aste
A Guide for Small Businesses
United States
Solid Waste and
Emergency Response December 200

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CONTENTS

  1  INTRODUCTION
  2  DECIDING WHETHER HAZARDOUS WASTE REGULATIONS APPLY TO YOU
  2  Defining Hazardous Waste
  3  Identifying Your Waste
  3  Finding Your Generator Category

  7  OVERVIEW OF REQUIREMENTS FOR CONDITIONALLY EXEMPT SMALL QUANTITY GENERATORS
  8  OBTAINING AN EPA IDENTIFICATION NUMBER
 11  MANAGING HAZARDOUS WASTE ON SITE
 11     Accumulating Your Waste
 13     Treating Your Waste To Meet the Land Disposal Restrictions
 13     Preventing Accidents
 14     Responding to Emergencies
 16  SHIPPING WASTE OFF SITE
 16     Selecting a Treatment, Storage, and Disposal Facility
 16     Labeling Waste Shipments
 17     Preparing Hazardous Waste Manifests
 17     Land Disposal Restrictions (LDR) Reporting Requirements
 18     Export Notification
 18     Closure

 21  SUMMARY OF REQUIREMENTS FOR LARGE QUANTITY GENERATORS
 22  WHERE TO GET MORE HELP
 22  EPA and Other Federal Resource Centers
 24  EPA Regional Offices
 26  ACRONYMS AND DEFINITIONS

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INTRODUCTION

    Does your business generate
    hazardous waste? Many small
businesses do. If you need help
understanding which federal haz-
ardous waste management regula-
tions apply to your business, this
handbook is for you. It has been
prepared by the U.S. Environmen-
tal Protection Agency (EPA) to help
small-business owners and opera-
tors understand how best to com-
ply with federal hazardous waste
management regulations.
This handbook provides an
overview of the regulations to give
you a basic understanding of your
responsibilities. It should not be
used as a substitute for the actual
requirements. All of the federal
hazardous waste  regulations are
located in Title 40 of the Code of
Federal Regulations (CFR), Parts
260 to 299 (www.epa.gov/
epacfr40).
EPA defines three categories of
hazardous waste generators based
upon the quantity of hazardous
waste they generate per month:
(1)  Conditionally exempt small
    quantity generators (CESQGs),
    which generate less than 220
    Ibs (100 kg) per month.
(2)  Small quantity generators
    (SQGs), which generate
    between 220 Ibs (100 kg) and
    2,200 Ibs (1,000 kg) per
    month.
(3)  Large quantity generators
    (LQGs), which generate more
    than 2,200 Ibs (1,000  kg) per
    month.
Each category of generator must
comply with the hazardous waste
rules specific to that category. This
handbook is intended primarily for
businesses that generate a  small
quantity of hazardous waste (SQGs
and CESQGs) to help them learn
about regulations that apply to
them.
This handbook explains only the
federal requirements for hazardous
waste management. Many states
have their own hazardous waste
regulations based on the federal
        You can look up unfamiliar
        words, phrases, or
     acronyms in the list of defini-
     tions found on page 26.
hazardous waste regulations. In
some of these states, the require-
ments are the same as the federal
standards and definitions. Other
states, however, have developed
more stringent requirements than
the federal program. If this is the
case in your state, you must com-
ply with the state regulations. To
become familiar with your state's
requirements, consult your state
hazardous waste agency. For the
address or phone number for your
state agency, contact the RCRA
Call Center at 800 424-9346 or
TDD 800 553-7672.
                              FOR MORE INFORMATION
  *"****«,»».
   HA^AJ
  I  I
                                                                If you have questions about any part of this
                                                          '     book, or the federal hazardous waste regula-
                                                               tions, contact the RCRA Call Center at
                                                              703 412-9810 or TDD 703 412-3323 in the
                                                              Washington, DC, area or at 800 424-9346 or
                                                             TDD 800 533-7672 from other locations, or
                                                             .

                                                            The Call Center provides free technical assis-
                                                           tance. Any information you share will not be
                                                                                                     1
                                                           used for any other purpose.

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DECIDING WHETHER  HAZARDOUS WASTE
REGULATIONS  APPLY TO YOU
Federal hazardous waste
management regulations
apply to most businesses
that generate  hazardous
waste. To determine if
these regulations apply to
your  business, you must
first determine if you even
generate hazardous
waste.

Defining Hazardous Waste
A   waste is any solid, liquid, or con-
   tained gaseous material that is
discarded by being disposed of,
burned or incinerated, or recycled.
(There are some exceptions for recy-
cled materials.) It can be the by-
product of a manufacturing process
or simply a commercial product that
you use in your business—such as
a cleaning fluid or battery acid—and
that is being disposed of. Even
materials that are recyclable or can
be reused in some way (such as
burning solvents for fuel) might be
considered waste.
Hazardous waste can be one of
two types:
» Listed waste. Your waste is
    considered hazardous if it
    appears on one of four lists
    published in the Code of
    Federal Regulations (40 CFR
    Part 261). Currently, more
    than  500 wastes are listed.
    Wastes are listed as haz-
    ardous  because they are
    known to be harmful to human
    health and the environment
    when not managed properly.
    Even when managed properly,
    some listed wastes are so
    dangerous that they are called
    acutely hazardous wastes.
    Examples of acutely haz-
    ardous  wastes include wastes
    generated from some pesti-
    cides and that can be fatal to
    humans even in low doses.
» Characteristic wastes. If your
    waste does not appear on
    one of the hazardous waste
    lists, it  still might be
    considered hazardous if it
                     Determine if you generate hazardous waste
                    in the first place.
                   Measure the amount of hazardous waste that
                   you produce per month.
                  Determine your generator category to learn the
                 management requirements that apply to you.
    demonstrates one or more of
    the following characteristics:
    ^ It catches fire under certain
      conditions. This is known as
      an ignitable waste. Examples
      are paints and certain
      degreasers and solvents.
    ^•It corrodes metals or has  a
      very high or low pH. This is
      known as a corrosive waste.
      Examples are rust removers,
      acid or alkaline cleaning flu-
      ids, and battery acid.
    ^•It is unstable and explodes
      or produces toxic fumes,
      gases, and vapors when
      mixed with water or under
      other conditions such as
      heat or pressure. This is
      known as a reactive waste.
      Examples are certain
      cyanides or sulfide-bearing
      wastes.
    ^. It is harmful or fatal when
      ingested or absorbed, or it
      leaches toxic chemicals into
      the soil or ground water when
      disposed of on land. This is
      known as a toxic waste.
      Examples are wastes that
      contain high concentrations
      of heavy metals, such as cad-
      mium, lead, or mercury.
You can determine if your waste  is
toxic by having it tested using the
Toxicity Characteristic Leaching

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     One way to help determine if your waste exhibits any of the
     characteristics listed on page 2 is to check the Material
  Safety Data Sheet (MSDS) that comes with all products containing
  hazardous materials (www.msdsonline.com for information). In
  addition, your national trade association or its local chapter might
  be able to help you.
Procedure (TCLP), or by simply
knowing that your waste is haz-
ardous or that your processes gen-
erate hazardous waste. For more
information about the TCLP and
other test methods, contact the
RCRA Call Center or the Methods
Information Communication
Exchange (MICE) at 703 676-4690
or .

Identifying Your Waste
   To help you identify some of the
   waste streams common to your
business, consult the table on
page 4 to find a list of typical haz-
ardous wastes generated by small
businesses. Use the insert in the
middle  of this handbook for a
more detailed listing of the EPA
waste codes associated with these
waste streams to determine if your
waste is hazardous. Commercial
chemical products that are discard-
ed might also become hazardous
waste.  For a complete listing of
hazardous waste codes, see 40
CFR Part 261.
If your waste is hazardous, you will
need to manage it according to
appropriate federal regulations.

