United States Solid Waste and EPA530-K-00-003
Environmental Protection Emergency Response September 2000
Agency (5305W) www.epa.gov/osw
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FOR MORE INFORMATION CALL:
RCRA Hotline
U.S. Environmental Protection Agency
800 424-9346 or TDD 800 553-7672.
In the Washington, DC, area: 703 412-9810
or TDD 703 412-3323.
5 Printed on paper that contains at least 30 percent postconsumer fiber.
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CONTENTS
Foreword 2
Frequently Asked Questions About RCRA 3
The Life Cycle of a Typical Motor Freight/Railroad
Transportation Waste 6
Requirements for Regulated Motor Freight/Railroad
Transportation Facilities 8
Reduce or Minimize the Hazardous Wastes You Generate 10
Other Environmental Laws Affecting the Motor Freight/Railroad
Transportation Industry 15
Contacts and Resources 17
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FOREWORD
If you are involved with the motor freight and railroad
transportation industries, your facility probably generates
hazardous waste. That means you are regulated by the U.S.
Environmental Protection Agency (EPA) under a federal law called
the Resource Conservation and Recovery Act (RCRA). Under
RCRA, you are required to follow certain procedures when
generating, storing, transporting, treating, or disposing of hazardous
waste. RCRA in Focus provides an overview of the federal hazardous
waste regulations you are required to follow and wastes that are likely
to be hazardous in your business. It also provides recycling and
pollution prevention options to help you decrease the amount of
hazardous waste you generate.
RCRA IN FOCUS
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FREQUENTLY ASKED QUESTIONS
ABOUT RCRA
What Is RCRA?
RCRA is a federal law that encourages environmentally sound methods for managing
commercial and industrial waste as well as household and municipal waste. It regulates facilities that
generate, transport, treat, store, or dispose of hazardous waste. The vast majority of motor freight
and railroad transportation facilities are considered hazardous waste generators, rather than
treatment, storage, and disposal facilities (TSDFs), which are subject to more rigorous regulations.
The term "RCRA" is often used interchangeably to refer to the law, the regulations, and EPA
policy and guidance. The law describes the waste management program mandated by Congress that
gave EPA authority to develop the RCRA program. EPA regulations carry out the Congressional
intent by providing explicit, legally enforceable requirements for waste management. EPAguidance
documents and policy directives clarify issues related to the implementation of the regulations.
All of the RCRA hazardous waste regulations can be found in the Code of Federal Regulations
(CFR), Title 40, Parts 260 to 279. The CFR can be purchased through the U.S. Government
Printing Office (GPO).
Who Is Regulated?
Any motor freight or railroad transportation facility that generates hazardous waste is potentially
subject to RCRA. You must conduct tests required by the regulations or use your knowledge of and
familiarity with the waste you generate to determine whether it is hazardous waste (as opposed to
other types of waste). You might be subject to substantial civil and criminal penalties if you fail to
properly or completely identify hazardous waste generated by your business.
What Is Hazardous Waste?
To be considered hazardous waste, a material first must be classified as a solid waste. EPA defines
solid waste as garbage, refuse, sludge, or other discarded material (including solids, semisolids,
liquids, and contained gaseous materials). If your waste is considered solid waste, you must then
determine if it is hazardous waste. Wastes are defined as hazardous by EPA if they are specifically
named on one of four lists of hazardous wastes (listed wastes) or if they exhibit one of four
characteristics (characteristic wastes). Each type of RCRA hazardous waste is given a unique
hazardous waste code using the letters D, F, K, P, or U and three digits (e.g., D001, F005, P039).
See pages 10 to 14 for additional information on motor freight and railroad transportation waste
codes.
Listed Wastes. Wastes are listed as hazardous because they are known to be harmful to human
health and the environment when not managed properly, regardless of their concentrations. The
lists include the following three types of waste:
• Non-Specific Source Wastes. These are material-specific wastes, such as solvents, generated
by several different industries. Waste codes range from F001 to F039. Examples include ethyl
benzene, methylene chloride, and toluene.
• Specific Source Wastes. These are wastes from specifically identified industries. Waste codes
range from K001 to K161. Motor freight and railroad transportation facilities typically do not
generate specific source wastes.
• Discarded Commercial Chemical Products. Off-specification products, container residuals,
spill residue runoff, or active ingredients that have spilled or are unused and that have been, or
are intended to be, discarded. Waste codes for acutely hazardous chemicals range from P001 to
P205 and U001 to U411. An example is U159, unused methyl ethyl ketone.
STATE
REQUIREMENTS
You may be reg-
ulated both by
your state hazardous
waste agency and EPA
RCRA allows states to
receive legal permission,
known as authorization,
to implement the RCRA
hazardous waste pro-
gram. You must always
contact your state
authority to determine
which state require-
ments apply to your
business.
To operate a haz-
ardous waste program, a
state's regulations must
be consistent with, and
at least as stringent as,
the federal program.
Some states adopt more
stringent requirements
for facilities handling
hazardous waste, which
are considered part of
the authorized program.
MORE
QUESTIONS?
Call the RCRA
Hotline at
800 424-9346 or TDD
800 553-7672 for addi-
tional information about
RCRA rules and regula-
tions. In the Washington,
DC, area, call 703 412-
9810 or TDD 703 412-
3323.
MOTOR FREIGHT & RAILROAD TRANSPORTATION
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AM I REGULATED
BY RCRA OR
SUPERFUND?
RCRA regulates the
treatment, storage,
and disposal of hazardous
waste being generated now
and in the future.
Superfund was created to
pay for the identification,
inspection, investigation,
ranking, and cleanup of
abandoned or uncon-
trolled hazardous waste
sites that people responsi-
ble for contamination are
unable or unwilling to
clean up. Call the RCRA
Hotline for more
information.
HOW IS USED
OIL HANDLED?
RCRA contains spe-
cial provisions for
the management of used
oil destined for recycling.
