Laws and Regulations
The statutory map
This domain rewards candidates who can place a fact in the right statute quickly. RCRA (40 CFR 260–273) governs hazardous waste cradle to grave: identification (listed F, K, P, and U wastes plus the four characteristics - ignitability, corrosivity, reactivity, toxicity), generator status, accumulation, manifests, and land disposal restrictions. CERCLA is the release-and-cleanup statute: reportable quantities, the National Contingency Plan, and liability. SARA Title III/EPCRA is community right-to-know - emergency planning, release notification, MSDS/chemical inventory (Tier II), and Toxics Release Inventory reporting. The Clean Air Act covers NAAQS and state implementation plans, NESHAP/MACT, Title V permits, and the Risk Management Program; the Clean Water Act covers NPDES, stormwater, SPCC, and dredge-and-fill; TSCA covers PCBs, asbestos, lead, and new-chemical review; OSHA covers HAZWOPER, HazCom, and process safety management; DOT's 49 CFR 171–180 covers classification, shipping papers, packaging, placarding, and training.
Traps
Generator status depends on the rate of generation in a calendar month, not on how much sits in the accumulation area - questions blur monthly rate with the on-site cap. RCRA ignitability is a flash point below 140 °F, not 100 °F. DOT recurrent hazmat training is every three years, and HAZWOPER 40-hour training requires an annual 8-hour refresher. CERCLA reportable quantities (often 1 lb) are not EPCRA threshold planning quantities or TRI thresholds.
Rule of thumb
A generator producing 100–1,000 kg/month is a small quantity generator: 180-day accumulation (270 days if the TSDF is more than 200 miles away) and no more than 6,000 kg on site.