Finding Your Generator
Category
0
nee you know that you gener-
ate hazardous waste, you
need to measure the amount of
waste you produce per month. The
amount of hazardous waste you
generate determines your genera-
tor category.
Many hazardous wastes are liquids
and are measured in gallons—not
pounds. In order to measure your
liquid wastes, you will need to con-
vert from gallons to pounds.  To do
this, you must know the density of
the liquid. A rough guide is that 30
gallons (about half of a 55-gallon
drum) of waste with a density simi-
lar to water weighs about 220
pounds (100 kg); 300 gallons of a
waste with a density similar to
water weighs about 2,200 Ibs
(1,000 kg).
EPA has established three genera-
tor categories, as follows, each of
which  is regulated differently:
CESQGs:
Conditionally Exempt Small
Quantity Generators: You are con-
sidered a CESQG if you generate
less than 220 Ibs (100 kg) per
month  of hazardous waste. You
are exempt from hazardous waste
management  regulations provided
that you comply with the  basic
requirements  described on page 6.
If you  are a CESQG and you gener-
ate no more than 2.2 Ibs (1  kg) of
acutely hazardous waste (or 220
                                                                  Ibs (100 kg) of acutely hazardous
                                                                  waste spill residues) in a calendar
                                                                  month, and never store more than
                                                                  that amount for any period of time,
                                                                  you may manage the acutely haz-
                                                                  ardous waste according to the
                                                                  CESQG  requirements. If you gener-
                                                                  ate or store more than 2.2 Ibs
                                                                  (1kg) of acutely hazardous waste
                                                                  on site, you must manage  it
                                                                  according to the  LQG requirements
                                                                  (see below).
                                                                  SQGs:
                                                                  Small Quantity Generators: You
                                                                  are considered an SQG if you gen-
                                                                  erate between 220 and 2,200 Ibs
                                                                  (100 and 1,000  kg) per month of
                                                                  hazardous waste. SQGs must com-
                                                                  ply with EPA requirements for man-
                                                                  aging hazardous  waste described
                                                                  in this document.
                                                                  LQGs:
                                                                  Large Quantity Generators: You
                                                                  are considered an LQG  if you gen-
                                                                  erate more than  2,200  Ibs (1,000
                                                                  kg) per month of hazardous waste.
                                                                  LQGs must comply with more
                                                                  extensive hazardous waste rules
                                                                  than those summarized in this
                                                                  handbook. See page 21 for an
                                                                  overview.

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TYPICAL HAZARDOUS WASTE GENERATED BY SMALL  BUSINESSES
TYPE OF BUSINESS   HOW GENERATED
                                                      TYPICAL WASTES
                                                                                       WASTE CODES
Drycleaning and     Commercial drycleaning              Still residues from solvent distilla-    D001, D039, F002, F005, U210
Laundry Plants      processes                          tion, spent filter cartridges, cooked
                                                      powder residue, spent solvents,
                                                      unused perchloroethylene

Furniture/Wood      Wood cleaning and wax removal,       Ignitable wastes, toxic wastes,       D001, F001-F005
Manufacturing and   refinishing/stripping, staining, paint-    solvent wastes, paint wastes
Refinishing         ing, finishing, brush cleaning and
                   spray brush cleaning

Construction        Paint preparation and painting, car-    Ignitable wastes, toxic wastes,       D001, D002, F001-F005
                   pentry and floor work, other special-    solvent wastes, paint wastes, used
                   ty contracting activities, heavy         oil, acids/bases
                   construction, wrecking and demoli-
                   tion, vehicle and equipment mainte-
                   nance for construction activities

Laboratories        Diagnostic and other laboratory       Spent solvents, unused reagents,    D001, D002, D003, F001-F005, U211
                   testing                             reaction products, testing samples,
                                                      contaminated materials


Vehicle             Degreasing, rust removal, paint       Acids/bases, solvents, ignitable      D001, D002, D006, D007, D008,
Maintenance        preparation, spray booth, spray        wastes, toxic wastes, paint wastes,   D035, F001-F005, U002, U080, U134,
                   guns, brush cleaning, paint removal,    batteries, used oil, unused  cleaning  U154, U159, U161, U220, U228,
                   tank cleanout, installing lead-acid      chemicals                         U239
                   batteries, oil and fluid replacement

Printing and Allied    Plate preparation, stencil prepara-      Acids/bases, heavy metal wastes,    D002, D006, D008, D011, D019,
Industries           tion for screen printing, photopro-      solvents, toxic wastes, ink,  unused   D035, D039, D040, D043, F001-F005,
                   cessing, printing, cleanup             chemicals                         U002, U019, U043, U055, U056,
                                                                                       U069, U080, U112, U122, U154,
                                                                                       U159, U161, U210, U211, U220,
                                                                                       U223, U226, U228, U239, U259,
                                                                                       U359
Equipment Repair
Degreasing, equipment cleaning,
rust removal, paint preparation,
painting, paint removal, spray booth,
spray guns, and brush cleaning.
Acids/bases, toxic wastes,
ignitable wastes, paint wastes,
solvents
D001, D002, D006, D008, F001-F005
Pesticide End-
Users/Application
Services
Pesticide application and cleanup
Used/unused pesticides, solvent
wastes, ignitable wastes, contami-
nated soil (from spills), contaminat-
ed rinsewater, empty containers
D001, F001-F005, U129, U136, P094,
P123
Educational and
Vocational Shops
Automobile engine and body repair,
metalworking, graphic arts-plate
preparation, woodworking
Ignitable wastes, solvent wastes,
acids/bases, paint wastes
D001, D002, F001-F005
Photo Processing
Processing and developing nega-
tives/prints, stabilization system
cleaning
Acid regenerants, cleaners,
ignitable wastes, silver
D001, D002, D007, D011
Leather
Manufacturing
Hair removal, bating, soaking,
tanning, buffing, and dyeing
Acids/bases, ignitables wastes,
toxic wastes, solvent wastes,
unused chemicals
D001, D002, D003, D007, D035,
F001-F005, U159, U228, U220

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                                                                   In many cases, small businesses that fall
                                                                   into different generator categories at
                                                                  different times choose to satisfy the more
                                                                  stringent requirements to simplify
                                                                  compliance.
UNIVERSAL WASTES
   The Universal Waste Rule was written to streamline envi-
   ronmental regulations for wastes generated by large
numbers of businesses in relatively small quantities. It is
designed to reduce the amount of hazardous waste dis-
posed of in municipal solid waste, encourage the recycling
and proper disposal of certain common hazardous wastes,
and reduce the regulatory burden for businesses that gen-
erate these wastes.

Universal wastes are items commonly thrown into the
trash by households and small businesses. Although han-
dlers of universal wastes can meet less stringent stan-
dards for storing, transporting, and collecting these
wastes, handlers must still comply with the full hazardous
waste requirements for final recycling, treatment, or dis-
posal. By providing a waste management structure that
removes these wastes from municipal landfills and inciner-
ators, this  rule ensures stronger safeguards for public
health and the environment.

Universal wastes include:

^>-  Batteries, such as nickel-cadmium (Ni-Cd) and small
     sealed lead-acid batteries, which are found in many
     common items, including electronic equipment, cell
     phones, portable computers, and emergency backup
     lighting.
^>- Agricultural pesticides that have been recalled or
    banned from use, are obsolete, have become dam-
    aged, or are no longer needed due to changes in
    cropping patterns or other factors. They often are
    stored for long periods of time  in sheds or barns.

^>- Thermostats, which can contain as much as 3 grams
    of liquid mercury and are located in almost any build-
    ing, including commercial, industrial, agricultural, com-
    munity, and household buildings.

^>- Lamps, which typically contain mercury and some-
    times lead, and are found in businesses and house-
    holds. Examples  include fluorescent, high-intensity
    discharge  (HID), neon, mercury vapor, high-pressure
    sodium, and metal halide lamps.

Materials are continually added to the Universal Waste list;
check 
for the latest information.

The Universal Waste Rule also encourages communities
and businesses to establish collection programs or partici-
pate in manufacturer take-back programs required by a
number of states. Many large manufacturers and trade
associations are already planning national and regional col-
lection programs for their universal waste products.

For more information, see 40 CFR Part 273.
                                                           IS
                                                  Depending on your type of business, you might be regulated
                                                 under different rules  at different times. If, for example, you gen-
                                                 erate less than 220 Ibs (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 man-
                                               agement requirements for CESQGs. If, in July, you generate
                                               between 220 and 2,200 Ibs (100 kg to 1,000 kg) of hazardous
                                              waste, your generator status would change, and you would be
                                              considered an SQG for July. Your July waste would then be subject
                                              to the management requirements for SQGs. If you mix the wastes
                                             generated during June and July, the entire mixture would be subject
                                             to the more stringent SQG standards.