These management stan-
dards apply to oil refined
from crude oil or any syn-
thetic oil that has become
contaminated through use
by chemical or physical
impurities. Used oil that
will be recycled or reused
is subject to special man-
agement standards, rather
than the hazardous waste
standards, unless it is
treated as a waste (i.e., you
decide to send the used oil
for treatment and disposal
rather than recycling). The
used oil regulations can be
found in 40 CFR 279.
Characteristic Wastes. Even if your waste does not appear on one of the hazardous waste lists, it still
might be regulated as hazardous waste if it exhibits one or more of the following characteristics:
• Ignitability. Ignitable wastes create fires under certain conditions or are spontaneously combustible,
and have a flash point less than 60°C (140°F). One example is spent solvents from motor freight and
railroad transportation operations. The waste code for these materials is D001.
• Corrosivity. Corrosive wastes are acids or bases that are capable of corroding metal containers,
such as storage tanks, drums, and barrels. Acidic waste from motor freight and railroad
transportation surface preparation is a good example. The waste code for these materials is D002.
• Reactivity. Reactive wastes are unstable under "normal" conditions. They can cause explosions,
toxic fumes, gases, or vapors when mixed with water. Examples include lithium-sulfur batteries
and explosives. The waste code for these materials is D003.
• Toxicity. Toxic wastes are harmful or fatal when ingested or absorbed. When toxic wastes are
disposed of on land, contaminated liquid might drain (leach) from the waste and pollute ground
water. Toxicity is defined through a laboratory procedure called the Toxicity Characteristic
Leaching Procedure (TCLP). Certain chemicals in pigment wastes generated from motor freight
and railroad transportation staining and painting are examples of potential toxic wastes. The
waste codes for these materials range from D004 to D059.
How Are Generators Regulated?
If your motor freight or railroad transportation business generates hazardous waste, you must
manage it according to regulations for your specific generator type. Hazardous waste generators are
divided into three categories, according to how much they generate in a calendar month:
• Large Quantity Generators (LQGs). LQGs generate greater than or equal to 1,000 kg
(approximately 2,200 Ib) of hazardous waste per month or greater than 1 kg (approximately 2.2
Ib) of acutely hazardous waste per month.
• Small Quantity Generators (SQGs). SQGs generate greater than 100 kg (approximately 220
Ib) but less than 1,000 kg (approximately 2,200 Ib) of hazardous waste per month.
• Conditionally Exempt Small Quantity Generators (CESQGs). CESQGs generate less than
or equal to 100 kg (approximately 220 Ib) of hazardous waste per month and less than or equal to
1 kg (approximately 2.2 Ib) of acutely hazardous waste per month.
Some states do not recognize the CESQG class. Contact your state environmental agency to find
out if the CESQG status is recognized. To find your appropriate state contact, call the RCRA
Hotline at 800 424-9346.
Under the federal RCRA requirements, your generator status might change from one month to
the next as the quantity of waste you generate changes. State requirements vary widely. You must
comply with whichever standard is applicable for a given month. In many cases, small businesses
that fall into different generator categories at different times choose to always satisfy the more
stringent requirements (usually state requirements) to simplify compliance. Generators must
"count" the amount of waste generated, which involves adding up the total weight of all quantities
of characteristic and listed waste generated at a particular facility. Certain wastes, such as those that
are reclaimed or recycled continuously on site, may not be counted for the monthly total calculation
under the federal regulations.
RCRA IN FOCUS
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Do Exclusions Exist?
The RCRA regulations contain many exclusions for wastes and waste management practices that
are not considered to be hazardous. Several exclusions and exemptions pertain specifically to the
motor freight and railroad transportation industry. Some states, however, do not recognize the
federal exclusions.
Exclusions and Exemptions Description
Domestic Sewage Exclusion
"Closed Loop" Recycling
Exclusion
Scrap Metal Recycling
Exclusion
Mixtures of domestic sewage and other wastes that pass
through a sewer system to a publicly owned treatment works
(POTW) for treatment are excluded. Generators are encour-
aged to contact their local POTW to find out what regula-
tions apply.
Wastes that are reclaimed and returned for use to the original
process in which they were generated are generally excluded
as long as: 1) only tank storage is used; 2) the process is
enclosed (e.g., hard piped); 3) controlled flame combustion
is not used; and 4) the wastes are not stored for more than 12
months prior to reclamation.
Scrap metals being recycled are generally exempt from the
hazardous waste management regulations.
How Is Antifreeze Handled?
While no special federal requirements exist at present for the management and disposal of used
antifreeze, generators are required to determine whether used atifreeze from vehicles is hazardous
or nonhazardous. Used antifreeze has the potential to be hazardous due to potentially high pH or
lead levels. Generators must test their waste or rely upon their knowledge of the waste to make a
determination about whether it meets the definition of a hazardous waste. If it is hazardous, it must
be handled like any other hazardous waste.
MOTOR FREIGHT & RAILROAD TRANSPORTATION
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THE LIFE CYCLE OF
A TYPICAL MOTOR
FREIGHT & RAILROAD
TRANSPORTATION
WASTE
You've just finished cleaning engine parts and
are left with solvent wastes that must be
managed according to RCRA. You generate
a small quantity of this type of waste each month.
You have decided to reclaim solvents onsite using a
distillation unit.
This example details a typical waste life cycle at a
motor freight, railroad transportation, or tank clean-
ing facility. This life cycle presents the hazardous
waste management requirements for the generator
from generation to shipment off site.
The example given is of an SQG motor freight
terminal generating hazardous waste spent solvent
solutions. Other waste life cycles could be different
depending on the waste, whether onsite treatment
will occur, the type of waste management units
used, and the facility generator status.
SEND WASTE OFF
SITE FOR TREATMENT,
STORAGE, OR
DISPOSAL
Using a registered hazardous
waste transporter, send the
waste to a RCRA hazardous
waste TSDF accompanied by
the appropriate manifest. You
can choose from any permit-
ted or interim status TSDF.
Options for solvents include a
hazardous waste incinerator
that will landfill the incinera-
tor ash, a hazardous waste fuel
blender who will blend the
solvents with other wastes and
then burn them for energy
recovery in a boiler or indus-
trial furnace, or a facility that
will recycle the solvents.
