; however, youremain responsible for compliance. For addi-tional information, consult DOT regulations (49CFR Parts 172 and 173), or call the DOT hazard-ous materials information line at (202) 366-4488.In Arizona, you can also contact ADOT, Hazard-ous Materials, at (602) 712-4407.
Federal and Arizona regulations allow you totransport your own hazardous waste to a
designated TSDF provided that you comply withDOT rules and register with ADEQ as a hazard-ous waste transporter. Some states, however, donot allow this practice. Call DOT and the statehazardous waste management agency to whichyou are shipping the waste regarding applicableregulations.
SHIPPING HAZARDOUS WASTE OFF-SITE
When shipping waste off-site, SQGs must follow certain procedures that aredesigned to ensure safe transport and proper management of the waste.
Placard and label shipments properly.
SQGs
■ Package, label and mark your shipment,and placard the vehicle in which yourwaste is shipped as specified in Depart-ment of Transportation (DOT) regula-tions.
■ Prepare a hazardous waste manifest toaccompany your shipment.
■ Include a notice and certification witheach waste shipment.
■ Ensure the proper management of anyhazardous waste you ship (even when itis no longer in your possession).
ADEQ / MANAGING HAZARDOUS WASTE 21
PREPARING
HAZARDOUS WASTE MANIFESTS
A hazardous waste manifestmust accompany all hazardous
waste that is shipped off-site. A hazard-ous waste manifest is a multipart formdesigned to track hazardous waste fromgeneration to disposal. It will help youtrack your waste during shipment andensure it arrives at the proper destina-tion. If you send waste to a recyclingfacility, you may be able to use a tollingagreement instead of a manifest. Atolling agreement is a closed-looparrangement whereby a generatorcontracts with a recycling company toreclaim its hazardous waste and returnit as a recycled product, thereby avoid-ing disposal. A copy of the contractmust be kept on file for three years afterthe contract has ended.
Various versions of hazardous wastemanifest forms are available.
■ Some states require their own mani-fest form. Arizona uses the federalform (Uniform Hazardous WasteManifest, EPA form 8700-22). If thestate to which you are shipping yourwaste requires its own manifest, usethat state’s form. To obtain manifestforms, contact the hazardous wastemanagement agency of the recipientstate, your transporter, or the TSDFthat you intend to use.
■ If the state to which you are shippingdoes not require its own manifest,you can use the federal form. Copiesare available from some transporters,TSDFs, and some commercialprinters.
■ Arizona requires a hazardous wastegeneration fee of $10 for each tongenerated and shipped off site,beginning at 1 ton and prorated peradditional ton. Companies havingapproved Arizona Pollution Preven-tion Plans receive a $5 per tondiscount. See Appendix C.
SELECTING ATRANSPORTER OR TSDF/RECYCLER
It is important to choose your transporter andyour TSDF carefully since you remain responsiblefor the proper management of your hazardouswaste even after it has left your site and has beenprocessed by your TSDF.
For help in choosing a transporter or TSDF, checkwith the following sources:
■ References from business colleagues who haveused a specific hazardous waste transporter orTSDF.
■ Trade associations for your industry that mightkeep a file on companies that handle hazardouswaste.
■ The Better Business Bureau or Chamber ofCommerce in the TSDF’s area, which mighthave a record of any complaints registeredagainst a transporter or a facility.
■ ADEQ can tell you whether the transporter orTSDF has a U.S. EPA ID number and a permit,if required.
Technological advances can help reduce waste.
SQGs
22 MANAGING HAZARDOUS WASTE / ADEQ
You must fill in all parts of amanifest and sign it. Information
requested includes: name of transporter,name of the designated facility, yourEPA ID number, quantity of waste, anda description of the waste based onDOT requirements, such as propershipping name and hazard class. Callthe DOT information line for moreinformation on DOT waste descriptionrequirements. Arizona requires the EPAWaste Codes to be listed in Column I.