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WHAT DO YOU  MEASURE TO DETERMINE YOUR GENERATOR CATEGORY?
DO Measure:
All quantities of listed and char-
acteristic hazardous wastes that
are:
» Accumulated on the property
    for any period of time before
    disposal or recycling.
    (Drycleaners, for example,
    must count any residue
    removed from machines,
    as well as spent cartridge
    filters.)
» Packaged  and transported
    away from your business.
» Placed directly in a regulated
    treatment or disposal unit at
    your place of business.
» Generated as still bottoms
    or sludges and removed
    from product storage tanks.
DO NOT Measure:
Wastes that:
» Are specifically exempted
    from counting. Examples
    include lead-acid batteries
    that will be reclaimed, scrap
    metal that will be recycled,
    used oil managed under the
    used oil provisions of 40
    CFR 279, and universal
    wastes (e.g.,  batteries, pesti-
    cides, thermostats, and
    lamps) managed under 40
    CFR 273.
» Might be left  in the bottom
    of containers that have been
    thoroughly emptied through
    conventional means such as
    pouring or pumping.
» Are left as residue  in the bot-
    tom of tanks  storing prod-
    ucts, if the residue is not
    removed from the product
    tank.
» Are reclaimed continuously
    on site without storing prior
    to reclamation, such as
    drycleaning solvents.
» Are managed in an "elemen-
    tary neutralization unit,"  a
    "totally enclosed treatment
    unit,"  or a "wastewater treat-
    ment unit," without being
    stored first. (See Definitions
    for an explanation of these
    types of units.)
» Are discharged directly to
    publicly owned treatment
    works (POTWs) without being
    stored or accumulated first.
    This discharge to a POTW
must comply with the Clean
Water Act. POTWs are public
utilities, usually owned by
the city, county, or state, that
treat industrial and domestic
sewage for disposal.
Have already been counted
once during the calendar
month, and are treated on
site or reclaimed in some
manner, and used again.
Are regulated under the uni-
versal waste rule or have
other special requirements.
The federal regulations con-
tain special, limited require-
ments for managing certain
commonly generated wastes.
These wastes can be man-
aged following the less bur-
densome requirements listed
below instead of the usual
hazardous waste require-
ments. Check with your state
agency to determine if your
state has similar regulations.
Used oil—40 CFR Part 279
Lead-acid batteries that are
reclaimed—40 CFR Part
266, Subpart G
Scrap metal that is recy-
cled—40 CFR 261.6 (a)(3)
Universal wastes (e.g., cer-
tain batteries, recalled and
collected pesticides, and
mercury-containing thermo-
stats and lamps)—40 CFR
Part 273

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                                                                                       CESQG
OVERVIEW OF REQUIREMENTS  FOR CONDITIONALLY
EXEMPT SMALL  QUANTITY  GENERATORS
If you generate no more
than 220 Ibs (100 kg) of
hazardous waste per
month, you are a
Conditionally Exempt
Small Quantity Generator
(CESQG). You  must comply
with three basic waste
management requirements
to remain exempt from the
full hazardous waste regu-
lations that apply to gener-
ators of larger quantities
(SQGs and LQGs).

(Note: there are different
quantity limits for acutely
hazardous waste.)

   First, you  must identify all  haz-
   ardous waste that you gener-
ate. Second, you may not store
more than 2,200 Ibs (1,000 kg) of
hazardous waste on site at any
time. Finally, you must ensure
delivery of your hazardous waste
to an off-site treatment or disposal
facility that is one of the following,
or, if you treat or dispose of your
hazardous waste on
site, your facility
            such as certain batteries,
            recalled and collected pesti-
            cides, or mercury-containing
            thermostats or lamps.)
also most be:
»  A state or fed-
    erally regulated
    hazardous
    waste manage-
    ment treat-
    ment, storage,
    or disposal
    facility.
STATE REQUIREMENTS
   Some states have additional requirements
   for CESQGs. For example, some states
require CESQGs to follow some of the SQG
requirements such as obtaining an EPA identifi-
cation number, or complying with storage stan-
dards. See page 14 for SQG storage
requirements.
    A facility permitted, licensed,
    or registered by a state to
    manage municipal or industri-
    al solid waste.
    A facility that uses, reuses, or
    legitimately recycles the
    waste (or treats the waste
    prior to use, reuse, or
    recycling).
    A universal waste handler or
    destination facility subject to
    the universal waste require-
    ments of 40 CFR Part 273.
    (Universal wastes are wastes
         Suggestion:
         It's a good idea to call the appro-
         priate state agency to verify that
         the treatment, storage, and dispos-
         al facility (TSDF) you have selected
         has any necessary permits, etc.
         You also may want to see that the
         facility fits into one of the above
         categories. (It's a good idea to
         document such calls for your
         records.)
                       Identify your hazardous waste.
                      Comply with storage quantity limits.
                     Ensure proper treatment and disposal of your
                     waste.

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OBTAINING AN  EPA  IDENTIFICATION NUMBER
If your business generates
between 220 Ibs (100 kg)
and 2,200 Ibs (1,000 kg)
of hazardous waste per
month, you are an SQG,
and you must obtain and
use an EPA identification
number. EPA and states
use these 12-character
numbers to monitor and
track  hazardous waste
activities.  You will need to
use your identification
number when you send
waste off site to be
managed.

To obtain an EPA identification
number, you should:
»  Call or write your state haz-
    ardous waste management
    agency or the hazardous waste
    division of your EPA Regional
    office and ask for a copy of
    EPA Form 8700-12,
    "Notification of Hazardous
    Waste Activity" (EPA Regional
offices are listed on pages 24
or visit ). You will be
sent a booklet that contains a
form with  instructions and
those portions of the regula-
tions that will help you identify
your waste. A sample copy of a
completed notification form is
shown on pages 9-10. (Note: A
few states use a form that is
different from the one shown.
Your state agency will send
you the appropriate form to
complete.)
Fill in the form as shown in the
example. To complete Item IX
of the form, you will need to
identify your hazardous waste
by its EPA Hazardous Waste
Code. A list of common haz-
ardous wastes and their waste
codes can be found on the
insert in this handbook; for a
complete  list of  waste codes,
you should consult 40 CFR Part
261, or contact  your state or
regional EPA office or the RCRA
Call Center. The form you
receive from your state might
contain an additional sheet
that provides more space for
waste codes.  Complete one
    copy of the form for each busi-
    ness site where you generate
    or handle hazardous waste.
    Each site will receive its own
    EPA identification number.
    Make sure you sign the certifi-
    cation in Item X.
» Send the completed form to
    your state hazardous waste
    contact.  This address is listed
    in the information booklet that
    you will receive with the form.
EPA records the information on the
form and assigns an EPA identifica-
tion number to the site identified on
your form. The EPA number stays
with the property when ownership
changes. If you move your business,
you must notify EPA or the state of
your new location and  submit a new
form. If another business previously
handled hazardous waste at this
location and obtained  an EPA
Identification  Number,  you will be
assigned the  same number after
you have notified EPA that you have
moved to this location. Otherwise,
EPA will assign you a new identifica-
tion number.
                      Call your state agency to determine if you
                     need an EPA identification number.
                    If you do, obtain a copy of EPA Form 8700-12.
                   Fill in the form completely.
                  Send the form to your STATE hazardous waste
                  contact.

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                                                                                                                   SQG
SAMPLE "NOTIFICATION OF REGULATED WASTE ACTIVITY"  FORM
Please print or type with ELITE type (12 characters per inch) in the unshaded areas only
                                                                                       OSA No. 0246-EPA-OT
Please refer to Section V. Line-by-
Line Instructions for Completing
EPA  Form 8700-12  before
completing  this form.  The
information  requested here is
required by law (Section 3010 of
the Resource Conservation and
Recovery Act).	
Notification of Regulated
        Waste Activity
     United States Environmental Protection Agency
                                                                                    Date Received
                                                                                 (For Official Use Only)
 I. Installation's EPA ID Number (Mark 'X' in the appropriate box)
     A. Initial Notification
                            B. Subsequent Notification
                               (Complete item C)
 II. Name of Installation (Include company and specific site name)
    eTn  &  r  a  I
                                      a
 III. Location of Installation (Physical address not P.O. Box or Route Number)
 Street
                                                                   23000
 IV. Installation Mailing Address (See instructions)
 Street or P.O. Box
 V. Installation Contact (Person to be contacted regarding waste activities at site)
                                                   Phone Number (Area Code and Number)
                                                  504-555
Manager
 VI. Installation Contact Address (See instructions)
                  B. Street or P.O. Box
                 501    Main
                                               Street
                                                                   23000
VII. Ownership (See instructions)
 5 Q 11   IMI  al  in     Street
 Street (Continued)
A. Name of Installation's Legal Owner
J lol e>\ e\  p  h   i In \e\   \D\o\e
Street, P.O. Box, or Route Number
 2I5I4I   iBlrlolaldl   iSltlrlelelt
City or Town
                                                            State
                                                                   Zip Code
Smalltown
                                                            V
 Phone Number (Area Code and Number)
                                         B. Land Type
 504-555-6759
                                                    C. Owner Type
                                   D. Change of Owner
                                       Indicator
                                           ^ No
                                                               Yes
                                                                                      Date Changed
                                                                                 Month   Day   Year
EPA Form 8700-12 (Rev. 12/99)
                                               -1of2-

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           SAMPLE "NOTIFICATION OF REGULATED WASTE ACTIVITY" FORM (CONTINUED)