RCRA IN FOCUS
IDENTIFY WASTE
By running tests or using
your knowledge of the waste,
identify whether your solvent
waste is hazardous. Based on
these analyses, determine the
appropriate waste code for
your solvents; in this case, for
example, it could be D001,
D035, D037, D039, D040,
and F001 through F005. Keep
all records of test results,
waste analyses, and other
determinations made in the
hazardous waste identification
process for 3 years.
PREPARE
APPROPRIATE
NOTIFICATION AND
CERTIFICATION
Ensure that all hazardous
waste sent off site for treat-
ment, storage, and disposal is
accompanied by appropriate
notifications and certifica-
tions (initial shipments only).
COUNT WASTE
Next, determine how much
hazardouse waste you have
produced in a calender
month. Do not count solvent
placed directly into a solvent
recovery still. Count the sol-
vent still bottoms when they
are removed from the still,
however.
PREPARE
HAZARDOUS WASTE
MANIFEST
Send a manifest along with all
hazardous waste sent off site
to a TSDF. Be sure to receive
a completed copy of the man-
ifest from the TSDF, and
keep a copy on site for 3
years. The manifest contains a
certification stating that you
have a program in place to
reduce the volume and toxici-
ty of waste generated to the
degree economically practica-
ble, and that you have select-
ed a treatment, storage, and
disposal method currently
available that minimizes cur-
rent and future threats from
the waste.
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DETERMINE
GENERATOR STA-
TUS
Add together all haz-
ardous wastes to deter-
mine your generator sta-
tus. In this case, you have
produced less than 1,000
kg (2,200 Ib) but greater
than 100 kg (220 Ib) of
still bottoms from your
solvent recovery unit,
which means you are an
SQG in this calender
month period. If the
amount of waste you
generate fluctuates from
month to month, you
may wish to satisfy the
more stringent require-
ments each month to
simplify compliance.
FOLLOW U.S.
DEPARTMENT OF
TRANSPORTATION
(DOT) PACKAGING
STANDARDS
Before shipping waste off site
for treatment, storage, or dis-
posal, package, label, and
mark waste containers in
accordance with all applicable
DOT requirements. For
more information, call the
DOT Hotline at 800 467-
4922.
OBTAIN EPA
IDENTIFICATION
NUMBER
To identify your business as a
hazardous waste generator,
obtain an EPA identification
number by submitting Form
8700-12 (Notification of
Regulated Waste Activity),
which is obtained from your
state hazardous waste agency.
Remember, your state
requirements might be
different.
CONTRACT WITH
HAZARDOUS WASTE
TRANSPORTER
To send waste off site to a
TSDF, contract with a regis-
tered hazardous waste trans-
porter. To locate a reliable
transporter, contact a col-
league to obtain a reference.
PLACE WASTE IN
ACCUMULATION
UNIT
When the waste is generated,
place it in an appropriate
accumulation unit (e.g., a
tank or container) that meets
the design and management
requirements for that type of
unit. Mark accumulation
containers with the date the
waste was placed in the unit;
mark accumulation tanks and
containers with the words
"Hazardous Waste." Do not
accumulate wastes onsite for
longer than the allowed
accumulation times
(180 days, or 270 days if
wastes must be shipped more
than 200 miles).
IMPLEMENT
PERSONNEL
TRAINING
Be sure that your personnel
are familiar with hazardous
waste handling and emer-
gency procedures.
IMPLEMENT SQG
EMERGENCY
PROCEDURES
REQUIREMENTS
Check to be sure that emer-
gency preparedness and preven-
tion requirements are met.
These include identifying an
emergency response coordinator
and notifying local emergency
response authorities. Post emer-
gency response information near
the telephone.
MOTOR FREIGHT & RAILROAD TRANSPORTATION
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REQUIREMENTS FOR REGULATED MOTOR FREIGHT & RAILROAD TRANSPORTATION FACILITIES
The following table presents an overview of the federal RCRA regulatory requirements for motor freight and railroad transportation facilities that are either LQGs,
SQGs, or CESQGs. As noted, your state might have different or more stringent requirements.
RCRA REGULATORY REQUIREMENTS
REGULATORY
REQUIREMENT
EPA Identification
Number
Hazardous Waste
Identification
Used Oil Standards
Waste Counting
Accumulation Area
LQGS SQGS CESQGS IMPLEMENTATION EXPLANATION
Other Accumulation
Areas (Time and
Quantity Limits)
Storage Unit
Requirements
Air Emissions
Preparedness and
Prevention
Obtain an EPA identification number for each facility within your company. EPA and states use this 12-character identification num-
ber to track hazardous waste activities.
Obtain an EPA identification number by submitting Form 8700-12 (Notification of Regulated Waste Activity), which is provided by
your state hazardous waste agency. This is a one-time notification. Contact your state regarding the need for renotification if cir-
cumstances at your facility change.
Identify whether you generate hazardous waste to determine if you are subject to the RCRA hazardous waste regulations. Test
procedures are described in "Test Methods for the Evaluation of Solid Waste, Physical/Chemical Methods, SW-846" or tests can
be performed by a local laboratory.
If you generate used oil, you are subject to a separate set of management standards from the hazardous waste management
standards if the used oil will be recycled. If the used oil is to be treated and disposed of, perform the hazardous waste identifica-
tion step listed above.
Determine how much hazardous waste you generate to determine your generator status.
You can accumulate waste in a "satellite accumulation area" with minimal regulatory burden. This area must be at or near the
point of generation and under the control of the operator of the process generating the waste.
There is no time limit on accumulation in the satellite accumulation area for waste under 55 gallons.
There is a 55-gallon accumulation limit in the satellite accumulation area. Excess waste beyond the 55-gallon limit must be moved
from the satellite accumulation area within 3 days.
You must accumulate the waste in containers.
Waste containers must be marked with the words "Hazardous Waste" or other words that identify their contents.
This waste is exempt from other accumulation provisions while in the satellite accumulation area.
If waste accumulation does not meet the requirements for satellite accumulation, it is subject to more stringent requirements.