The transporter is required to sign thecompleted manifest when the shipmentis accepted for transport. The facilityoperator at the designated TSDF alsosigns the form when the shipment isreceived and sends a copy of it back toyou. You must keep this copy on file forthree years. (It might be a good practice,however, to keep it for as long as youare in business.) Arizona also requiresthe generator and transporter to send acopy of the manifest to ADEQ, Hazard-ous Waste Section, Facility AssistanceUnit, 1110 W. Washington St., 4415A-1,Phoenix, AZ, 85007. All TSDFs locatedin Arizona are also required to sendcopies to ADEQ.
Arizona requires generators to submitmanifests for hazardous waste ship-ments only. The generator copy submit-ted to ADEQ must have three signa-tures: the generator, the transporter,and the TSDF.
Any SQG that does not receive a signedcopy of the manifest from the desig-nated TSDF must submit a legible copyof the manifest together with a writtennotice indicating that a signed copy wasnot received from the facility operator.This is known as an exception reportand must be submitted to ADEQ within60 days following the end of the monthof shipment of the waste. If errors arefound in your manifest, you mustcorrect the manifest and pay a $20 permanifest resubmittal fee. See AppendixC for example.
LAND DISPOSAL RESTRICTIONS
(LDR) REPORTING REQUIREMENTS
Regardless of where the wasteis being sent, for each ship-
ment of waste subject to LDRs youmust send the receiving TSDF orrecycler an LDR notice. This noticemust provide information aboutyour waste, such as the EPAhazardous waste code and the LDRtreatment standard. The purpose ofthis notice is to let the TSDF knowthat the waste must meet treatmentstandards before it is land disposed.There is no required form for thisnotice, but your TSDF may providea form for you to use. A certifica-tion may also be required in spe-cific situations. Call the EPA RCRAHotline at (800) 424-9346, theADEQ Inspections and ComplianceUnit at (602) 771-4108, and consult40 CFR Part 268 for help with LDRnotification and certificationrequirements.
EXPORT
NOTIFICATION
If you choose to export yourhazardous waste, you must
notify EPA 60 days before theintended date of shipment toobtain written consent. EPA’sAcknowledgment of Consentdocument must accompany theshipment at all times. For moreinformation on how to obtainthe consent to export hazardouswaste, contact the EPA RCRAHotline at (800) 424-9346.
Plating processes must be managed properly.
SQGs
ADEQ / MANAGING HAZARDOUS WASTE 23
Hazardous waste determina-
tion (40 CFR 262.10)
Generator category determi-
nation [40 CFR 262.10 (b)
and 261.5 (b) and (c)]
EPA ID numbers (40 CFR
262.12)
Prepare hazardous waste for
shipment off-site (40 CFR
262.30–262.33)
The manifest (40 CFR
262.20–262.23, 262.42)
Managing hazardous waste
on-site (40 CFR 262.34)
Recordkeeping, registration,
fees, and annual report (40
CFR 262.40–262.41) Arizona
requires an annual report.
Comply with land disposal
restrictions (40 CFR 268)
Export/import requirements
(40 CFR 262 Subparts E and
F)
LQG REQUIREMENTS
Identify and document all hazardous wastes you generate. Measure
the amount of hazardous waste you generate per calendar month to
determine your generator category (e.g., LQG).
Obtain a copy of EPA Form 8700-12, fill out the form, and send it to
the contact listed with the form. An EPA ID number will be returned
to you for your location.
Package, label, mark, and placard wastes following DOT require-
ments. Ship waste using hazardous waste transporter.
Ship waste to hazardous waste treatment, storage, disposal, or
recycling facility. Ship hazardous waste off-site using the manifest
system (EPA Form 8700-22) or state equivalent. Send copy to ADEQ.
Accumulate waste for no more than 90 days without a permit.
Accumulate waste in: Containers / drip pads / tanks / containment
buildings, and comply with specified technical standards for each
unit type. Comply with preparedness and prevention requirements.
Prepare written contingency plan. Train employees in hazardous
waste management and emergency response.
If you are a large quantity generator (LQG) [generating more than 2,200 lb (1,000 kg) in anycalendar month or 220 lb (100 kg) of acute spill residue], you must comply with the full setof hazardous waste regulations. If you generate or accumulate more than 2.2 lb (1 kg) acutelyhazardous waste or 220 lb (100 kg) of acute spill residue in a calendar month, the acutelyhazardous waste must be managed according to LQG regulations. This table summarizes thefederal and state LQG requirements. This is only a summary and does not include all of theLQG requirements. For more details, call the EPA RCRA Hotline, ADEQ Inspections &Compliance Unit, or see 40 CFR Part 262.
