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PCEW: Hazardous and Non-Hazardous Waste Management and Disposal

PCEW · Work through your exam, one topic at a time.

All guide sections

Hazardous and Non-Hazardous Waste Management and Disposal

What the exam tests

Hazardous waste questions test the RCRA decision path: is it a solid waste, is it hazardous by listing or characteristic, who generates it, how it may be accumulated, and how it moves to disposal. Non-hazardous industrial and municipal wastes follow separate state and local rules.

Core rules

  • Solid waste includes discarded material, including some recycled materials.
  • Hazardous waste is listed F, K, P, or U, or exhibits a characteristic: D001 ignitability, D002 corrosivity, D003 reactivity, or D004–D043 toxicity. P- and U-listed wastes are discarded commercial chemical products; P-listed wastes are acute hazardous wastes.
  • Generator categories are VSQG below 100 kg/month, SQG from 100 to less than 1,000 kg/month, and LQG at 1,000 kg/month or more. Acute hazardous waste has a separate 1 kg/month trigger: more than 1 kg/month makes the generator an LQG.
  • Accumulation containers must be closed, labeled as hazardous waste, marked with the accumulation start date, compatible, and inspected. Satellite accumulation allows 55 gallons, or 1 quart of acute hazardous waste, at the point of generation.
  • The uniform hazardous waste manifest tracks waste from generator to transporter to TSDF. Land disposal restrictions apply before land disposal; universal waste and used oil have streamlined rules.

Worked example

A process generates 800 kg/month of non-acute hazardous waste and 2 kg/month of a discarded P-listed unused chemical. The non-acute total is below the 1,000 kg/month LQG threshold, but the 2 kg/month acute waste exceeds the 1 kg/month acute trigger. The facility is an LQG and must apply LQG accumulation standards and manifesting, not SQG rules. The reasoning turns on the acute waste stream separately.

Traps

Treating pH exactly 12.5 as non-corrosive when D002 includes pH at or above 12.5; using flash point at or below 140°F instead of below 140°F; assuming an empty container is automatically unregulated; mixing hazardous and non-hazardous waste; treating satellite accumulation as 90- or 180-day storage; and treating the manifest as proof of disposal.