LQGs can accumulate waste on site for up to 90 days without a permit. SQGs can accumulate waste for 180 days, or 270 days if
the SQG must transport the waste more than 200 miles to a destination facility.
Begin counting accumulation time when waste is first placed in the accumulation unit.
Waste must be put in an exempt unit, recycled, or sent off site within the proper time period stated above.
If an LOG accumulates wastes beyond the allotted time period, the facility is fully subject to the requirements of a hazardous waste
storage facility unless granted an exemption. SQGs cannot accumulate more than 6,000 kg of hazardous waste at any time.
CESQGs cannot accumulate more than 1,000 kg of hazardous waste, more than 1 kg of acutely hazardous waste, or 100 kg of
spill residue from acutely hazardous waste at any time.
Accumulate waste only in units that are in good condition, remain closed except when adding or removing waste, are inspected at
least weekly, are compatible with the types of waste, and meet special standards for ignitable waste and incompatible waste.
LQGs can use accumulation tanks and containers that have been assessed for integrity, have a secondary containment system,
and are inspected each operating day. SQGs can use certain accumulation tanks as well.
LQGs can use containment buildings as well.
For all units, the date that the accumulation period begins must be clearly marked and visible on each container. All containers
and tanks must be clearly marked or labeled with the words "Hazardous Waste" and accumulation units must be shut down and
closed permanently in accordance with standards at the end of the unit life.
LQGs and SQGs can treat their waste without a RCRA storage permit in accumulation units that meet standards.
LQGs must comply with organic air emissions requirements.
LQGs and SQGs must comply with preparedness and prevention requirements, including the following:
An adequate internal alarm or communications system.
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Contingency Plan
Personnel Training
DOT Packaging
Offsite Management
of Waste
Onsite Management
of Waste
Manifest
Land Disposal
Restrictions
Notification
Hazardous Waste
Minimization
Biennial Report
Recordkeeping
Adequate water pressure to operate fire control systems.
Adequate testing and maintenance of all emergency systems.
Access to communication or alarm systems during waste handling activities.
Adequate aisle space for emergency response.
An arrangement with local emergency response authorities.
LOG facilities must prepare a facility contingency plan in accordance with regulations.
The contingency plan must be designed to minimize hazards from fires, explosions, or any unplanned release of hazardous waste
or constituents.
A copy of the contingency plan must be kept on site and an additional copy must be submitted to all local emergency services
providers.
LQGs and SQGs must have an emergency coordinator on site or on call at all times to respond to emergencies.
Emergency response information must be posted next to the telephone.
In the event of a fire, explosion, or release that could threaten human health outside the facility, or when a spill has reached sur-
face water, the emergency coordinator must notify the National Response Center at 800 424-8802.
LQGs must have a personnel training program in accordance with regulatory standards.
Training must instruct facility personnel about hazardous waste management procedures and emergency response.
Training must be completed within 6 months from the applicability of requirements.
The facility must undertake an annual review of initial training.
SQGs must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures relevant to
their responsibilities.
Before being transported, waste must be packaged, labeled, and marked in accordance with applicable DOT requirements. Call
the DOT hazardous materials information line at 202 366-4488 for information.
Hazardous waste sent off site for handling may only be sent to a hazardous waste TSDF or recycling facility unless otherwise exempt.
CESQGs: See onsite management of waste below.
CESQGs may either treat waste on site, if it qualifies as one of the following types of facilities, or ensure delivery of waste to one
of the following types of facilities: permitted RCRATSDF; interim status TSDF; state-authorized to handle hazardous waste; per-
mitted, licensed, or registered by state to handle municipal solid waste according to standards; permitted, licensed, or registered
by state to handle nonmunicipal waste; if managed after January 12, 1998, facility is permitted, licensed, or registered by state to
handle nonhazardous waste in accordance with standards; facility beneficially uses or reuses, or legitimately recycles or reclaims
its waste; facility treats its waste prior to beneficial use, reuse, or legitimate recycling or reclamation; or a universal waste handler
in accordance with standards.
Hazardous waste sent off site must be accompanied by a manifest, a multipage form that documents the waste's progress
through treatment, storage, and disposal. It can usually be obtained from your state agency.
The manifest must have enough copies to provide the generator, each transporter, and the destination facility with one copy for
their records and a second copy to be returned to the generator after completion by the destination facility operator.
SQGs that have a contractual agreement with a waste reclaimer that specifies the types and frequencies of shipments do not
need to manifest the wastes if they retain a copy of the agreement in their files.
Waste must meet certain treatment standards under the Land Disposal Restrictions program when waste is land disposed. Waste
must be treated to reduce the hazardous constituents to levels set by EPA or the waste must be treated using a specified technol-
ogy. All waste sent off site for treatment, storage, and disposal must be accompanied by appropriate LDR program notifications
and certifications. There are no required forms, but these papers must indicate whether or not wastes meet treatment stan-
dards or whether the waste is excluded from the definition of hazardous or solid waste, or is otherwise exempt.
To encourage generators to produce less hazardous waste, LQGs are required to have a program in place to reduce the volume
and toxicity of waste generated to the degree economically practicable, and must select a currently available treatment, storage,
or disposal method that minimizes present and future threats.
LQGs and SQGs must sign a certification of hazardous waste minimization on the manifest.
SQGs must make a good faith effort to minimize waste generation and to select the best available waste management method
that they can afford.
LQGs must submit biennial reports of waste generation and management activity by March 1 of every even-numbered year. EPA,
other agencies, and the public use this information to track trends in hazardous waste management.
LQGs must maintain personnel training records until the facility closes.
LQGs must keep copies of each biennial report for 3 years.
LQGs and SQGs must keep a copy of each manifest for 3 years.
LQGs and SQGs must keep records of test results, waste analyses, and other hazardous waste determinations for 3 years.
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REDUCE OR MINIMIZE THE
HAZARDOUS WASTES You GENERATE
The following examples
show hazardous wastes
typically generated by
the motor freight and
railroad transportation
industry, including
shipping and leasing
companies that own
and dean tank cars,
and the tank car clean-
ing industry. The exam-
ples provide sugges-
tions for how to recycle,
treat, or dispose of haz-
ardous waste according
to federal regulations.