SUMMARY OF REQUIREMENTS FOR LQGS
Retain specified records for three years. Register with ADEQ and
pay annual fee of $300. Arizona requires a hazardous waste genera-
tion fee of $10 for each ton generated and shipped off site, begin-
ning at 1 ton and prorated per additional ton. Companies having
approved Arizona Pollution Prevention Plans receive a $5 per ton
discount. Submit annual reports by March 1 of each year covering
generator activities for the previous year.
Ensure that wastes meet treatment standards prior to land disposal.
Send notifications and certifications to TSDF as required. Maintain
waste analysis plan if treating on-site.
Follow requirements for exports and imports, including notification
of intent to export and acknowledgment of consent from receiving
country.
SUMMARY
LQGs
24 MANAGING HAZARDOUS WASTE / ADEQ
FINAL TIPS
CAN YOU USE THE
UNIVERSAL WASTE RULE?
Do you have hazardous wastes that can bemanaged under the hazardous waste universalwaste rule? Items such as hazardous wastebatteries, certain hazardous waste pesticides,mercury-containing thermostats, and mercury-containing waste lamps fall under the universalwaste regulations.
Small and large businesses that generate hazard-ous wastes that are in the universal waste catego-ries listed above can use the more streamlinedrequirements under the universal waste rule. Iteases the regulatory burden on businesses thatgenerate these wastes. Specifically, it has stream-lined requirements for: notification, labeling,marking, prohibitions, accumulation time limits,employee training, response to releases, off-siteshipments, tracking, exports, and transportation.
For example, the rule extends the amount of timethat businesses can accumulate these materials onsite. It also allows companies to transport themwith a common carrier, instead of a hazardouswaste transporter, and no longer requires compa-nies to obtain a manifest.
For additional assistance, contact the FacilityAssistance Unit, Compliance Assistance Pro-gram, at (602) 771-4235.
ARE YOU SURE?
■ Have you marked your containers ofhazardous waste with the wordsHAZARDOUS WASTE? Have youincluded the accumulation start date?
■ Do you keep your containers closed atall times, except when adding orremoving waste?
■ Have you done a hazardous wastedetermination? Have you kept therecords of test results, waste analysis,or other determination?
■ Are you operating and maintainingyour facility in a manner to minimizethe possibility of hazards throughabatement of potential fire, explo-sions, safety hazards, and potentialreleases? Are you providing adequatemaintenance and repair of yourequipment and structures so you arein compliance with state and localfire, electrical and building codes, andsafety codes?
■ Are you controlling, containing,cleaning up, and properly disposing ofany and all releases of hazardouswaste?
■ Have you developed and are youmaintaining and posting the requiredemergency contact information nextto your telephone?
■ Are you filing your Annual Reportand paying your registration andgeneration fees?
The above are things that inspectorstypically find facilities not doing whenthey go on inspections—don’t be caughtin violation.
ADEQ / MANAGING HAZARDOUS WASTE 25
Arizona Revised Statues: Contact the Arizona StateBar Association, (602) 252-4804; http://www.azleg.state.az.us/ars/49/title49.htm
Arizona Administrative Code (AAC): Contact theSecretary of State, (602) 542-4086, http://www.sos.state.az.us/public_services/Table_of_contents.htm
APPENDIX B—EPA AND
OTHER FEDERAL RESOURCE CENTERS
EPA Region 9 / Hazardous Waste Management Div.75 Hawthorne StreetSan Francisco, CA 94105Phone: (415) 947-8708Library: (415) 744-1510www.epa.gov/region09/
RCRA/Superfund/LUST Hotline1725 Jefferson Davis HighwayArlington, VA 22202Phone: (800) 424-9346 or TDD (800) 553-7672Fax: (703) 486-3333Answers questions on matters related to solid waste,hazardous waste, and underground storage tanks. Alsocan be used to find and order EPA publications.