            Please print or type with ELITE type (12 characters per Inch) in the unshaded areas only
                                                         Form Approved. OMB No. 2050-0023 Expires 12/31/02
                                                                           GSA No. 0246-EPA-OT
             VIII. Type of Regulated Waste Activity (Mark 'X' In the appropriate boxes. Refer to Instructions)

                                                                                           C. Used Oil Management Activities
A. Hazardous Waste Activities
              1.  Generator (See Instructions)
              D   a. Greater than 10OOkg/mo (2,200 Ibs.)
              [X]   b. 100 to 1000 kg/mo (220-2,200 Ibs.)
              G   c. Less than 100 kg/mo (220 Ibs)
              2.  Transporter (Indicate  Mode in boxes
                  1-5 below)
              G   a. For own waste only
              Q   b. For commercial purposes

              Mode of Transportation
              D   1-Air
              D   2. Rail
              D   3. Highway
              D   4. Water
              D   5. Other-specify
                D 3.  Treater,  Storer, Disposer  (at
                      installation) Note: A permit is
                      required  for this activity, see
                      instructions.
                   4.  Exempt Boiler and/or Industrial
                      Furnace
                   Q] a. Smelting, Melting, and Refin-
                        ing Furnace Exemption
                   D b. Small Quantity On-Site Burner
                        Exemption
                D 5.  Underground Injection Control
                                                 H
                                       1.  Used Oil Transporter/Transfer
                                           Facility - Indicate Type(s) of
                                           Acllvlty(les)
                                        Q a. Transporter
                                        Q b. Transfer Facility
                                       2.  Used Oil Processor/Re-refiner -
                                           Indicate Type(s) of Activity(ies)
                                        O a. Processor
                                        Q b. Re-refiner
                                    D 3.  Off-Specification Used Oil Burner
                                       4.  Used Oil Fuel Marketer
                                        O a. Marketer Who Directs Shipment
                                            of Off-Specification Used Oil to
                                            Used Oil Burner
                                        G b. Marketer Who First Claims the
                                            Used Oil Meets the
                                            Specifications
                                      B. Universal Waste Activity
              D Large Quantity Handler of Universal Waste
              IX. Description of Hazardous Wastes (Use additional sheets if necessary)
              A. Listed Hazardous Wastes. (See 40 CFR 261.31 - 33; See Instructions If you need to list more than 12 waste codes.)
              B. Characteristics of Nonhsted Hazardous Wastes. (Mark 'X'in the boxes corresponding to the characteristics of
                nonllsted hazardous wastes your Installation handles; See 40 CFR Parts 261.20 - 261.24; See Instructions If you need
                to list more than 4 toxlctty characteristic waste codes.)
                                                    (List specific EPA hazardous waste number(s) for the Toxicity Characteristic contaminant(s))
            Llgnltable  2. Corrosive 3. Reactive   4.Toxlclty
              70001)     (0002)     (0003)   Characteristic
              C. Other Wastes. (State-regulated or other wastes requiring a handler to have an I.D. number; See Instructions.)
              a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of
              the person or persons who manage the system, or those persons directly responsible for gathering the information, the information
              submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for
              submitting false Information, Including the possibility of fine and Imprisonment for knowing violations.
              Signature
  Name and Official Title (Type or print)
Josephine  Doe,  own
                                                                    Date Signed
                                                                   12-01-00
             Note: Mail completed form to the appropriate EPA Regional or State Office.  (See Section IV of the booklet for addresses.)
            EPA Form 8700-12 (Rev. 12/99)
                                                                 - 2 of 2 -
10

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                                     It is a good practice never to mix wastes. Mixing
                                     wastes can create an unsafe work environment and
                                    lead to complex and expensive cleanups and disposal.
 MANAGING HAZARDOUS WASTE ON  SITE
 Most small businesses
 accumulate some haz-
 ardous waste on site for a
 short period of time and
 then ship it off site to a
 treatment, storage, or dis-
 posal facility (TSDF).

Accumulating Your Waste
   Accumulating hazardous waste
   on site can pose a threat to
human health  and the environment,
so you may keep it only for a short
time without a permit. Before ship-
ping the waste for disposal or recy-
cling, you  are responsible for its
safe management, which includes
safe storage, safe treatment, pre-
venting accidents, and responding
to emergencies in accordance with
federal regulations.
SQGs can accumulate no more
than  13,228 Ibs (6,000 kg) of haz-
ardous waste  on site for up to 180
days without a permit. You can
accumulate this amount of waste
for up to 270  days if you must
transport it more than 200 miles
away for recovery, treatment, or
disposal. Limited extensions may
be granted by the state director or
the regional EPA administrator. If
you exceed these limits, you are
considered a TSDF and must
obtain an operating permit. Wastes
generated in small amounts
throughout your facility may be
stored in satellite accumulation
areas located at or near the point
of generation of the waste. The
total amount of waste that may be
accumulated at a satellite area is
limited to 55 gallons. Once this
quantity has been exceeded, you
have 3 days to transfer the waste
to your designated 180-day (or
270-day) storage area.
(Note: Different quantity limits apply
to acutely hazardous wastes.)
SQGs must accumulate waste in
tanks or containers, such as 55-
gallon drums. Your storage tanks
and containers must be  managed
according to EPA requirements
summarized below:
For containers, you must:
»  Label each container with the
    words "HAZARDOUS WASTE"
    and the date that the waste
    was generated.
Use a container made of, or
lined with, a material that is
compatible with the haz-
ardous waste to be stored.
(This will prevent the waste
from reacting with or corroding
the container.)
Keep all containers holding
hazardous waste closed dur-
ing storage, except when
adding or removing waste. Do
not open, handle, or store
(e.g., stack) containers in a
way that might  rupture them,
cause them to  leak, or other-
wise fail.
Inspect areas where contain-
ers are stored at least weekly.
Look for leaks and for deterio-
ration caused by corrosion or
other factors.
Maintain the containers in
good condition.  If a container
leaks, put the hazardous waste
in another container, or contain
it in some other way that com-
plies with EPA regulations.
Do not mix incompatible
wastes or materials unless
precautions are taken to
prevent certain  hazards.
                      Accumulate wastes according to limits estab-
                     lished by EPA for SQGs.
                    Follow the storage and handling procedures
                   required by EPA for SQGs.
                  Follow EPA requirements for equipment testing
                  and maintenance, access to communications or
                 alarms, aisle space, and emergency arrangements
                with local authorities.
                                                                       11

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 SQG
          WASTE MINIMIZATION: THE KEY TO BETTER WASTE MANAGEMENT
             The easiest and most cost-effective way of managing any waste is not to generate it in the first place. You
             can decrease the amount of hazardous waste your business produces  by developing a few  "good house-
          keeping" habits. Good housekeeping procedures generally save businesses money, and they prevent acci-
          dents and waste. To help reduce the amount of waste you generate, try the following practices at your
          business.
              Do not mix wastes. Do not
              mix nonhazardous waste with
              hazardous waste. Once you
              mix anything with listed haz-
              ardous waste, the whole
              batch becomes hazardous.
              Mixing waste can also make
              recycling very difficult, if not
              impossible. Atypical example
              of mixing wastes would be
              putting nonhazardous clean-
              ing agents in a container of
              used hazardous solvents.
              Change materials, process-
              es, or both.  Businesses can
              save money and increase
              efficiency by replacing a
              material or a process with
              another that produces less
              waste. For example, you
              could use plastic blast
              media for paint stripping of
              metal parts  rather than con-
              ventional solvent stripping.
              Recycle and reuse manufac-
              turing materials. Many com-
              panies routinely put useful
              components back into pro-
              ductive use  rather than dis-
              posing of them. Items such
              as oil, solvents, acids, and
              metals are commonly recy-
              cled  and used  again. In addi-
              tion, some companies have
taken waste minimization
actions such as using fewer
solvents to do the same job,
using solvents that are  less
toxic, or switching to a deter-
gent solution.
Safely store hazardous  prod-
ucts and containers. You
can avoid creating more haz-
ardous waste by preventing
spills or leaks. Store  haz-
ardous product and waste
containers in secure areas,
and inspect them frequently
for leaks. When leaks or
spills occur, materials used
to clean them also become
hazardous waste.
» Make a good faith effort.
    SQGs do not have to docu-
    ment their waste minimiza-
    tion activities or create a
    waste minimization plan. You
    do, however, need to certify
    on your manifests that you
    have made a good faith
    effort to minimize waste gen-
    eration when you send your
    waste off site.
12

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                                                                                                      SQG
                                                                                                          7?, f T I '
For tanks, you must:
» Label each tank with the
    words "HAZARDOUS WASTE"
    and the date that the waste
    was generated.
» Store only waste that will  not
    cause the tank or the inner
    liner of the tank to  rupture,
    leak, corrode, or fail.
» Equip tanks that have an
    automatic waste feed with a
    waste feed cutoff system, or a
    bypass system for use in the
    event of a leak or overflow.
» Inspect discharge control  and
    monitoring equipment and the
    level of waste  in uncovered
    tanks at least  once each
    operating day.  Inspect the
    tanks and surrounding areas
    for leaks or other problems
    (such as corrosion) at least
    weekly.
Use the National Fire
Protection Association's
(NFPA's) buffer zone require-
ments for covered tanks con-
taining ignitable or reactive
wastes. These requirements
specify distances considered
to be safe buffer zones for
various ignitable or reactive
wastes. You can reach the
NFPA at 617 770-3000.
Do not mix incompatible
wastes or materials unless
precautions are taken to pre-
vent certain hazards.
Do not place ignitable or reac-
tive wastes in tanks unless
certain precautions are taken.
Provide at least 2 feet (60
centimeters) of freeboard
(space at the top of each
tank) in uncovered tanks,
unless the tank is equipped
                                                                           with a containment structure,
                                                                           a drainage control system, or
                                                                           a standby tank with adequate
                                                                           capacity.

