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 difficultit 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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