Environmental Management
Waste, from cradle to grave
RCRA keeps the generator in the chain of custody. First make a waste determination - by process knowledge or testing - and classify the waste as listed (F, K, P, U), characteristic (ignitable, corrosive, reactive, toxic), or non-hazardous. Generator status drives the requirements:
- Very small quantity generator: under 100 kg per month.
- Small quantity generator: 100 to 1,000 kg per month; accumulate no more than 180 days (270 if shipping over 200 miles) and no more than 6,000 kg on site.
- Large quantity generator: over 1,000 kg per month; 90-day accumulation, biennial reporting, formal training.
Hazardous waste shipped off site moves on a uniform manifest; keep copies for three years. Universal wastes (lamps, batteries, mercury devices) and used oil have streamlined rules but are not unregulated.
Air, water, and reporting
EPCRA requires an annual Tier II inventory report by March 1 for facilities holding 10,000 pounds or more of a hazardous chemical, or 500 pounds (or the threshold planning quantity) for an extremely hazardous substance. Releases of CERCLA hazardous substances above a reportable quantity go to the National Response Center. TRI Form R is due July 1. SPCC plans apply to oil storage above 1,320 gallons aboveground or 42,000 gallons underground; stormwater discharges require an SWPPP under an NPDES permit.
Traps
Items routinely blur EPCRA inventory thresholds with CERCLA release reporting, or misapply accumulation times. Pollution prevention ranks source reduction above recycling, treatment, and disposal.
Worked example
A plant generates 800 kg of hazardous waste per month. That falls between 100 and 1,000 kg, making it a small quantity generator: 180-day accumulation and a manifest are required.