                                                                      Treating Your Waste
                                                                      to Meet the Land Disposal
                                                                      Restrictions  (LDRs)
                                                                       M;
     Iost hazardous wastes may
     not be land disposed unless
they meet "treatment standards."
The Land Disposal Restrictions
(LDR) program requires that the
waste is treated to reduce the haz-
ardous constituents to levels set
by EPA,  or that the waste  is treat-
ed using a specific technology. It is
your responsibility to ensure that
your waste is treated to meet LDR
treatment standards before it is
land disposed. (See page 17 for a
description of required LDR
notices.) Most SQGs probably will
have their designated TSDF do this
treatment. If you choose to treat
your waste yourself to  meet LDR
treatment standards, there are
additional  requirements including
waste analysis plans, notifications,
and certifications. To learn about
these requirements, contact the
RCRA Call Center, your state
agency,  or EPA regional office, and
consult  40 CFR Part 268.

Preventing Accidents
     Whenever you store hazardous
     waste on site, you must mini-
mize the potential risks from fires,
explosions, or other accidents.
                                                                                                             13

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 SQG
        All SQGs that store hazardous
        waste on site must be equipped
        with:
        » An  internal communications or
            alarm system capable of pro-
            viding immediate emergency
            instruction (voice or signal) to
            all  personnel.
        » A device, such as a telephone
            (immediately available at the
            scene of operations) or a
            hand-held, two-way radio,
            capable of summoning emer-
            gency assistance from local
            police and fire departments or
            emergency response teams.
        » Portable fire extinguishers,
            fire-control devices (including
            special  extinguishing equip-
            ment, such as those using
            foam, inert gas, or dry chemi-
            cals), spill-control  materials,
            and decontamination
            supplies.
        » Water at adequate volume
            and pressure to supply water-
            hose streams, foam-producing
            equipment, automatic sprin-
            klers, or water spray systems.
        You must test  and maintain all
        equipment to ensure proper opera-
        tion. Allow sufficient aisle space to
        permit the unobstructed movement
        of personnel, fire protection equip-
        ment, spill-control equipment, and
        decontamination equipment to any
        area of facility operation. Attempt
        to secure arrangements with fire
        departments, police, emergency
        response teams, equipment suppli-
  IF YOU THINK YOU HAVE AN EMERGENCY,
  IMMEDIATELY CALL  911 AND THE NATIONAL
  RESPONSE CENTER AT 800 424-8802.
   In the event of a fire, explosion,
   or other release of hazardous
  waste that could threaten
  human health outside the facili-
  ty, 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

ers, and local hospitals, as appro-
priate, to provide services  in the
event of an emergency. Ensure
that personnel handling hazardous
waste have immediate access to
an alarm or emergency communi-
cations device.
You are not required to have a for-
mal personnel training program, but
you must ensure that  employees
handling hazardous waste are famil-
iar with proper handling and emer-
gency procedures. In addition, you
must have an emergency coordina-
tor on the premises or on-call at  all
times, and have basic facility safety
information readily accessible.

Responding to Emergencies
   Although EPA does  not require
   SQGs to have a written contin-
gency plan, you must  be prepared
for an emergency at your facility.
You should also be  prepared to
answer a set of "what if" ques-
tions. For example:  "What  if there
is a fire  in the area where  haz-
the situation and help you make
appropriate emergency deci-
sions. In many cases, you will
find that the problem you faced
was not a true emergency, but  it
is better to call if you are not
sure. Serious penalties exist for
failing to report emergencies.
ardous waste is stored?" or "What
if I spill hazardous waste, or one of
my hazardous waste containers
leaks?" In case of a fire, explo-
sion, or toxic release, having such
a plan  provides an organized and
coordinated course of action.
SQGs are required to establish
basic safety guidelines and
response procedures to follow in
the event of an emergency.
Worksheets 1 and 2 (on page 15)
can help you set up these proce-
dures.  The information on
Worksheet 1 must be posted near
your phone. You must ensure that
employees are familiar with these
procedures.
14

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Worksheet 1 Fill in and post this information next to your telephone.
EMERGENCY RESPONSE INFORMATION
Emergency Coordinator
Name:

Telephone:


Fire Extinguisher
Location(s):




Spill-Control Materials
Location(s):


Fire Alarm (if present)
Location(s):



Fire Department
Telephone:

Worksheet 2 Fill in and post this information next to your telephone. Make sure all employees read and are familiar
with its contents.
  EMERGENCY RESPONSE PROCEDURES
  In the event of a spill:
  Contain the flow of hazardous waste
  to the extent possible, and as soon
  as is possible, clean up the haz-
  ardous waste and  any contaminated
  materials or soil.
  In the event of a fire:
  Call the fire department and, if safe,
  attempt to extinguish the fire using
  a fire extinguisher.
  In the event of a fire, explosion, or
  other release that  could threaten
  human health outside the facility, or
  if you know that the spill has
  reached  surface water:
  Call the National Response Center
  at its 24-hour number (800 424-
  8802). Provide the following infor-
  mation:
Our company name:
Our address:
Our U.S. EPA identification 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
                                                                                                            15

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SQG
       SHIPPING WASTE OFF SITE
       When shipping waste off
       site, SQGs must follow
       certain  procedures that
       are designed to ensure
       safe transport and proper
       management of the waste.
       Selecting a Treatment,
       Storage, and Disposal
       Facility (TSDF)
           SQGs may send their waste only
           to a regulated Treatment,
       Storage, and  Disposal Facility
       (TSDF) or recycler. Most regulated
       TSDFs and recyclers will have a
       permit from the state or EPA.
       Some, however, may operate under
       other regulations that do not
       require a permit. Check with the
       appropriate state authorities to be
       sure the facility you select has any
necessary permits. All TSDFs and
recyclers must have EPA identifica-
tion numbers.

Labeling Waste Shipments
    SQGs must properly package,
    label, and mark all hazardous
waste shipments, and placard the
vehicles in which these wastes are
shipped following Department of
Transportation (DOT) regulations.
Most small businesses use a com-
mercial transporter to ship haz-
ardous waste. These transporters
can advise you on specific require-
ments for placarding, labeling,
marking, and packaging; however,
you remain responsible for compli-
ance. For additional information,
consult the DOT regulations (49
CFR Parts 172 and 173) or call
the DOT hazardous materials infor-
mation line at 202  366-4488 or
800 467-4922.
Federal regulations allow you to
transport your own hazardous
waste to a designated TSDF provid-
ed that you comply with DOT rules.
Some states, however, do not
allow this practice. Call  DOT and
your state hazardous waste man-
agement agency regarding applica-
ble regulations.
                           @ Package, label, and mark your shipment, and
                              placard the vehicle in which your waste is
                             shipped as specified in DOT regulations.
                         @ Prepare a hazardous waste manifest to accom-
                            pany your shipment.
                         I)  Include a notice and certification with the first
                           waste shipment.
                         I  Ensure the  proper management of any hazardous
                          waste you ship (even when it is no longer in your
                          possession).

