Q: What Is RCRA Hazardous Waste?
A: Wastes that exhibit certain characteristics may be regulated by RCRA (see 40 CRF Part 261). A waste may be considered hazardous if it is ignitable (i.e., burns readily), or if it is corrosive, or reactive (i.e., explosive). Waste may also be deemed hazardous if it contains certain amounts of specifically regulated toxic chemicals. In addition to these characteristic wastes, EPA has also developed a list of over 500 specific hazardous wastes. Hazardous waste takes many physical forms and may be solid, semi-solid, or even liquid.
Q: Whom Does The RCRA Hazardous Waste Program Regulate??
A: The RCRA hazardous waste program regulates commercial businesses as well as federal, state, and local government facilities that generate, transport, treat, store, or dispose of hazardous waste. Each of these entities is regulated to ensure proper management of hazardous waste from the moment it is generated until its ultimate disposal or destruction.
Q: If I Move My Facility To A Different Location, May I Still Use My Same Epa Id Number?
A: No, EPA ID numbers are site (location) specific. When a facility relocates, it should notify DEP so that the old number can be inactivated. If the facility moves to a location that has an existing identification number, the regulations require the facility to notify the DEP so that the existing number can be reactivated. If the new location does not have an EPA ID number, the facility must complete Form 8700-12 to renotify for the new location.Conditionally exempt small quantity generators (CDSQGs) are not required to notify.
Q: How Long Can I Store My Hazardous Waste?
A: That depends on how much you generate during one calendar month. Generally speaking, the storage requirements for a specific generator of hazardous waste can be confined to the following categories and criteria.
Conditionally Exempt Small Quantity GeneratorsGenerators of less than 220 lbs (100 kilograms) of RCRA hazardous waste per calendar month, or less than 2.2 lbs (1 kg) of acutely hazardous waste (i.e., hazardous waste with a p-code) in one calendar month are considered conditionally-exempt small quantity generators (CESQGs). These facilities additionally are limited to accumulating no more than 2,200 lbs (1,000 kg) of hazardous waste at any time.
Small Quantity Generators
Generators of less than 2,200 lbs (1,000 kilograms) of RCRA hazardous waste per calendar month, or less than 2.2 lbs (1 kg) of acutely hazardous waste (i.e., hazardous waste with a p-code) in one calendar month are considered small quantity generators (SQGs). These facilities are additionally limited to accumulating no more than 13,200 lbs. (6,000 kg) of hazardous waste at any time.
Large Quantity Generators – 90-day Storage Limit From Time Of Generati
Generators of greater than 2,200 lbs (1,000 kilograms) of RCRA hazardous waste per calendar month, or more than 2.2 lbs (1 kg) of acutely hazardous waste (i.e., hazardous waste with a p-code) in one calendar month are considered large quantity generators (LQGs). These facilities are additionally limited to accumulating no more than 2,200 lbs (1,000 kg) of hazardous waste at any time. Further requirements for LQGs include the preparation and implementation of an emergency response plan, training for response personnel, and submission of an annual hazardous waste report.
Q: Can I Throw The Green Tipped Fluorescent Bulbs In The Trash?
A: The green tipped fluorescent bulbs are “Eco-friendly” and were developed with much less mercury than the “old” type, this enables you to safely throw them in the trash.
Q: Can I Throw Waste Paint In The Trash?
A: Water based paints can be thrown in the trash ONLY if there are no free liquids. If there are free liquids in your water based paint, you can open the lids and let the paint dry or add some floor dry (kitty litter works great, too), stir until you have no free liquids, throw in trash. You CANNOT throw oil/solvent based paints in the trash, these must be properly disposed of as a hazardous waste.
Q: How Do I Know What Rating Of Drum I Need To Use?
A: There are three UN rated type drums. They are “X” rated, “Y” rated and “Z” rated drums. To determine which rating of drum you need, you must use the US DOT shipping table and find the exemption for the material you will be shipping. Find the exemption, (which follows the shipping table) and look-up what rating drum you need.
Q: What Is The Difference Between Generator Status?
A: A “Conditionally exempt small quantity generator” is a facility who generates less than 100 Kg of hazardous waste per calendar month OR less than 1 Kg of acutely hazardous waste per calendar month (P-listed waste). A “Small quantity generator” generates between 100 Kg and 1,000 Kg of hazardous waste per calendar month AND accumulates less than 6,000 Kg of hazardous waste at anytime. If you generate more than what is stated for “small quantity generator” than you are considered a ʻlarge quantity generator”. Your status as a generator can change depending on how much waste you produce in one calendar month.
Q: Can 2-propanol (Isopropyl Alcohol) Form Potentially Explosive Peroxides?
A: Yes, if it is at least HPLC purity.
Q: Can Potassium Metal Form Potentially Explosive Peroxides?
A: Yes, they actually form explosive super-oxides. If you have potassium that is red, purple, orange or any other colors then silver or white, these could be explosive super-oxides. These MUST be stabilized by reduction.
Q: What Is The Problem With Powder White Picric Acid (Trinitrophenol)?
A: In this phase, it is considered a high explosive. Only trained individuals should touch or move this. This material would need to be stabilized with water or a select solvent. Dry picric acid is considered a 1.1D explosive by US DOT.
Q: Why Is It Important To Have And Use A Fume Hood Wash Down System In A Fume Hood Where Perchloric Acid Is Being Used?
A: Most fume hood are made of sheet metal. When perchloric acid comes into contact with (sheet) metal, they form extremely explosive and unstable metal perchlorates. The entire fume hood would have to be decontaminated by trained experts.
What Is The Best Way To Store Peroxide Forming Solvents?
A: In an amber glass bottle or metal can, under nitrogen, and in a non-flammable storage cabinet. Do not store these solvents in clear glass jars, unmarked containers or in the refrigerator or freezer. For peroxides to form you need oxygen, so storing it under nitrogen deprives it of oxygen. Peroxides also need light to form, so storing the solvent in amber or opaque containers prevent light from entering the bottle. Two reasons not to store the solvent in the cold (i.e. refrigerator) is 1) if the solvent has an inhibitor, the cold actually will make the inhibitor useless and 2) if the solvent has peroxides, the mere temperature change can cause the peroxide bonds to break with explosive force.