1. CE/Geol/ChE 174 Hazardous Materials
Requirements for Generators
Christopher Vais

2. Important Definitions
Facility
Treatment
Disposal

3. Important Definitions
Generator
person, by site, whose act or process produces hazardous waste
Transporters
Treatment, Storage, and Disposal Facilities (TSDF’S)

4. Conditionally Exempt Small Quantity Generators
Conditionally Exempt Small Quantity Generators (CESQG) generate 100 kilograms or less per month of hazardous waste, or 1 kilogram or less per month of acutely hazardous waste. Requirements for CESQGs include (see also 40 CFR 261.5): CESQGs must identify all the hazardous waste generated. CESQGs may not accumulate more than 1,000 kilograms of hazardous waste at any time. CESQGs must ensure that hazardous waste is delivered to a person or facility who is authorized to manage it.

5. Small Quantity Generators
Small Quantity Generators (SQG) generate more than 100 kilograms, but less than 1,000 kilograms, of hazardous waste per month.
Requirements for SQGs include:
SQGs may accumulate hazardous waste on site for 180 days (or 270 days if shipping a distance greater than 200 miles).
The quantity of hazardous on site waste must never exceed 6,000 kilograms.
There must always be at least one employee available to respond to an emergency and be responsible for coordinating all emergency response measures.

6. Large Quantity Generators
Large Quantity Generators (LQG) generate 1,000 kilograms per month or more of hazardous waste, or more than 1 kilogram per month of acutely hazardous waste.
Requirements for LQGs include:
LQGs may only accumulate waste on site for 90 days.
LQGs do not have a limit on the amount of hazardous waste accumulated on site.
There must always be at least one employee available to respond to an emergency.
LQGs must have detailed, written contingency plans for handling emergencies. LQGs must submit a biennial hazardous Waste report.

7. Requirements for Generators
Notification
Characterize waste
Obtain ID number
Use manifest
Minimize waste
Prepare waste for shipment

8. Requirements for Generators
Write reports
Exporting waste
Categories of generators
Large quantity generators
kg/m generators
Conditionally exempt small quantity generators

9. Manifest System The Hazardous Waste Manifest System is a set of:
1. Forms,
2. Reports, and
3. Procedures
designed to seamlessly track hazardous waste from the time it leaves the generator facility where it was produced, 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 properly delivered, and that no waste has been lost or unaccounted for in the process.

10. Manifest System
All hazardous waste shipped off-site be tracked from "cradle-to-grave" using a manifest that provides information about:
The generator of the waste,
The facility that will receive the waste,
A description and quantity of the waste (including the number and type of containers), and
How the waste will be routed to the receiving facility.
Because hazardous waste is also regulated by the DOT under its hazardous materials laws, the manifest meets both EPA’s requirements for a manifest, and DOT’s requirements for "shipping papers."

11. Manifest System WARNING
Each party that handles the waste signs the manifest and retains a copy for themselves.
WARNING
Never sign any manifest on the behalf of the generator with a written authorization to do so. If you do you will place yourself and/or the company you work for in the “chain of liability” from which there is little chance of escape

12. Hazardous Waste Manifest

13. RCRA Manifest System-Forms
Handlers of waste (generators, or treatment, storage or disposal facilities) must obtain manifest forms from any source that has been approved by the EPA Manifest Registry to print and distribute the form.
The Table of Approved Registrants is a list of printers approved by EPA to print RCRA hazardous waste manifests.
The table provides information on how to contact organizations to obtain forms. Expect to spend between $0.21 and $1.00 per form.

14. RCRA Manifest System-Additional State Requirements
A number of States have additional State requirements regarding the use of the Uniform Hazardous Waste Manifest.
Some States require copies to be submitted to the State, and/or have State-specific waste codes in addition to the federal hazardous waste codes required to be entered on the new manifest.
A copy of the manifest does not go to the United States Environmental Protection Agency.

15. RCRA Manifest System-Additional State Requirements
Copy of Manifest goes to State:
Alabama, Arizona, California, Connecticut, Delaware, Illinois, Maine, Maryland, Massachusetts, Michigan, Minnesota, New Hampshire, New Jersey, New York, North Dakota, Pennsylvania, Utah, Vermont, Wisconsin.
Copy of Manifest DOES NOT go to State:
Alaska, Arkansas, Colorado, Florida, Georgia, Hawaii, Idaho, Indiana, Iowa, Kansas, Louisiana, Mississippi, Montana, Nebraska, New Mexico, North Carolina, Ohio, Oklahoma, Oregon, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Virginia, Washington, West Virginia, Wyoming.

16. RCRA Manifest System-Scanned Manifests
40 C.F.R.§ (a) and §262,23(a) require generators to provide that the "signed" manifest copies bear the handwritten signatures of the generator, transporter, and the owner/operator of the designated facility.
Electronically stored image files qualify as "copies" bearing the necessary "handwritten" signatures. meet this standard, because:
1.The handwritten signatures from the hard copy records are captured by the scanner, incorporated into the stored image files, and reproduced accurately.
2.The image files meet the standards included in the Federal Rules of Evidence

17. Manifest System Generators: Item 1. Enter the generator’s twelve digit
RCRA generator number.
Item 2. Enter the total pages of the completed
manifest.
Item 3. Enter an emergency response 24-
hour phone number.
{See Item 3 Note}
Item 4. This block must have the preprinted
manifest number printed by the forms
printer.