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Preparing Hazardous Waste
Manifests
   The Hazardous Waste Manifest
   System is a set of forms,
reports, and procedures designed
to seamlessly track hazardous
waste from the time it leaves the
generator  until it reaches the off-
site waste management facility
that will store, treat, or dispose of
the hazardous waste. The system
allows the waste generator to
verify that its waste has been prop-
erly delivered and that no waste
has been lost or unaccounted for
in the process.
The key component of this system
is the Uniform Hazardous Waste
Manifest, which is a multipart form
prepared by most generators that
transport hazardous waste for off-
site treatment, recycling, storage,
or disposal. The manifest is
required by both the DOT and EPA.
When completed, it contains infor-
mation on the type and quantity of
the waste being transported,
instructions for handling the
waste, and signatures of all par-
ties involved in the off-site treat-
ments, recycling, storage, or
disposal  process. Each party also
must retain a copy of the  mani-
fest. This process ensures critical
accountability in the transportation
and disposal process. Once the
waste reaches its destination, the
receiving facility returns a signed
copy of the manifest to the genera-
tor, confirming that the waste has
been received.
At press time, the Uniform
Hazardous Waste Manifest system
is in the process of being updated
and modernized. Please check the
Internet at www.epa.gov/
epaoswer/hazwaste/gener/
manifest/index.htm.
EPA expects to standardize the
content and appearance of the cur-
rent manifest form so that the
same form may be used by waste
handlers nationwide. Other antici-
pated changes include improved
tracking procedures and an option
to complete, send, and  store the
mainfest information electronically.

Land Disposal Restrictions
(LDR) Reporting
Requirements
   Regardless of where the waste
   is being sent,  the initial ship-
ment of waste subject to LDRs
must be sent to a receiving TSDF
or recycler along with an LDR
notice. You must send an addition-
al LDR notice if your waste or
receiving facility changes. This
notice must provide information
about your waste, such  as the EPA
hazardous waste code and the
LDR treatment standard. The pur-
pose of this notice is to let the
TSDF know that the waste must
                                                                                                             17

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 SQG
         meet treatment standards before it
         is land disposed. There is no
         required form for this notice, but
         your TSDF may provide a form for
         you to use. A certification may
         also be required in specific situa-
         tions. Contact the RCRA Call
         Center, your state agency, or EPA
         regional office and consult 40 CFR
         Part 268 for help with LDR notifica-
         tion and certification requirements.

         Export Notification
          If you choose to export your haz-
          ardous waste, you must notify
         EPA 60 days before the intended
         date of shipment to obtain written
         consent. EPA's "Acknowledge-ment
         of Consent" document must
         accompany the shipment at all
         times. For more  information on
         how to obtain the consent to
         export hazardous waste, contact
         the RCRA Call Center at 800 424-
         9346.
Closure
     When you close your facility,
     you must ensure that all haz-
ardous waste has been removed
from your hazardous waste tanks,
discharge-control equipment, and
discharge confinement structures.
In addition, any contamination you
might have  caused must be
cleaned up and managed under all
applicable hazardous waste
regulations.
18

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                                                                                                    SQG
MANAGING USED OIL
EPA's used oil management stan-      |
dards are a set of "good house-
keeping" requirements that
encourage used oil handlers to
recycle used oil instead of dispos-
ing of it. Used oil can be collected,
refined and recycled, and used
again—for the same job or a com-
pletely different task.
Used oil is defined as "any oil  that
has been refined from crude oil or
any synthetic oil that has been
used and, as a result of such use,
is  contaminated by physical or
chemical impurities." To meet
EPA's definition of used oil, a sub-
stance must meet each of the fol-
lowing criteria:
» Origin. Used oil must have
     been refined from crude oil or
     made from synthetic materi-
    als. Animal and vegetable oils
    are excluded from EPA's defi-
     nition of used oil.
                                      Use. Oils used as lubricants,
                                      hydraulic fluids, head transfer
                                      fluids, buoyants, and for other
                                      similar purposes  are consid-
                                      ered used oil. Unused oil
                                      such as bottom clean-out
                                      waste from virgin fuel oil stor-
                                      age tanks or virgin fuel oil
                                      recovered from a  spill do not
                                      meet EPA's definition of used
                                      oil because these oils have
                                      never been used. EPA's defini-
                                      tion also excludes products
                                      used as cleaning agents or
                                      solely for their solvent proper-
                                      ties, as well as certain petro-
                                      leum-derived products such
                                      as antifreeze and kerosene.
                                      Contaminants. To meet EPA's
                                      definition, used oil must
                                      become contaminated as a
                                      result of being used. This
                                      includes residues and contami-
                                      nants generated from handling,
                                      storing, and processing used
                  oil. Physical contaminants can
                  include dirt, metal scrapings, or
                  sawdust. Chemical contami-
                  nants could include solvents,
                  halogens, or saltwater.
              The following types of businesses
              handle used oil:
              »  Generators are businesses
                  that handle used oil through
                  commercial or industrial oper-
                  ations or from the mainte-
                  nance of vehicles and
                  equipment. Examples include
                  car repair shops, service sta-
                  tions, government motor
                  pools, grocery stores, metal-
                  working industries, and boat
                  marinas. Farmers who pro-
                  duce less than an average of
                  25 gallons of used oil per
                  month are excluded from gen-
                  erator status. Individuals who
                  generate used oil through the
                  maintenance of their personal
                  vehicles and  equipment are
SELECTING A TRANSPORTER OR TSDF/RECYCLER
 It is important to choose your transporter and your
 TSDF carefully because you remain responsible for
the proper management of your hazardous waste
even after it has left your site.
For help in choosing a transporter or TSDF, check
with the following sources:
» References from business colleagues who have
    used a specific hazardous waste transporter or
    TSDF.
» Trade associations for your industry that might
    keep a file on companies  that handle hazardous
    waste.
The Better Business Bureau or Chamber of
Commerce in the TSDF's area, which might have
a record of any complaints registered against a
transporter or a facility.
Your state hazardous waste management
agency or EPA regional office, which can tell you
whether the transporter or TSDF has an EPA
identification number and a permit, if required.
Facility information, including types and quanti-
ties of waste managed and violations
assessed, can be accessed via  the Envirofacts
Internet site  at .
                                                                                                          19

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              not subject to regulation
              under the used oil manage-
              ment standards.
         »  Collection centers and aggre-
              gation points are facilities
              that accept small amounts of
              used oil and store it until
              enough is collected to ship  it
              elsewhere for recycling.
         »  Transporters are companies
              that pick up used oil from all
              sources and deliver it to re-
              refiners, processors, or burners.
              Transfer facilities are any struc-
              ture or area where used oil is
              held for longer than 24 hours
              but not longer than 35 days.
         »  Re-refiners  and processors
              are facilities that blend or
              remove impurities from used
              oil so the oil can be burned
              for energy recovery or reused.
         »  Burners burn used oil for
              energy recovery in boilers,
              industrial furnaces, or in haz-
              ardous waste incinerators.
         »  Marketers are handlers that
              either a) direct shipments of
              used oil to be burned as fuel  in
              regulated devices or b) claim
              that certain EPA specifications
              are met for  used oil to  be
              burned for energy recovery in
              devices that are not regulated.
         Although different used oil  han-
         dlers have specific requirements,
         the following requirements are
         common to all types of handlers:
         Storage
         »  Label all containers and tanks
              as Used Oil.
»  Keep containers and tanks in
     good condition. Do not allow
     tanks to rust, leak, or deterio-
     rate. Fix structural defects
     immediately.
»  Never store used oil in any-
     thing other than tanks and
     storage containers. Used oil
     also can be stored in units
     that are permitted to store
     regulated hazardous waste.
Oil Leaks or Spills
»  Take steps to prevent leaks
     and spills. Keep machinery,
     equipment, containers, and
     tanks in good working condi-
     tion, and be careful when trans-
     ferring used oil. Keep sorbent
     materials available at the site.
»  If a leak or spill occurs, stop
     the oil from flowing at the
     source. If a  leak can't be
     stopped, put the oil in another
     holding container or tank.
» Contain spilled oil using sor-
    bent berms or spreading sor-
    bent over the oil and
    surrounding area.
» Clean up the used oil and
    recycle it as you would have
    before it was spilled. If recy-
    cling is not possible, you
    must first make sure the used
    oil is not a hazardous waste
    and dispose  of it appropriate-
    ly. All used cleanup materials,
    including rags and sorbent
    booms, that contain used oil
    must also  be handled accord-
    ing to the used oil manage-
    ment standards.
» Remove, repair, or replace the
    defective tank or container
    immediately.
Used oil requirements are detailed
in  40 CFR Part  279. For more
information, contact the Emergency
Response Division's Information
Hotline at 202 260-2342.
20