PROCESS
Wastes Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
Recycling and pollution prevention measures can significantly reduce your regulatory
burden and might save your facility considerable money. This section presents informa-
tion on hazardous wastes typically generated by various motor freight and railroad
transportation processes and provides suggestions for how to recycle them or imple-
ment pollution prevention measures. Some tank cleaning operations, for example, have
self-contained small parts washing systems that do not drain to the sewer. These systems might
include a solvent dispenser, wash basin, and waste solvent collection system. Hazardous waste generat-
ed by these commercial operations may be returned to the supplier who redistills the cleaning fluid
and disposes of the remaining hazardous waste. Switching to nonhazardous aqueous-based solvents
for small scale cleaning operations, however, will reduce the amount of hazardous waste you generate.
Solvent recycling can also decrease hazardous waste production from small parts cleaning.
Only the federal hazardous waste codes are provided here. Your state might have different codes for
some waste streams. You should check with your state hazardous waste authority for additional waste
codes and requirements.
Unloading and Cleaning Tank Trucks and Rail Cars
Acid or alkaline cleaners, ethyl benzene, residuals (heels) from shipment of product or haz-
ardous waste, residues from wastewater treatment, spent solvents, volatile organic emis-
sions, and wastewater.
D001 (residuals, solvent wastes), D002 (cleaners, residuals, wastewaters), F003 (ethyl ben
zene), F and K waste codes (residuals from shipment of F- and K-listed waste), and P and
U waste codes (residuals from shipment of commercial chemical products).
Reclaim solvents in an onsite distillation unit for reuse or send for reclamation.
Reuse wastewater solutions as the first rinse of highly contaminated tanks or cars.
Sell heels/residuals of commercial chemical products (CCPs) to a reclamation facility.
Use alkaline heels/residuals to neutralize acid wastes.
Use detergent CCP heels/residuals in future cleaning operations.
Treat aqueous heels/residuals and wastewaters in a wastewater treatment unit regulat-
ed by the Clean Water Act.
Package and label hazardous wastes for shipment using a hazardous waste
transporter to a hazardous waste TSDF.
Manage heels/residuals separately from each other to facilitate recycling.
Switch from washing processes using solvents or caustic solutions to steam cleaning
methods, nonhazardous detergents, or aqueous solvents.
Install a closed washing and rinsing system to recycle wastewaters, reduce water
usage, and limit volatile organic air emissions.
Use suction or vacuum pumps and squeegee the walls of tanks or cars to remove
heels/residuals more efficiently and reduce contamination of wastewaters.
Wash trucks or rail cars more frequently to prevent residue accumulation that could
make wash waters hazardous.
10
RCRA IN FOCUS
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PROCESS
Wastes Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
PROCESS
Wastes Generated
Possible RCRA
Waste Codes
Minimize the amount of water used in washing operations.
Keep solvent containers covered to prevent product volatilization.
Use a first in, first out policy in storage areas and computerize inventory control to pre-
vent materials from expiring.
Degreasing, Parts Washing, Rust Removal
Ammonium hydroxide, benzene, chromic acid, hydrobromic acid, hydrochloric acid, hydrofluo-
ric acid, methylene chloride, mineral spirits, nitric acid, oil or grease, petroleum distillates,
phosphoric acid, potassium hydroxide, rags containing solvents or grease, sodium hydroxide,
sulfuric acid, toluene, toxic metals, volatile organic constituents, wastewaters, and sludges.
D001 (benzene, methylene chloride, mineral spirits, oil or grease, petroleum distillates,
toluene, used rags), D002 (ammonium hydroxide, chromic acid, hydrobromic acid,
hydrochloric acid, hydrofluoric acid, nitric acid, phosphoric acid, potassium hydroxide, sodi-
um hydroxide, sulfuric acid, wastewaters), D007 (wastewaters, rags, contaminated sol-
vents), D008 (contaminated solvents, rags, wastewaters), D018 (contaminated solvents,
wastewaters), F001 or F002 (methylene chloride), and F005 (benzene, toluene).
• Reclaim solvents in an onsite distillation unit for reuse or contract to have the solvents
shipped off site for recycling.
• Contact state or regional EPA office to determine the status of rags in your state.
• Treat wastewaters in a wastewater treatment unit regulated by the Clean Water Act.
• Package and label hazardous wastes for shipment using a hazardous waste
transporter to a hazardous waste TSDF.
• Replace solvent- and caustic-using parts washers with ultrasonic part washing systems,
bake-off ovens, or detergent baths.
• Substitute aqueous solutions for organic solvents.
• Keep vehicles in good repair to prevent oil leaks.
• Install drip racks over solvent sinks and increase drip time to reduce air emissions.
• Apply solvents with a method other than spraying to avoid air emissions.
• Close solvent containers and keep solvent sinks covered to prevent product volatilization.
• Use dry precleaning methods such as wire brushing.
• Use contaminated washing solutions as prerinse for dirty parts.
Alcohols, methyl ethyl ketone, methyl isobutyl ketone, methylene chloride, mineral spirits,
paint pigments, petroleum distillates, volatile organic compounds, wastewater, and xylene.
D001 (alcohols, methyl ethyl ketone, methyl isobutyl ketone, methylene chloride, mineral
spirits, petroleum distillates, xylene), D007 (pigments), D008 (pigments), D035 (methyl ethyl
MOTOR FREIGHT & RAILROAD TRANSPORTATION
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Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
PROCESS
Wastes Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
ketone), F001 or F002 (methylene chloride), F003 (methyl isobutyl ketone, xylene), and
F005 (methyl ethyl ketone, toluene).
• Reclaim solvents in an onsite distillation unit for reuse or send for reclamation.
• Treat wastewaters in a wastewater treatment unit regulated by the Clean Water Act.
• Dispose of paint sludges and cleaning wastes from paint stripping operations properly if
hazardous solvents or other hazardous stripping materials are used.
• Package and label hazardous wastes for shipment using a hazardous waste transporter
to a hazardous waste TSDF.
