FACTS ABOUT
  RCRA
                           REGULATING
                 HAZARDOUS  WASTE
                              FACILITIES
Hazardous  Waste

        Hazardous wastes are generated by thousands of com-
        mercial, industrial and governmental operations across
        our nation. Every state has hazardous waste producers,
        and waste is often transported through several states
        before it is ultimately disposed of, treated, or recycled.
        Hazardous wastes can be in numerous forms: solid,
liquid, or sludge, and the nature of their hazardous characteristics
are varied. Under the federal Resource Conservation and Recovery
Act (RCRA), a waste is "hazardous" if it exhibits any  of the
following characteristics: ignitability, corrosivity, reactivity or
toxicity. The U.S. Environmental Protection Agency (EPA) has
made the determination that certain wastes are hazardous and has
published a list of these wastes. Thus, wastes fall under the RCRA
hazardous waste regulatory program if they are "listed" by EPA or
exhibit any of the four characteristics of a hazardous waste.  Under
RCRA, facilities which treat, store, dispose of, or recycle hazard-
ous wastes — so-called 'TSDR facilities"— must meet strict tech-
nical and performance requirements.

"Cradle-to-Grave"  Management
   Prior to RCRA there was no national regulatory system for
tracking hazardous wastes and for establishing accountability of
waste management practices. Thus, wastes were often disposed of
by placing them into unsecured landfills or even by dumping on
roadsides and open fields, leaving no record of what the wastes
were or who had disposed of them.
   Under the "cradle-to-grave" system established under RCRA,
this situation has changed dramatically. The key to this system is
the uniform manifest program, illustrated in Figure 1, which keeps
strict tabs on hazardous wastes from their production (cradle) to
their disposal (grave). RCRA requires generators of solid wastes to
determine whether their wastes are hazardous as defined by the
EPA. If they are hazardous, the generator must obtain an EPA iden-
tification number for the facility and must comply with RCRA
regulations governing the safe handling of hazardous wastes while
they are handled at the facility.
   If the generator does not send wastes off site, a RCRA permit
must be obtained for managing the wastes on site. If the wastes are
transported off site (e.g., to a commercial TSDR facility), the
generator must prepare a manifest for each waste shipment which
identifies the waste, the generator, the transporter and the facility to
which the waste is being shipped. The manifest provides the basis
for tracking the waste through the entire transportation cycle,
including intermediate stops. If the wastes do not reach their in-
tended destination as scheduled, the generator must notify EPA or
the authorized state agency so that the situation can be investigated.
   The TSDR facility that is the ultimate repository of the wastes
                               — Continued on Pg. 2

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          "Cradle-to-Grave"
         Continued from Pg. 1
must meet strict technical and performance
standards to ensure that the wastes  are
handled in an environmentally protective
manner. The facility cannot receive haz-
ardous wastes unless it has  obtained a
RCRA operating permit from EPA or an
authorized state, or is in compliance with
"interim status"  standards specified  by
EPA or the state.  As will be explained
shortly, because  of the  time  required to
obtain a RCRA permit, TSDR facilities can
be authorized to manage hazardous wastes
under interim status if they meet  certain
waste  management requirements  estab-
lished by EPA.
    The RCRA "cradle-to-grave"  system
does not end with the secure arrival of the
waste at its intended TSDR facility. Re-
gardless of whether the TSDR facility is
operating under interim status or a permit,
the facility's owner does not have the op-
Con of simply closing down the facility and
walking away from it when he or  she no
longer wishes to handle waste or goes out of
business. UnderRCRA,theownermustbe
prepared to close the hazardous waste facil-
ity  under environmental requirements es-
tablished by EPA and must provide finan-
cial assurances to pay for proper closure
measures.  If the facility is to be closed by
removing wastes, the owner must demon-
strate that RCRA clean-up standards  are
met, which could involve an environmental
sampling and analysis program and site re-
mediation, as necessary. If the facility is a
land disposal operation and is  to be closed
with wastes left in place (e.g., placing a cap
over a landfill), the facility must continue to
monitor groundwater for at  least 30 years
after closure.
The Cradle:
Hazardous Waste

    Ninety-nine  percent  of hazardous
wastes are generated by  large quantity
generators, each producing over 1,000
kilograms of hazardous waste per month.
Ninety-six percent of these  wastes are
managed on site, requiring large quantity
generators to obtain  RCRA  permits as
TSDR facilities. The remaining four per-
cent have their wastes transported off site to
commercial TSDR facilities.
    About one million tons are produced
each year  by  small quantity generators,
each producing 100 to 1,000 kilograms per
month. Small quantity generators typically
range from construction and automotive
repair firms, laundromats and dry cleaners,
to photographic processors and electro-
platers.
    Generators of less than 100 kilograms
per month are exempt from RCRA regula-
tions.  These generators most often have
their wastes transported  off site to be
treated or disposed of by commercial
TSDR facilities.
Transporting
Hazardous.Waste