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SUMMARY  OF  REQUIREMENTS FOR  LARGE  QUANTITY
GENERATORS
If you  are a  Large Quantity Generator (LQG) (generating more than 2,200  Ibs (1,000
kg)  per month), you must comply with the  full set of hazardous waste regulations. This
table summarizes the federal LQG requirements. This is only a summary and does not
include all of the LQG requirements. For more details, contact the RCRA Call Center at
800 424-9346, or TDD  800  553-7672, or see  40  CFR Part 262.  Be sure to check with
your state as  well because certain states  have additional  or more stringent  require-
ments than  the federal  government.
  LQG Requirements
Summary
  Hazardous Waste Determination
  (40 CFR Part 262.10)
  Generator Category Determination
  (40 CFR Part 262.10 (b) and 261.5 (b)
  and (c))
Identify all hazardous wastes you generate. Measure the amount of hazardous waste you
generate per month to determine your generator category (e.g., LQG).
  EPA Identification Numbers
  (40 CFR 262.12)
Obtain a copy of EPA Form 8700-12, fill out the form, and send it to the contact listed with
the form. An EPA identification number will be returned to you for your location.
  Prepare Hazardous Waste for Shipment
  Off Site (40 CFR Parts 262.30 - 262.33)
Package, label, mark, and placard wastes following Department of Transportation require-
ments. Ship waste using hazardous waste transporter.
  The Manifest
  (40 CFR Parts 262.20 - 262.23, 262.42)
Ship waste to hazardous waste treatment, storage, disposal, or recycling facility. Ship haz-
ardous waste off site using the manifest system (EPA Form 8700-22) or state equivalent.
  Managing Hazardous Waste On Site
  (40 CFR Part 262.34)
Accumulate waste for no more than 90 days without a permit. Accumulate waste in contain-
ers, tanks, drip pads, or containment buildings. Comply with specified technical standards for
each unit type.
  Recordkeeping and Biennial Report
  (40 CFR Parts 262.40 - 262.41)
Retain specified records for 3 years. Submit biennial report by March 1 of even numbered
years covering generator activities for the previous year.
  Comply with Land Disposal Restrictions
  (40 CFR 268)
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.
  Export/Import Requirements
  (40 CFR Subparts E and F)
Follow requirements for exports and imports, including notification of intent to export and
acknowledgement of consent from receiving country.
  Air Emissions (40 CFR Part 265,
  Subpart CC)
If applicable, use various monitoring and control mechanisms to:
•  Control volatile organic compound (VOC) emissions from hazardous waste management
  activities.
•  Reduce organic emissions from process vents associated with certain recycling activities
  and equipment that is in contact with hazardous waste that has significant organic content.
•  Control VOCs from hazardous waste tanks, surface impoundments, and containers using
  fixed roofs, floating roofs,  or closed-vent systems routed to control devices.
  Closure (40 CFR Parts 265.111 and
  265.114)
Decontaminate and remove all contaminated equipment, structures, and soil, and minimize
the need for further maintenance of your site. Meet unit-specific closure standards for tanks,
containment buildings, and drip pads.
                                                                                                                21

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        WHERE TO GET  MORE  HELP
        For further assistance in
        understanding the  haz-
        ardous waste regulations
        applicable to you, contact
        your state hazardous waste
        agency. Other assistance
        resources include the  EPA
        Resource Centers (includ-
        ing the RCRA Call Center),
        or your EPA regional  office
        (page 24).
Also, see other related sections of
the Code of Federal Regulations:
^  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)
 EPA and Other Federal
 Resource Centers
 RCRA Call Center
 U.S. Environmental Protection
 Agency
 1200 Pennsylvania Ave, NW.
 Washington, DC 20460
 Phone: 800 424-9346, or TDD
 800 553-7672. In Washington,
 DC: 703 412-9810, or
 TDD 703 412-3323
 Web: www.epa.gov/epaoswer/hotline
 Answers questions on  matters
 related to solid waste,  hazardous
 waste, and underground storage
 tanks. Also can be used to find
 and order EPA publications.
           RCRA in Focus
              RCRA in Focus is a series of
              short  informational booklets
           that describes the RCRA regula-
           tions as they apply to specific
           industry sectors. The documents
           explain what RCRA is, who is
           regulated, and what hazardous
           waste is; provide a sample life
           cycle of a  RCRA waste in each
           industry; include a quick refer-
           ence chart of all applicable
           RCRA regulations and a series
           of waste minimization sugges-
           tions for various specific indus-
           trial processes;  and provide
           information on other relevant
           environmental laws and a page
           of contacts and  resources.
  Individual issues of RCRA in
  Focus have been written for the
  following industries:
      Dry Cleaning (EPA530-K-99-
      005)
  •   Leather Manufacturing
      (EPA530-K-00-002)

  •   Motor Freight & Railroad
      Transportation (EPA530-K-
      00-003)

      Photo Processing (EPA530-
      K-99-002)
  •   Printing (EPA530-K-97-007)

  •   Vehicle Maintenance
      (EPA530-K-99-004)
  Other issues of RCRA in Focus
  will cover:

  •   Wood Preserving/Wood
      Products
•   Construction, Demolition &
    Renovation
•   Metals Manufacturing
•   Furniture Manufacturing
•   Pharmaceutical
    Manufacturing
•   Laboratories
Copies of RCRA in Focus can be
obtained by contacting the RCRA
Call Center at 800 424-9346 or
TDD 800 553-7672 and request-
ing the document numbers list-
ed above. You can also view the
documents online at
.
22

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Small Business Ombudsman
Clearinghouse/Hotline
U.S. Environmental Protection
Agency
Small Business Ombudsman
(1230C)
1200 Pennsylvania Ave, NW.
Washington, DC 20460
Phone: 800 368-5888 or
202 260-1211
Fax: 202 401-2302
Web: www.epa.gov/sbo
Helps private citizens, small busi-
nesses, and smaller communities
with questions on all program
aspects within EPA.
Department of Transportation
(DOT) Hotline
Office of Hazardous Materials
Standards (DOT)
Research and Special Programs
Administration
400 7th Street, SW.
Washington, DC 20590-0001
Phone: 202 366-4488 or
800 467-4922
Fax: 202 366-3753
Web: http://hazmat.dot.gov
Answers questions on matters
related to DOT'S hazardous materi-
als transportation regulations.
RCRA Docket Information Center
(RIC)
U.S. Environmental Protection
Agency
RCRA Docket Information Center
(5305W)
1200 Pennsylvania Ave, NW.
Washington, DC 20460
Phone: 703 603-9230
Fax: 703 603-9234
E-mail: RCRA-Docket@
epamail.epa.gov
Web: www.epa.gov/epahome/
dockets.htm
Provides public access to all regu-
latory materials on solid waste and
distributes technical and nontech-
nical information on solid waste.
Pollution Protection Information
Clearinghouse (PPIC)
U.S. Environmental Protection
Agency
1200 Pennsylvania Ave, NW.
Washington, DC 20460
Phone: 202 260-4659
Fax: 202 260-0178
E-mail: PPIC@epamail.epa.gov
Web: www.epa.gov/opptintr/
libra ry/libppic.htm
Provides a library and an electronic
bulletin board (accessible by any
PC equipped with a modem) dedi-
cated to information on  pollution
prevention.
Information Resource Center
U.S. Environmental Protection
Agency
Headquarters Library
1200 Pennsylvania Ave, NW.
IRC (3404)
Washington, DC 20460
Phone: 202 260-5922
Fax: 202 260-5153
E-mail: public-access@
epamail.epa.gov
Web: www.epa.gov/natlibra/hairc
Maintains environmental reference
materials for EPA staff and the
general public, including books,
journals, abstracts, newsletters,
and audio-visual materials generat-
ed by government agencies and
the private sector.
Methods Information
Communication Exchange (MICE)
U.S. Environmental Protection
Agency
OSW Methods Team
1200 Pennsylvania Ave, NW.
(5307W)
Washington, DC 20460
Phone: 703 676-4690 or
703 308-8855
Fax: 703 318-4682 or
703 308-0511
E-mail: mice@cpmx.saic.com
Web: www.epa.gov/sw-846
                                                                                                          23