18. Manifest System-Emergency Contact
Item 3 Note.
If the telephone number of an emergency response information telephone number service provider is entered on a shipping paper, then the shipping paper must also identify the person (by name or contract number) who has the contractual agreement with the service provider. 
In addition, the name of the person identified with the emergency response telephone number must be entered on the shipping paper immediately before, after, above, or below the emergency response telephone number unless the name is entered elsewhere on the shipping paper in a prominent, readily identifiable, and clearly visible manner that allows the information to be easily and quickly found.”

19. Manifest System Generators
Item 5. The generator’s name and address to which the completed
manifest should be mailed, including the generator’s normal
business telephone number.
Also add the physical site address from which the shipment
originates, if this address is different than the mailing address.
Item 6. Transporter name and RCRA I.D. number of the first
transporter who will transport the waste.
Item 7. If applicable the name and RCRA I.D. of the second transporter
if appropriate. If a third, or more, transporters are used, then use
EPA Form A(Continuation Sheet) for these
transporters.

20. Manifest System Generators:
Item 8. Enter the company name and site address of the facility to
receive the waste. Also enter the facility’s phone number and RCRA I.D. number.
Item 9a. If the waste listed in Item 9b is made up of both hazardous and non-hazardous materials, the identify the hazardous materials by entering an “X” in this Item next to the hazardous material identified in Item 9b.
Item 9b. Enter the DOT Proper Shipping Name, Hazard Class or
Division, Identification Number (UN/NA) and Packing Group for each waste as identified in 49 CFR Part 172

21. Manifest System Generators:
Item 10. Enter the number of containers for each waste and the
appropriate abbreviation for the type of container.
TABLE I.—TYPES OF CONTAINERS
BA = Burlap, cloth, paper, or plastic bags.
CF = Fiber or plastic boxes, cartons, cases.
CM = Metal boxes, cartons, cases (including roll-offs).
CW = Wooden boxes, cartons, cases CY = Cylinders.
DF = Fiberboard or plastic drums, barrels, kegs.
DM = Metal drums, barrels, kegs DT = Dump truck.
DW = Wooden drums, barrels, kegs.
HG = Hopper or gondola cars TC = Tank cars.
TT = Cargo tanks (tank trucks) TP = Portable tanks

22. Manifest System Generators:
Item 11. Enter the total quantity of waste, do not enter decimals or
fractions. Using appropriate units of measurement. Use actual
measurements or reasonably accurate estimates. Container
capacities are not acceptable as estimates.
Item 12. Use the following abbreviation for the unit of measure:
TABLE II.—UNITS OF MEASURE
G = Gallons (liquids only). K = Kilograms. L = Liters (liquids only).
M = Metric Tons (1000 kilograms). N = Cubic Meters.
P = Pounds. T = Tons (2000 pounds). Y = Cubic Yards.
Note: Tons, Metric Tons, Cubic Meters, and Cubic Yards should only
be reported in connection with very large bulk shipments, such
as rail cars, tank trucks, or barges.

23. Manifest System Generators:
Item 13. Enter up to six federal and state waste codes to describe each
waste stream identified in Item 9b. State waste codes that are
not redundant with federal codes are entered here. Use the
waste codes that are most representative of the properties of
the waste.
Item 14. Enter any special handling or shipment-specific information
necessary for the proper management or tracking. Also use
this space for any other necessary chemical information.
Note: This space may be used for federally required information
where there is no specific space provided for on the manifest.

24. Manifest System Generators: Item 15. Generator’s certifications.
This is where the generator must read, sign and date the waste minimization certification statement. This is where the generator is also certifying that the shipment has been properly prepared and is in proper condition for transportation.
Basically this is where you are swearing that the manifest is true and correct, and the materials are what you say they are, and are in proper containers, correctly marked and placarded.
Note: The person signing the manifest may preprint the words
“On behalf of” in the signature block to indicate that they
are signing as the employee or agent of the named
principal.

25. Manifest System Generators:
Item 16 This item is for the International Shipment of Hazardous
Waste. {See next Section}
Item 17. Enter the name of the person accepting the waste on behalf of
the first transporter. This person must sign and date the
manifest acknowledging acceptance of the waste.
If applicable, enter the name of the person accepting the waste
on behalf of the second transporter.
If all goes well the generator is finished with the manifest, other than
checking for discrepancies with the returned copy.

26. Transboundary Shipments Revised rule is effective in all States on July 7, 2010
Transboundary Shipments of Hazardous Wastes Between OECD (Organization for Economic Cooperation and Development) Member Countries,
Export Shipments of Spent Lead-Acid Batteries,
Submitting Exception Reports for Export Shipments of Hazardous Wastes, and Imports of Hazardous Wastes

27. Does This Rule Apply To Me?
The revisions regarding the OECD in this final rule affect all persons who: 1. export or import hazardous waste, 2. export or import universal waste, or 3. export spent lead-acid batteries (SLABs) destined for recovery operations in OECD Member countries, except for Mexico and Canada.