• Prepare smaller test batches of coatings.
• Use tarps or cloths to prevent paint mists from contaminating air, water, or soil when
painting outside.
• Do not allow paint or paint wastes into your facility's drainage system, unless the system
is designed and permitted to treat such wastes.
• Switch from hazardous organic-based paints to aqueous-based paints.
• Use all of the paint in a container. Use leftovers as undercoatings or primers.
• Replace finishes needing solvents with less hazardous products, such as water-borne coatings.
• Install biofiltration systems to filter exhaust from spray areas.
• Provide training for spray gun operators in overspray-reduction techniques.
• Install high-volume, low-pressure, or electrostatic sprayers to decrease overspray.
• Replace solvent-based stripping with mechanical methods such as plastic blast media systems.
• Cover solvent containers to prevent product volatilization.
• Clean spray guns and equipment frequently for efficient paint transfer.
• Use solvent-based coatings with high levels of solids to reduce air emissions.
• Purchase paint in recyclable or returnable containers to reduce disposal costs.
• Contact a waste exchange program.
• Follow label directions for shelf-life and storage conditions to avoid having to dispose of
unused product.
Spray Gun, Spray Booth, and Brush Cleaning
Acetone, alcohols, isopropanol, methanol, methyl ethyl ketone, methyl isobutyl ketone, meth-
ylene chloride, mineral spirits, paint pigments, petroleum distillates, toluene, and volatile
organic constituents.
D001 (acetone, alcohols, isopropanol, methanol, methyl ethyl ketone, methyl isobutyl ketone,
methylene chloride, mineral spirits, petroleum distillates, toluene), D007 (pigments), D008
(pigments), D035 (methyl ethyl ketone), F001 or F002 (methylene chloride), F003 (acetone,
methanol, methyl isobutyl ketone), and F005 (methyl ethyl ketone, toluene).
• Reuse cleanup solvent until it is spent, then recycle on site or send out for reclamation.
• Collect paint containers and residues for recycling.
• Package and label hazardous wastes for shipment using a hazardous waste transporter
to a hazardous waste TSDF.
12
RCRA IN FOCUS
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Potential Pollution
Prevention Methods
PROCESS
Wastes Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
PROCESS
Wastes Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
Spray paint in large batches to reduce the number of times the gun must be cleaned.
To minimize spills, clean spray guns by immersing only the front end in solvent.
Clean spray guns by passing solvent through gun and into a container, rather than
spraying cleaning solvent into the air.
Cover solvent containers to prevent product volatilization.
Filter spray booths using washable metal filters instead of disposable filters.
Wash spray booth filters for reuse.
Catch overspray in a trough for collection and distillation rather than using disposable
absorbent material.
Use a first in, first out policy in storage areas and computerize inventory control to
prevent materials from expiring.
Parts Replacement
Batteries (lead acid, nickel cadmium, nickel, iron, carbonaite), scrap metal, and used tires.
D002 (battery acid), D006 (cadmium), and D008 (lead).
Sell scrap metal to a recycling facility.
Collect batteries for reclamation.
Have scrap tires retreaded or send for recycling.
Recycle batteries on site, through the supplier, or at a local recycling facility.
Package and label hazardous wastes for shipment using a hazardous waste transporter
to a hazardous waste TSDF.
To facilitate battery recycling, sort and label batteries, store in a manner that protects the
batteries and prevents leaks, and inspect for leaking batteries.
Protect batteries from the weather with tarp, roof, or other means.
Store batteries in an open rack or water-tight secondary containment unit to prevent leaks.
Neutralize acid spills and dispose of resulting waste as hazardous waste if it still exhibits
a characteristic of hazardous waste.
Use longer-life batteries.
Store scrap metal under cover to prevent run-off of oil and grease during outdoor storage.
Rebuild scrap parts for reuse.
Maintenance and Fluid Replacement
Fluids contaminated with heavy metals, radiator flushing solutions, used oil, and used oil filters.
D002 (flushing solution), D008 (contaminated fluids), and D018 (contaminated fluids).
Drain oil filters carefully and collect and dispose of the oil properly.
Manage used oils that have been mixed with listed hazardous waste as a hazardous waste.
Reuse radiator flushing fluid.
MOTOR FREIGHT & RAILROAD TRANSPORTATION
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Potential Pollution
Prevention Methods
PROCESS
Wastes Generated
Possible RCRA
Waste Codes
Potential Recycling,
Treatment, and
Disposal Methods
Potential Pollution
Prevention Methods
Collect used oil and automotive fluids for recycling.
Package and label hazardous wastes for shipment using a hazardous waste transporter
to a hazardous waste TSDF.
Avoid mixing used oil with hazardous waste or material that would prevent recycling of the oil.
Use a drip pan when dealing with used oil.
Transfer drip pan contents to containers as soon as practical to prevent air emissions
and spills.
Avoid allowing used oil or oil drips to enter your drainage system unless an oil-water
separation system is in place or specific arrangements have been made with the local
sewer utility.
Use absorbent materials (e.g., pigmat) to catch drips or spills during activities where oil
drips might occur.
Use track pans, absorbent materials, or other collection devices under an idling locomotive.
Label and cover all drums or containers with used oil or oil filters that are exposed to
storm water.
Discharge coolant when the locomotive has stopped and is at a location where the coolant
can be collected and managed, when possible, to minimize contamination of soil and water.
Avoid discharging coolant when locomotive is crossing open water or traveling adjacent
to open water, to minimize aesthetic degradation of water.
Switch to a radiator fluid that is amenable to recycling.
Avoid mixing locomotive coolant with antifreeze that will be recycled.
Use brake fluid, transmission fluid, and other fluids that do not contain chlorinated hydrocarbons.
Use a first in, first out policy in storage areas and computerize inventory control to pre-
vent materials from expiring.
Storage of Cleaning Chemicals
Acetone, hydrofluoric acid, methanol, methylene chloride, methyl ethyl ketone, methyl
isobutyl ketone, mineral spirits, toluene, and xylene.
