1. Hazardous Waste Management
Legislation
RCRA – Resource Conservation and Recovery Act
Regulate management and disposal of wastes currently being produced
CERCLA – Comprehensive Environmental, Response,
Compensation, and Liability Act
(Often called Super-Fund)
Deals with clean-up of old or pre-existing hazardous waste problems
And clean-up of spills
TOSCA – Toxic Substances Control Act
Prevention of the creation of hazardous wastes and PCB clean-up

2. RCRA Mandates “cradle-to-grave” management of Hazardous wastes
Every organization that manages hazardous wastes must
notify EPA and receive an Identification number
Hazardous wastes are monitored by the Hazardous
Waste Manifest System

3. Uniform Hazardous Waste Manifest Generators create Uniform Hazardous
document
Manifest must
Accompany waste
At all times, from
Generation to
disposal

4. What Constitutes a Generator?
Anyone classified as a small or large quantity generator
must start the manifest document
So anyone generating more than 100 kg/month
Has to comply with the Uniform Hazardous Waste
Manifest process
Manifests must also be created if > 10 kg/month of
acutely toxic wastes are generated
Generators ID number must accompany the waste
at all times

5. Transporter
Storage
Treatment
Disposal
TSD

7. CERCLA Establishes responsibility for waste clean-up
Generators ultimately responsible
Liability is “strict” according to CERCLA
Don’t have to prove an action was irresponsible to
estabish responsibility
Liability is “Joint and Several”
A generator may be held responsible more than “his fair share”
Deep pocket
Liability is retroactive

8. Results
More “on-site” disposal
Why?

9. Clean-up of Old Sites Evaluation Hazard Ranking System (HRS)
1 Potential health effects
2 Potential for fammability & explosion
3 Potential for direct contact with waste
HRS score
Based on HRS score sites are prioritized
National Priority List (NPL)
2200 sites on NPL
~40 have been cleaned up
In addition, 110 DOE sites
17,000 DOD sites

10. Steps to Clean-up Sites on NPL
1) RI/FS (Remedial Investigation/Feasibility Study)
Define Problem
Investigate alternative solutions
Determine a recommended solution
2) Public Meetings
3) ROD (record of decision)
Choose alternative solution