    The  transportation  of hazardous
wastes is regulated by EPA and the Depart-
ment  of  Transportation (DOT).  EPA's
manifest system provides strict accounta-
bility for each shipment and confirms its
acceptance by the TSDR facility. DOT's
regulations establish standards for the safe
packaging and  handling of hazardous
wastes while in transit and for clearly mark-
ing the transporting vehicles. Most hazard-
ous waste is transported over highway and
rail, although water and air transportation
is sometimes used.
                                 Figure 1.
              The RCRA Hazardous Waste Management System
                                                      Storage Facility
      Transporter
                                                          EPA or
                                                          Authorized
                                                          State Agency
           Generator
                                                                                      EPA RCRA FACT SHEET

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The  Grave:
Hazardous  Waste
Treatment,  Storage,
Disposal  and
Recycling

    Often a facility requiring a RCRA
permit will have more than one type of
activity — treatment, storage, disposal or
recycling — on site. Figure 2 provides a
summary of the facilities active in 1985.
           Land Disposal was the most economical
           and commonly used method for disposing
           of hazardous waste until the 1984 amend-
           ments  to RCRA placed stringent limita-
           tions on the types of wastes which can be
           disposed of in or on the land. It is expected
           that the future use of land disposal will
           decrease significantly. The types of land
           disposal facilities in use are:

           • Landfills, units in which wastes are
           placed in or on the land and covered when
           fdled;
           • Surface impoundments, natural or man-
    Treatment,which
changes the character of haz-
ardous waste in order to render
it less hazardous, commonly
includes:

•  Incineration, or burning
hazardous wastes at high tem-
peratures in  order  to ensure
near-complete combustion;
• Biological and chemical
treatment of wastewaters;
• Steam-stripping technolo-
gies, which volatilize waste-
waters and capture hazardous
elements with air pollution
control equipment; and
• Solidification, which in-
volves mixing a stabilizing
agent (like cement) with haz-
ardous waste to create a solid
or impermeable material.
       2. Number of Active Facilities by Type of Technology
                                  TOTAL NUMBER OF
                                FACILITIES IN 1985 - 2959
                                  AS Facilities
                                  Commercial Facilities
        Treatment     Storage    Land Disposal   Recycling
Sou/o0: National Screening Survey, U. S. EPA, Office of Solid Waste, 1986
      Note: Some facilities have more than one process.
    Storage facilities  hold  hazardous
wastes for more than 90 days and must
apply for RCRA permits. Storage facilities
must meet RCRA standards for above- and
below-ground tanks and for storage of port-
able containers such as 55-gallon drums.

    Recycling facilities are used to treat
hazardous wastes to convert them to useful
materials, such as raw materials for manu-
facturing processes and saleable products.
There is a variety of recycling techniques,
including filtration and heat and chemical
treatment. Generators of hazardous waste
commonly recycle solvents,  acids  and
metals.
           made depressions or diked areas filled with
           water which can be used to treat, store or
           dispose of hazardous wastes;
           • Waste piles, noncontainerized accumu-
           lations  of  solid, nonflowing  hazardous
           waste;
           • Undergroundinjectionwells, consisting
           of steel and concrete-encased shafts placed
           deep in the earth for the injection of liquid
           hazardous wastes by force and under pres-
           sure; and
           • Land treatment, a disposal process in
           which hazardous waste is applied onto or
           incorporated into the soil surface. Natural
           microbes in the soil break down or immo-
           bilize the hazardous constituents.
More TSDR Sites

Needed

    Many existing contamination prob-
lems associated with hazardous wastes are
the result of disposal practices which pre-
dated the RCRA program. EPA is commit-
ted to ensuring that the unsound methods
which characterized much of the hazardous
waste management practices of the past
will not take place at facilities which are
regulated under  RCRA. EPA believes,
however, that the greater environmental
          threat comes from practices at
          facilities which are not regu-
          lated under RCRA, since they
          may not be complying with the
          performance  and  technical
          standards of RCRA TSDR fa-
          cilities.  Because of this con-
          cern, EPA is striving to assur:
          that there are a sufficient num-
          ber of RCRA-permitted facili-
          ties to provide capacity for the
          environmentally sound man-
          agement  of  all  hazardous
          wastes.
              Unfortunately, the lack of
          environmentally  sound re-
          gional and waste-specific treat-
          ment  and  disposal sites is al-
          ready aproblem. It is important
          that environmentally sound al-
          ternatives  to land disposal be
          put into place to  assure that
          there are safe, regulated places
          to put hazardous waste. Incin-
          eration is one such important
alternative.  More incinerators are needed,
particularly ones that can burn solids and
sludges  contaminated  by  hazardous
wastes.  This need will become even more
important as more solids and sludges are
added to the hazardous waste system as a
result of contaminated site clean-ups under
Superfund and RCRA.
    Technologies exist to safely treat and
dispose of wastes, but siting and permitting
the facilities which will employ these tech-
nologies are difficult—it is not uncommon
to take three to five years to site, permit and
construct an incinerator.  More effective
siting and permitting are, therefore, among
the most important solutions to the capacity
problem.
REGULATING HAZARDOUS WASTE FACILITIES