D001 (acetone, methanol, methylene chloride, methyl ethyl ketone, methyl isobutyl ketone, min-
eral spirits, toluene, xylene), U002 (unused acetone), U080 (unused methylene chloride), U134
(unused hydrofluoric acid), U154 (unused methanol), U159 (unused methyl ethyl ketone), U161
(unused methyl isobutyl ketone), U220 (unused toluene), and U239 (unused xylene).
• Collect spilled or off-specification commercial chemical products for reclamation.
• Package and label hazardous wastes for shipment using a hazardous waste transporter
to a hazardous waste TSDF.
Install curbs around hazardous product storage areas to contain leaks.
Minimize storage quantities.
Inspect storage areas to catch leaks while manageable.
Use a first in, first out policy in storage areas and computerize inventory control to
prevent materials from expiring.
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RCRA IN FOCUS
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OTHER ENVIRONMENTAL LAWS
AFFECTING THE MOTOR FREIGHT &
RAILROAD TRANSPORTATION INDUSTRY
THE CLEAN WATER ACT
The Water Pollution Control Act, commonly known as the Clean Water Act (CWA), is the federal
program designed to restore and maintain the integrity of the nation's surface waters. CWA controls
direct discharges to surface waters (e.g., through a pipe) from industrial processes or stormwater sys-
tems associated with an industrial activity. It also regulates indirect discharges, or discharges to
POTWs, through a public sewer system, by requiring industrial facilities to pretreat their waste
before discharging to a public sewer. Industrial pollutants from the motor freight and railroad trans-
portation industry that might be regulated by CWA include solvents. For parts cleaning, for instance,
if washing stations drain to local sewers or oil-water separator systems, any hazardous wastes used or
generated during parts washing that go down the drain may need to be permitted under CWA While
most railroad wastewater treatment systems are designed to remove oils from wastewater, other haz-
ardous materials (e.g., solvents) might not be removed in the process. As a result, many POTWs have
requirements, called pretreatment standards, in place. These standards govern the types and amounts of
hazardous wastes you are allowed to discharge to the sewers.
CWA Resources:
• 40 CFR Parts 100 to 129 and 400 to 503
• Internet access: www.epa.gov/OW/
• EPA Office of Water: 202 260-5700
• Your state water authority, regional EPA office, and local POTW
Oil Pollution Prevention Under the CWA
The Oil Pollution Prevention regulations were promulgated under the authority of the CWA.
These regulations establish requirements for facilities to prevent oil spills from reaching the naviga-
ble waters of the United States or adjoining shorelines. The regulations apply to non-transportation-
related facilities with a specific aboveground or underground oil storage capacity that, because of their
location, can reasonably be expected to discharge oil into the navigable waters of the United States.
Oil Pollution Prevention Regulation Resources:
• 40 CFR Part 112
• Internet access: www.epa.gov/
THE CLEAN AIR ACT
The Clean Air Act (CAA) regulates air pollution. It includes national emission standards for new
stationary sources within particular industrial categories. It also includes national emission standards,
which are designed to control the emissions of particular hazardous air pollutants (HAPs). Motor
freight and railroad transportation facilities generate some HAPs such as volatile organic compounds
in organic solvents and paints. The use of volatile solvents in small parts cleaning may require CAA
permitting in some poor air quality regions. Also, CAA permits may be required for discharge of
process air associated with certain large-scale painting operations. The CAA also seeks to prevent the
accidental release of certain hazardous chemicals and to minimize the consequences of such releases.
CAA Resources:
• 40 CFR Parts 50 to 99
• Control Technology Center, Office of Air Quality, Planning and Standards, EPA, general infor-
mation: 919 541-0800; publications: 919 541-2777
• Internet access: www.epa.gov/ttn/catc
COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND
LIABILITY ACT (CERCLA OR SUPERFUND)
The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of
1980, commonly known as Superfund, authorizes EPA to respond to releases, or threatened
CFR GUIDE TO
HAZARDOUS
WASTE
REGULATIONS
To review the
RCRA regulations
referred to in this docu-
ment, consult the fol-
lowing citations in 40
CFR:
Part 260—Hazardous
waste management sys-
tem: general.
Part 261—Identification
and listing of hazardous
waste.
Part 262—Standards
applicable to generators
of hazardous waste.
Part 263—Standards
applicable to transporters
of hazardous waste.
Part 264—Standards for
owners and operators of
hazardous waste and
specific types of haz-
ardous waste manage-
ment facilities.
Part 265—Interim status
standards for owners and
operators of TSDFs.
Part 266—Standards for
the management of spe-
cific hazardous wastes
and specific types of
hazardous waste man-
agement facilities.
continued
MOTOR FREIGHT & RAILROAD TRANSPORTATION
15
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CFR GUIDE
continued
Part 268—Land disposal
restrictions.
Part 270—EPA adminis-
tered permit programs: the
Hazardous Waste Permit
Program.
Part 271—Requirements
for authorization of state
hazardous waste programs.
Part 272—Approved state
hazardous waste manage-
ment programs.
Part 273—Standards for
universal waste manage-
ment.
Part 279—Standards for the
management of used oil.
FOR MORE
INFORMATION
For additional informa-
tion on any of these
laws, contact the RCRA
Hotline at
800 424-9346 or
703 412-9810 in the
Washington, DC, area.
TDD (hearing impaired):
800 553-7672 or 703 412-
3323 in the Washington,
DC, area.
releases, of hazardous substances that might endanger public health, welfare, or the environment,
that might come from any source. Superfund also grants EPA the authority to force parties responsi-
ble for environmental contamination to clean it up or to reimburse response costs incurred by EPA.
The most important part of this act applicable to motor freight and railroad transportation facili-
ties is the hazardous substance release reporting requirement. The person in charge at your business
must report to the National Response Center (phone: 800 424-8802) any release of a hazardous
substance that exceeds a designated "reportable quantity" for that substance within a 24-hour period.