Small Business Ombudsman Clearinghouse/HotlineU.S. EPA / Small Business Ombudsman (1230C)401 M Street SWWashington, DC 20460Phone: (800) 368-5888Fax: (703) 305-6462Helps private citizens, small businesses, and smallercommunities with questions on all program aspectswithin EPA.
Pollution Prevention Information Clearinghouse(PPIC)PPIC-EPA401 M Street SW (3404)Washington, DC 20460Phone: (202) 566-0799Fax: (202) 566-0794E-mail: [email protected] a library and an electronic bulletin board (ac-cessible by any PC equipped with a modem) dedicatedto information on pollution prevention.
WHERE TO GET MORE HELP
Your business may also be regulated by othersections of the Code of Federal Regulations
(CFR). You may want to investigate the followingCFRs:
■ Handling PCBs (40 CFR Part 761)■ Toxic Release Inventory (TRI) Reporting (40 CFR
Part 372)■ Domestic Sewage Waste Disposal Reporting (40
CFR Part 403)■ Shipping Hazardous Materials (49 CFR Parts 171-
180)
APPENDIX A—STATE
HAZARDOUS WASTE MANAGEMENT ASSISTANCE
For further assistance in understanding thehazardous waste rules applicable to you,
or your compliance with them, contact:
Arizona Hazardous WasteInspections & Compliance UnitArizona Dept. of Environmental Quality1110 W. Washington St.Phoenix, AZ 85007(602) 771-4108 or (800) 234-5677
Or call the Facility Assistance Unit, ComplianceAssistance Program. The ADEQ Compliance Assis-tance program is a free, non-regulatory assistanceprogram created to help small businesses understandand follow hazardous waste regulations, and identifypollution prevention opportunities that may savemoney and reduce liability. Businesses can receivenon-regulatory assistance ranging from answeringquestions over the phone to individual facility visits.The Compliance Assistance Program can be contactedat (602) 771-4235; toll free (800) 234-5677.
To obtain the regulations, statutes, and rules referredto in this publication, contact the following or checkout the Web site listed.
Code of Federal Regulations: Contact the GovernmentPrinting Office, (202) 512-1800; http://www.epa.gov/epacfr40/chapt-I.info/
26 MANAGING HAZARDOUS WASTE / ADEQ
HAZARDOUS WASTE REGISTRATION FEE INVOICE AND FACILITY ANNUAL REPORT FOR SQGS
This form is mailed in January to SQGs, LQGs, TSDFs, resource recovery facilities, andtransporters. It covers your registration fees for the current year and is based on the highestamount of hazardous waste you generated in any one month of the previous year.
HAZARDOUS WASTE FACILITY ANNUAL REPORT FOR CESQGS
This form is the annual report for CESQGs. Your status is based on the highest amount ofhazardous waste you generated during any one month in the previous year. It is also mailed inJanuary. CESQGs have no registration fees.
APPENDIX C: FORMS/INVOICES FROM THE HAZARDOUS WASTE SECTION
ADEQ / MANAGING HAZARDOUS WASTE 27
HAZARDOUS WASTE GENERATION FEE INVOICE
This form is also mailed to SQGs in January of each year. It covers the amount of hazardouswaste you generated in the preceding year.
HAZARDOUS WASTE MANIFEST RESUBMITTAL FEE INVOICE
This form is only used when a facility has an error on the manifests submitted to ADEQ.A $20 fee is charged on each incorrect manifest.
28 MANAGING HAZARDOUS WASTE / ADEQ
❐ ❐
❐ ❐
✃
1. Do you have documentation on the amount and kinds of hazardous wastethat you generate and how you determined that they are hazardous?
2. Do you have a U.S. EPA ID number?
3. Do you ship wastes off-site?
4. If so, do you know the names of the transporter and the designated TSDFthat you use?
5. Do you have copies of completed manifests used to ship your hazardouswastes over the past three years? Have you sent copies with all threesignatures to ADEQ ?