28. Recovery/Recycling
The requirements apply to imports and exports of wastes considered hazardous under RCRA and are destined for recovery operations in the countries listed in 40 CFR § (a)(1).
40 CFR § (a)

29. Canada and Mexico
Any transboundary movement of hazardous wastes between the United States and Mexico or Canada will continue to be governed by their respective bilateral agreements and applicable regulations.

30. Canada
U.S. exports of intact SLABS to Canada for recycling will be prohibited starting on July 7, 2010 unless the new notice and consent process is completed.
There are two options available.

31. Canada Option No. 1
U.S. exporter submits an export notice to EPA, referencing the Canadian notice number for the corresponding Canadian import notice (if available). • At the same time, the Canadian receiving facility submits a new import notice to EC. • EC will coordinate its reviews of both notices and specify identical approval periods for the export and the import as appropriate, usually for the maximum allowable period (twelve months).

32. Canada Option No. 2
U.S. exporter submits an export notice to EPA and provides the notice number issued by EC to the Canadian facility. • EC will use the import notice number to expedite its review and provide its consent for the remaining approved period of import permit.

33. What Do I have to Do?
The level of control is indicated by assignment of the waste to a list of wastes subject to Green control procedures or a list of wastes subject to Amber control procedures AND by the national procedures of the United States, as defined in 40 CFR § (a). The OECD Green and Amber lists are incorporated by reference in 40 CFR § (d).

34. Exception Reporting
There is no specific time limit for a hazardous waste shipment to reach the designated facility.
If a large quantity generator (LQG) does not receive a signed copy of the manifest from the designated facility within 35 days of the date the initial transporter accepted the waste, the generator must contact the transporter and the owner or operator of the designated facility to determine the status of the waste
If a copy of the manifest is not received within 45 days then the LQG must submit an Exception Report to the EPA Regional Administrator.
If a copy of the manifest is not received within 60 days then the SQG must submit a legible copy of the manifest, with some indication that the generator has not received confirmation of delivery, to the EPA Regional Administrator for the Region in which the generator is located.

35. Manifest System for Exports
Generators:
Item 16. Export of Hazardous Waste
The primary exporter must check the export box on the manifest, and enter the point of export {city and state} from the United States.
Transporters:
The transporter must sign and date the manifest to show the day it left the United States.
The transporter must also deliver a copy of the manifest to the U.S. Customs.

36. Satellite Accumulation
Can accumulate up to 55 gallons of non-acute hazardous waste or one quart of acute hazardous waste.
The satellite accumulation area must be at or near the point of generation.
The satellite accumulation area must be under the control of the operator of the process generating the waste.

37. Satellite Accumulation
Required to date the containers when the quantity limits are reached.
Remove the hazardous waste to the main hazardous waste storage area or ship the wastes off-site within 3 days of reaching the above limits.
Keep the containers closed except when adding or removing wastes; and
Mark the containers with either the words “Hazardous Waste” or with other words that identify the contents of the container.

38. Satellite Accumulation
On December 3, 2009, USEPA published a guidance document on the matter of closed containers.
It explicitly sanctions the practice of affixing a funnel to the bung of a drum to which hazardous waste will frequently be deposited, with the caveat that the funnel be equipped with engineering controls to seal the drum and prevent spills.

39. Important Dates in Satellite Accumulation
1.Keep track of the date when the container was place in use in the Satellite Accumulation Area for internal purposes. 2. Date the containers when the quantity limits are reached. 3. Date the container when it is moved to the Central Accumulation Area., 4. The date by when the hazardous must be moved off-site.

40. Satellite Accumulation
States may change this rule: For Example
Ohio-Follows the federal rule.
Colorado-Must move the filled container within 24 hours to regular storage area.
California-Must have the material off-site within 12 months.

41. Central Accumulation Area
Hazardous Waste Containers must be stored under cover:
Outdoors a designated area preferably covered
If uncovered rainfall coming in contact with the containers must be captured and may require treatment as a hazardous waste
Indoors in a area dedicated space

42. Requirements for Storage Area
Must be covered
Must have an impervious surface on which the hazardous waste containers are placed
Storage surface should have secondary containment such as a berm or drains connected to a sump
Hazardous Waste Containers should not be allowed to sit in standing water
There should be no viable pathway by which leaking hazardous waste can reach the environment

43. Hazardous Waste Storage Containers

44. Hazardous Waste Label

45. Hazardous Waste Label
Must be completely filled out with the applicable generator name and address and Generator ID number
The accumulation start date is the date when hazardous waste was first placed in the container
Waste physical state must be noted (solid or liquid)
Hazardous characteristics specified (flammable, corrosive, reactive, toxic
Waste composition
If a listed waste, provide the list number i.e. F-032

46. Storage Considerations
Maintain adequate aisle spacing
Do not store incompatible wastes in close proximity to one another
Do not stack drums containing liquid waste
Store in a manner that permits full access to the hazardous waste labels
Do not store hazardous waste with new product