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        EPA Regional Offices
        EPA Region 1
        CT, MA, ME, NH, Rl, VT
        1 Congress Street
        Suite 1100
        Boston, MA 02114-2023
        617 918-1111 or
        800 372-7431 in Region 1
        Library: 888 372-5427 or
        617 918-1990
        EPA Region 2
        NJ, NY, PR, VI
        290 Broadway
        26th Floor
        New York, NY 10007-1866
        212 637-3000
        Library: 212 637-3185
EPA Region 3
DC, DE, MD, PA, VA, WV
1650 Arch Street
Philadelphia, PA 19103-2029
215 814-5000 or
800 438-2474 in Region 3
Library: 215 814-5254
EPA Region 4
AL, FL, GA, KY, MS, NC, SC, TN
Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, GA 30303-3104
404 562-9900
800 241-1754 in Region 4
Library: 404 562-8190
EPA Region 5
IL, IN, Ml, MN, OH, Wl
77 West Jackson Boulevard
Chicago, IL 60604
312 353-2000 or
800 621-8431 in Region 5
EPA Region 6
AR, LA, NM, OK, TX
1445 Ross Avenue
Suite 1200
Dallas, TX 75202-2733
214 665-2200 or
800 887-6063 in Region 6
Library: 214 665-6424
EPA Region 7
IA, KS, MO, NE
901 North 5th Street
Kansas City, KS 66101
913 551-7000 or
800 223-0425 in Region 7
Library: 913 551-7241
EPA Region 8
CO, MT, ND, SD, WY, UT
One Denver Place
999 18th Street
Suite 500
Denver, CO 80202-2466
303 312-6312 or
800 227-8917 in Region 8
EPA Region 9
AS, AZ, CA, GU, HI, MH, MP, NV
75 Hawthorne Street
San Francisco, CA 94105
415 744-1305
Library: 415 744-1510
EPA Region 10
AK, ID, OR, WA
1200 Sixth Avenue
Seattle, WA 98101
206 553-1200 or
800 424-4372 in Region 10
Library: 206 553-1289
24

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Worksheet 3 These questions are geared toward the federal requirements for SQGs but may be helpful for other
hazardous waste generators. Use them to help prepare for a visit from a federal, state, or local agency.
                   Do you have documentation on the amount and kinds of hazardous waste that you generate and on how
                   you determined that they are hazardous?

                   Do you have a U.S. EPA identification number?

                   Do you ship wastes off site?

                   If so, do you know the name of the transporter and the designated TSDF that you use?

                   Do you have copies of completed manifests used to ship your hazardous wastes over the past 3 years?

                   Are they filled out correctly?

                   Have they been signed by the designated TSDF and transporter?

                   If you have not received your signed copy of the manifest from the TSDF, have you filed an exception
                   report?

                   Is your hazardous waste stored in proper containers or tanks?

                   Are the containers or tanks properly dated and/or marked?

                   Have you complied with the handling requirements  described in this handbook?

                   Have you designated an emergency coordinator?

                   Have you posted emergency telephone numbers and the location of emergency equipment?

                   Are your employees thoroughly familiar with proper waste handling and emergency procedures?

                   Do you understand when you need to contact the National Response Center?

                   Do you store your waste for no more  than 180 days, or 270 days if you ship your waste more than 200
                   miles?
Yes
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
No
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
                                                                                                                          25

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        ACRONYMS AND  DEFINITIONS
        Byproduct
        A material that is not one of the
        primary products of a production
        process. Examples of byproducts
        are process residues such as slags
        or distillation column bottoms.

        CESQG—Conditionally
        Exempt Small Quantity
        Generator
        A business that generates less
        than 220 Ibs (100 kg) per month
        of hazardous waste.

        CFR—Code of Federal
        Regulations
        The CFR is a codification of the
        general and permanent rules pub-
        lished in the Federal Register by
        the Executive departments and
        agencies of the federal govern-
        ment.  The CFR is divided into 50
        "titles," which represent broad
        areas  subject to federal regulation.
        Each title is divided  into chapters,
        which  usually bear the name of the
        issuing agency.

        Commercial Chemical
        Product
        A chemical substance that is man-
        ufactured or formulated for com-
        mercial or manufacturing use.

        Container
        Any portable device  in which a
        material is  stored, transported,
        treated, disposed of, or otherwise
        handled.
DOT—Department of
Transportation
Federal agency that oversees all
national transportation systems
and regulates the transport of
hazardous materials.

Elementary  Neutralization
Unit
A tank, tank system, container,
transport  vehicle, or vessel (includ-
ing ships) that is designed to con-
tain and neutralize corrosive
waste.

Implementing Agency
EPA regional office or state agency
responsible for enforcing the haz-
ardous waste regulations.
Incompatible Waste
A hazardous waste that can cause
corrosion or decay of containment
materials, or is unsuitable for co-
mingling with another waste or
material because a dangerous
reaction might occur. See 40 CFR
Part 265, Appendix V for more
examples.

LDR—Land Disposal
Restrictions
The LDR program ensures that
toxic constituents present in haz-
ardous waste are properly treated
before hazardous waste is dis-
posed of in the land (such as in a
landfill).
26

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LQG—Large Quantity
Generator
A business that generates more
than 2,200 Ibs (1,000 kg) per
month of hazardous waste.

MICE—Methods Information
Communication Exchange
The MICE service provides
answers to questions about test
methods used to determine
whether a waste is hazardous.  It
also takes comments on technical
issues regarding EPA's methods
manual known as Test Methods for
Evaluating Solid Waste:
Physical/Chemical Methods (SW-
846).

MSDS—Material Safety Data
Sheets
Chemical manufacturers and
importers prepare detailed techni-
cal  bulletins called Material Safety
Data Sheets about the hazards of
each chemical they produce or
import. Your suppliers must send
you an MSDS at the time of the
first shipment of a chemical and
anytime the MSDS is updated
with new and significant informa-
tion about the hazards. MSDSs
include information about compo-
nents and contaminants, including
exposure limits, physical data, fire
and explosion hazard, toxicity, and
health hazard data. It also discuss-
es emergency and first aid proce-
dures and information about
storage and disposal, and  spill  or
leak procedures.
NFPA—National Fire
Protection Association
NFPA's mission is to reduce the
worldwide burden of fire and other
hazards  on the quality of life by
providing and advocating scientifi-
cally based codes and standards,
research, training, and education.
NFPA has specific rules for storing
hazardous wastes.

PBT—Persistent,
Bioaccumulative, and Toxic
Persistent chemicals are those
that don't readily break down in
the environment and can be trans-
ferred among air, water, soils, and
sediments. Bioaccumulative  chemi-
cals are  those that concentrate  in
animal and plant tissues as a
result of uptake from the surround-
ing environment or as a  result of
one organism consuming another.
Toxic chemicals, in this context,
are those that are hazardous to
human health and the environ-
ment. EPA has  been tasked with
focusing on reducing the toxicity of
wastes in addition to the quantity
of waste, and its Waste
Minimization National Plan focuses
on reducing PBT wastes.

POTW—Publicly Owned
Treatment  Works
A municipal wastewater treatment
plant that receives wastewater
through the public sewer from
households,  office buildings, facto-
ries and industrial facilities, and
other places where people live and
work.
Reclaimed Material
Material that is regenerated or
processed to recover a usable
product. Examples are the recov-
ery of lead values from spent bat-
teries and the regeneration of
spent solvents.

Recovered Material
A material or byproduct that has
been recovered or diverted from
solid waste. Does not include
materials or byproducts generated
from, and commonly used within,
an original manufacturing process.

Recycled Material
A material that is used, reused, or
reclaimed.

Reused Material
A material that is employed as an
ingredient in an industrial process
to make a product, or is used as
an effective substitute for a com-
mercial product.

Spent Material
Any material that has been used
and, as a result of contamination,
can no longer serve the  purpose
for which it was produced without
first processing it.

SQG—Small Quantity
Generator
A business that generates
between 220 and 2,200 Ibs (100
and 1,000 kg) per month of haz-
ardous waste.
                                                                                                          27

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        Sludge
        Any solid, semi-solid, or liquid
        waste generated from a municipal,
        commercial, or industrial waste-
        water treatment plant, water supply
        treatment plant, or air pollution
        control facility, exclusive of the
        treated  effluent from a wastewater
        treatment plant.

        Still Bottom
        Residue or byproduct of a distilla-
        tion  process such as solvent
        recycling.

        Tank
        A stationary device designed to
        contain  an accumulation of haz-
        ardous waste and 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 waste that is directly
connected to an industrial produc-
tion process and that is construct-
ed and operated to prevent the
release  of hazardous waste  into
the environment during treatment.
An example is a pipe in which
waste acid is neutralized.

TCLP—Toxicity
Characteristic Leaching
Procedure
A testing procedure used to  deter-
mine whether a waste is haz-
ardous.  The procedure identifies
waste that might leach hazardous
constituents into ground water if
improperly managed.
TSDF—Treatment, Storage,
and Disposal Facility
Refers to a facility that treats,
stores, or disposes of hazardous
waste; TSDFs have specific
requirements under RCRA.

VOCs—Volatile Organic
Compounds
VOCs are highly evaporative organ-
ic gases that can be produced dur-
ing the manufacture or use of
chemicals such as paints, sol-
vents, and cleaners. Various pollu-
tion control devices can prevent
the release of VOCs both outdoors
and indoors.

Wastewater Treatment Unit
A tank or tank system that is sub-
ject to regulation under either
Section 402 or 307(b) of the
Clean Water Act, and that treats or
stores an influent wastewater that
is hazardous waste, or that treats
or stores a wastewater treatment
sludge that is hazardous.
28

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