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RCRA Permitting  of
TSDR  Facilities

    Undo- RCRA.  all existing TSDRs
must apply for a permit by November 1988
in order to continue operation. A RCRA
permit is a legally binding document which
establishes the hazardous waste manage-
ment activities which can be conducted at a
TSDR facility in accordance with RCRA
requirements. Permits limit these activities
and require specified measures (like moni-
toring and reporting). Violations of permit
conditions are subject to enforcement ac-
tions  by  EPA or  the authorized  state
agency.
    Many TSDR facilities are operating
today  without a  final permit,  but  have
"interim status"  under RCRA.  When
RCRA began, interim status was given to
facilities which submitted the first pan of
the  two-pan RCRA permit application,
including basic information about the haz-
ardous waste they manage and descriptions
of each waste management unit at the facil-
ity.  Interim status does not  apply indefi-
nitely  — the RCRA amendments of 1984
established a schedule for TSDR facilities
to receive operating permits: November
1988 for land disposal facilities,  Novem-
ber  1989 for hazardous waste incinerators
and November 1991 for all other facilities.
    To receive an  operating permit the
facility must submit a highly detailed appli-
cation, called the "Pan B" application,
which includes  technical  information
about the facility's hazardous waste activi-
ties, measures proposed to ensure compli-
ance with RCRA requirements, and dem-
onstrations that these measures are  suffi-
cient to ensure protection of human health
and the environment
    Once a Pan B application is found to
fully meet RCRA requirements, EPA or the
state prepares a draft RCRA permit which
specifies all  proposed hazardous waste
activities to be allowed at the facility and
includes conditions and stipulations appli-
cable to these activities. Each permitted
facility must meet  RCRA requirements
designed specifically for that  facility's
environmental conditions. These require-
ments include, for example, procedures for
analyzing  wastes,  technology  require-
ments,  recordkeeping and  reporting re-
quirements, and a contingency plan estab-
lishing emergency response procedures.
    An opportunity for public review and
comment on a draft RCRA permit must be
provided before any final  decisions are
made by the  regulatory agency to issue a
final permit This can include a  public
hearing if interest in a hearing is requested
by any member of the public. EPA encour-
ages public participation throughout the
RCRA permitting process.


Suggested Readings

Solving the Hazardous Waste Problem:
EPA's RCRA  Program. U.S.  Environ-
mental Protection Agency, Office of Solid
Waste, EPA/530-SW-86-037, November
1986.
The  Hazardous  Waste  System, U.S.
Environmental Protection Agency, Office
of Solid Waste and Emergency Response,
June 1987.

1986 National Screening Survey of Haz-
ardous Waste Treatment, Storage, Dis-
posal and Recycling Facilities, U.S. Envi-
ronmental Protection Agency, Office of
Solid Waste, December 1986.

Hazardous Waste Regulation: The New
Era, by Richard C. Fortuna and David J.
Lennett, McGraw-Hill Book Company,
1987.

RCRA Hazardous Wastes Handbook,
7th Edition, Government Institutes, Inc.,
January 1987.

Standards  and  Interim  Status Stan-
dards  for Owners and Operators of
Hazardous Waste Treatment, Storage,
and Disposal Facilities. (Title 40, Code of
Federal Regulations, Parts 264 and 265).

For Further Information

    For further information, contact the
RCRA-Superfund  Hotline,  Office of
Solid Waste (WH-562),  U.S.  Environ-
mental Protection Agency, 401 M Street,
S.W., Washington, D.C. 20460. (800)424-
9346 (toll free) or (202) 382-3000.
    For information on specific aspects of
treatment, storage, disposal and recycling
facilities and on  where to obtain other
RCRA fact sheets, contact your EPA Re-
gional Office.
  EPA RCRA Fact Sheets

 Land Disposal
 Public Involvement
 The State and Federal Partnership
 Regulating Hazardous Waste
         Facilities
 Health & Risk Assessment
 Corrective Action
 Closure/Post Closure
 RCRA ICERCLA Comparison
 Enforcement
Official Bmjntts
Penalty for Prirate UM
$300

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