6. Are they filled out correctly?
7. Have they been signed by the designated TSDF and transporter?
8. If you have not received your signed copy of the manifest from the TSDF,have you filed an exception report?
9. Is your hazardous waste stored in proper containers or tanks?
10. Are the containers or tanks properly dated and/or marked?
11. Have you complied with the handling requirements described in thisdocument?
12. Have you designated an emergency coordinator?
13. Have you posted emergency telephone numbers and the location of emer-gency equipment? Is your Emergency Coordinator's name correct?
14. Are your employees thoroughly familiar with proper waste handling andemergency procedures?
15. Do you understand when you need to contact the National ResponseCenter and ADEQ?
16. Do you store your waste for no more than 180 days, or 270 days if youship your waste more than 200 miles?
❐ ❐
❐ ❐
❐ ❐
WORKSHEET 3
❐ ❐
❐ ❐
❐ ❐
❐ ❐
❐ ❐
❐ ❐
❐ ❐
❐ ❐
❐ ❐
❐ ❐
❐ ❐
YES NO
These questions are geared toward the federal requirements for SQGs but may be helpful forother hazardous waste generators. Use them to help prepare for a visit from a federal, state,or local agency.
ADEQ / MANAGING HAZARDOUS WASTE 29
Acute Hazardous Waste
Waste that is listed and even when managedproperly is extremely dangerous.
By-product
A material that is not one of the primary productsof a production process. Examples of by-prod-ucts are process residues, such as slags or distil-lation column bottoms.
Commercial Chemical Product
A chemical substance that is manufactured orformulated for commercial or manufacturing use.
Container
Any portable device in which a material isstored, transported, treated, disposed of, orotherwise handled.
Elementary Neutralization Unit
A tank, tank system, container, transport vehicle,or vessel (including ships) that is designed tocontain and neutralize corrosive waste.
Reclaimed Material
Material that is regenerated or processed torecover a usable product. Examples are therecovery of lead values from spent batteries andthe regeneration of spent solvents.
Recovered Material
A material or by-product that has been recoveredor diverted from solid waste. Does not includematerials or by-products generated from, andcommonly used within, an original manufactur-ing process.
Recycled Material
A material that is used, reused, or reclaimed.
Reused Material
A material that is employed as an ingredient in anindustrial process to make a product, or as aneffective substitute for a commercial product.
Spent Material
Any material that has been used and, as a resultof contamination, can no longer serve thepurpose for which it was produced without firstprocessing it.
Sludge
Any solid, semi-solid, or liquid waste generatedfrom a municipal, commercial, or industrialwastewater treatment plant, water supply treat-ment plant, or air pollution control facility,exclusive of the treated effluent from a wastewa-ter treatment plant.
Still Bottom
Residue or by-product of a distillation process,such as solvent recycling.
Tank
A stationary device designed to contain anaccumulation of hazardous waste that is con-structed primarily of nonearthen materials (e.g.,wood, concrete, steel, plastic).
Totally Enclosed Treatment Facility
A facility for the treatment of hazardous wastethat is directly connected to an industrial produc-tion process and that is constructed and operatedso as to prevent the release of hazardous wasteinto the environment during treatment. Anexample is a pipe in which waste acid is neutral-ized.
Toxicity Characteristic Leaching Procedure
(TCLP)
A testing procedure used to determine whether awaste is hazardous. The procedure identifieswaste that might leach hazardous constituentsinto groundwater if improperly managed.
Wastewater Treatment Unit
A tank or tank system that is subject to regulationunder either Section 402 or 307(b) of the CleanWater Act, and that treats or stores an influentwastewater that is hazardous waste, or that treatsor stores a wastewater treatment sludge that ishazardous.
DEFINITIONS
30 MANAGING HAZARDOUS WASTE / ADEQ
(602) 7
71-2
300
TD
D (6
02) 7
71-4
829
TO
LL
FREE
IN ARIZ
ON
A (800) 2
34-5
677
WW
W.A
DEQ.S
TATE.A
Z.US
TM
03-0
1 J
AN
2003
ARIZ
ON
A DEPT. O
F EN
VIR
ON
MEN
TAL Q
UALIT
Y
1110 W
EST W
ASH
ING
TO
N S
TREET
PH
OEN
IX , AZ 8
5007