Superfund Resource:
• Internet access: www.epa.gov/superfund
THE EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT
The Superfund Amendments and Reauthorization Act (SARA) of 1986 created the Emergency
Planning and Community Right-to-Know Act (EPCRA). This law was designed to improve com-
munity access to information about potential chemical hazards and to facilitate the development of
chemical emergency response plans by state and local governments. The EPCRA regulations estab-
lish several types of reporting obligations for facilities that store or manage specified chemicals such
as hydrofluoric acid and methylene chloride in the motor freight and railroad transportation indus-
try. Also, many of the chemicals used by motor freight and railroad transportation facilities, such as
solvents and pigments, may be considered hazardous chemicals as defined by the Occupational
Safety and Health Act (OSHA). Contact your local OSHA office if you have questions about
whether the chemicals used in your motor freight and railroad transportation business are consid-
ered hazardous under OSHA.
EPCRA Resources:
• 40 CFR Parts 350 to 372
• The State Emergency Response Commission (contact available from RCRA Hotline)
• Internet access: www.epa.gov/opptintr/tri/index.htm and www.epa.gov/swercepp/
SAFE DRINKING WATER ACT
The Safe Drinking Water Act (SDWA) mandates that EPA establish regulations to protect human
health from contaminants present in drinking water. Under the authority of SDWA, EPA developed
national drinking water standards and created a joint federal-state system to ensure compliance with
these standards. EPA also regulates underground injection of liquid wastes under the SDWA to pro-
tect underground sources of drinking water.
SDWA Resources:
• 40 CFR Parts 141 to 148
• SDWA Hotline: 800 426-4791
• Internet access: www.epa.gov/ogwdw
TOXIC SUBSTANCES CONTROL ACT
The Toxic Substances Control Act (TSCA) allows EPA to collect data on chemicals to evaluate,
assess, mitigate, and control risks that might be posed by their manufacture, processing, and use.
Motor freight terminals and railroad transportation sites may be affected by some of the TSCA
requirements. Electrical equipment, such as transformers, capacitors, and lighting ballasts, for example,
that were manufactured before 1978 generally have insulating fluids that contain polychlorinated
byphenyls (PCBs). PCBs are suspected carcinogens and are regulated under TSCA. PCB containing
equipment must be properly managed to prevent PCB releases to the environment.
TSCA Resources:
• 40 CFR Parts 702 to 799
• TSCA Hotline: 202 554-1404
• Internet access: www.epa.gov/internet/oppts/
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RCRA IN FOCUS
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CONTACTS AND RESOURCES
HOTLINES AND
INFORMATION CENTERS
RCRA Hotline
U.S. Environmental Protection Agency
Phone:800424-9346
or TDD 800 553-7672
In the Washington, DC, area:
703 412-9810, or TDD 703 412-3323
Home page: www.epa.gov/epaoswer/
hotline
Answers questions on matters related to
RCRA solid waste, hazardous waste, and
underground storage tanks, EPCRA, and
CERCLA.
RCRA Information Center
U.S. Environmental Protection Agency
RCRA Information Center (5305W)
401 M Street, SW.
Washington, DC 20460
Phone: 703 603-9230
Fax: 703 603-9234
E-mail: rcra-docket@epa.gov
Holds and provides public access to all regula-
tory materials on RCRA and distributes tech-
nical and nontechnical information on RCRA
issues.
Small Business Ombudsman
Clearinghouse/Hotline
U.S. Environmental Protection Agency
Small Business Ombudsman (2131)
401 M Street, SW
Washington, DC 20460
Phone:800368-5888
Fax: 703 305-6462
Home page: www.smallbiz-enviroweb.org
Helps private citizens, small businesses, and
smaller communities with questions on all
program aspects within EPA.
EPA Headquarters Library
U.S. Environmental Protection Agency
Headquarters Library
401 M Street, SW, Room 2904
Washington, DC 20460
Phone: 202 260-5921 or 5922
Fax: 202 260-6257
E-mail: library-HQ@epa.gov
Home page: www.epa.gov/
natlibra/liblists.html
Maintains environmental reference materials
for EPA staff and the general public, including
books, journals, abstracts, newsletters, and
audiovisual materials generated by government
agencies and the private sector. Also provides
access to online computer service bulletin
boards and CD-ROM systems.
Pollution Prevention
Information Clearinghouse
(PPIC)
U. S. Environmental Protection Agency
Pollution Prevention Clearinghouse (PPIC)
401 M Street, SW (7409)
Washington, DC 20460
Phone: 202 260-1023
Fax: 202 260-4659
E-mail: ppic@epa.gov
Transportation Assistance
Compliance Center
U. S. Environmental Protection Agency
Office of Enforcement and Compliance
Assurance (OECA)
401 M Street, SW
Washington, DC 20460
Phone: 202 564-2405
Fax: 202 264-0050
Home page:
Provides assistance in complying with environ-
mental regulations to the transportation industry.
U.S. Department of
Transportation
Hazardous Materials Information Center
Phone: 800 467-4922
Provides information about DOT's hazardous
materials regulations.
U.S. Government Printing
Office
Superintendent of Documents
P.O. Box 371954
Pittsburgh, PA 15250-7954
Phone: 202 512-1800
Fax: 202 512-2250
Prints and distributes the Code of Federal
Regulations. Title 40, Parts 260 to 299, contains
most of the RCRA requirements.
ADDITIONAL INTERNET
ADDRESSES
EPA Home Page
www.epa.gov
EPA RCRA Hazardous Waste Resources
www.epa.gov/osw/topics.htm
Code of Federal Regulations
www.epa.gov/docs/epacfr40/
Envirosense
es.inel.gov
Contains technical, policy, and general infor-
mation on pollution prevention topics.
EPA's Transportation Team Home Page
es.epa.gov/oeca/medt/transp.html
Provides information including industry sector
notebooks, for the transportation industry.
ADDITIONAL RESOURCES
Environmental Compliance Handbook for Short
Line Railroads (forthcoming) is a plain-English
guide to short line environmental responsibili-
ties for freight and rail companies. Published
by the U.S. Environmental Protection Agency
and the Federal Railroad Administration.
Check the OECA home page for availability at
.
MOTOR FREIGHT & RAILROAD TRANSPORTATION
17
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