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Waste Management and Pollution Controls

1) Define a generator (40 CFR 260.10) subject to hazardous waste regulations.
2) List each category of generator based on amount of waste generated monthly. Include monthly quantities allowed per category, time limits, and storage requirements. Explain why choosing the correct generator status could be important to a company.
3) Shippers of HW must follow the regulations as outlined in RCRA and also in which law? List the law by name and give the regulatory citation to reference when determining proper shipping name.
4) Proper classification under the above requirements includes determining the following: (all elements required in basic shipping description)
5) What is required for mixtures or solutions of HW and non-hazardous waste for a proper shipping name? Give all conditions that must be met.
6) If you see a placard on a transport vehicle that is Class 3, what kind of material is being transported? Could you safely ship a Class 5 waste with this material? Explain why or why not.
7) Completely define the TSD aspect of a TSDF. (i.e. What does TSD stand for/define each?)
8) What records are required to be maintained by a TSDF? Be specific.
9) List 5 types of HW management units. Briefly describe each unit and some general operating requirements for each.
10) Compare and contrast the difference between an interim status TSDF permit and a full permit. Be specific.
11) Describe the requirements for both TSDFs and generators under Land Disposal Restriction regulations. What amendments provided these requirements (cite the law)?
12) Describe the RCRA corrective action process in detail. These actions are specific to certain facilities and releases. What type of clean up action is regulated by RCRA corrective actions and what type of facility?
13) Name the 5 federal laws that address/require spill reporting and describe the requirements for each law.
14) Describe liability under CERCLA. Include types of liability, entities that are potentially responsible, limits, and possible defences under CERCLA.
15) Thoroughly describe the RI/FS process under CERCLA.
16) Outline and describe the public's participation role in RCRA and CERCLA processes.

Solution Preview

1) A generator is any site or person whose act or process produces a hazardous waste and is identified or listed in the section 261 of the 40 CFR 260.10 of EPA regulations. It also means any act that causes a hazardous waste and needs to be regulated.

2) Hazardous waste generators are divided into three categories:

i) Large quantity generators or LQG- These are generators who generates 1000 kilograms or more of acutely hazardous waste per month. Generators who produce 100kg or more of acute spill residue or soil per month are also termed as LQGs. They can accumulate waste only for 90 days on site barring certain exceptions. There must be at least one employee available to respond to emergencies usually it is the emergency coordinator. They must have detailed and written contingency plans on how to respond during emergencies. They must comply fully for the management of their tanks, drip pads, containers or containment buildings.
ii) Small Quantity Generators or SQG - Generators who generate more that 100 kg but less than 1000 kg of hazardous waste per month are termed SQG. They can accumulate waste on the site for upto 180 days without a permit or if the shipping distance is more than 200 miles then upto 270 days. The quantity of hazardous waste on the site cannot exceed 6000 kg. There must be atleast one employee available to respond to emergencies usually it is the emergency coordinator. They do not require any specific detailed contingency plans for emergencies. Their storage requirements are basic with technical standards for tanks and containers.
iii) Conditionally exempt small quantity generators or CESQ- These generators generate 100kgs or less of hazardous waste per month or 1kg or less of acutely hazardous waste. CESQs are required to identify all the types of hazardous waste generated. They cannot acquire more than 1000kgs of waste at any given time. They are required to deliver the hazardous wastes to a facility or person who has the authority to manage it. They have no specific storage requirements.

Companies should be careful when choosing their generator status as the safety of the company; employees and the community are dependent on it. If they estimate is less than the quantity of actual HW generated then they end up polluting the environment and go against EPA regulations.

3) The law that must be followed while determining proper shipping name is the RCRA or Resource Conservation and Recovery Act. The regulatory citation that needs to be referenced for proper shipping name is 49CFR 172.101 and a hazardous waste manifest form needs to completed along with the given EPA identification number.

4) Shipping of hazardous materials must include the basic description of the hazardous material which includes the identification number, hazard class, the proper shipping class and name of the packing group whenever applicable. In addition subsidiary information may include information like technical names of the hazardous material, quantity of material, the number and type of packages and those that come under part 172.201 to 172.204 of the guidelines of shipping of hazardous material. The emergency contacts must also be listed.

5) A mixture or solution not identified specifically by name, comprised of a single predominant hazardous material identified in the Hazardous Material Table must be described using ...