What is RCRA?
RCRA refers to the Resource Conservation and Recovery Act of 1976, which is the public federal law that governs the management and disposal of hazardous waste. RCRA gives the EPA the authority to monitor hazardous waste from cradle to grave.
What are the types of RCRA listed wastes?
Hazardous wastes are RCRA listed as such because they are known to harm human health and the environment when improperly managed. These hazardous wastes are categorized into four different lists, F, K, P, and U lists.
F List – The F list designates certain wastes produced from common industrial or manufacturing operations. Since these operations can occur in different localities of each industry, these are wastes from non-specific sources.
K List – This list describes certain wastes from known sources and specific industries, like treatment wastewater or pesticide manufacturing. Certain wastes such as sludge and wastewaters derived from processes in these industries can be described as source-specific wastes.
P List – The P-list includes pharmaceuticals, discarded chemicals, and pesticides. This list encompasses all acute hazardous waste which is subject to stricter generator accumulation requirements.
U List – This list is nearly identical to the P list, however, U-listed wastes are considered to be less toxic than P-listed wastes.
What are the Characteristics of Hazardous Wastes?
Even when commercial waste doesn’t have the same qualities as those listed above, it can still be considered hazardous if it has any of the qualities listed below:
Ignitability – Materials or chemicals that can ignite at 140 degrees or lower can be considered hazardous and require proper transportation and disposal.
Reactivity – Reactive waste can change rapidly under normal handling conditions. Precautions should be taken when handling reactive materials to prevent dangerous reactions such as explosions, as well as the release of toxic fumes or gases.
Corrosivity – Any material with a pH level of less than 2 or greater than 12.5 could be considered corrosive. At these pH levels, metal containers can begin to corrode, creating the need for specialty, waste-disposal methods.
Toxicity – A substance that is harmful or fatal when exposed to any life forms can be considered toxic and therefore hazardous. It is vital to protect the environment by properly disposing of toxic waste to prevent the contamination of local water sources.
Do Hazardous Waste Generators need a RCRA Permit?
Hazardous waste generators are not required to have an RCRA permit, however, a permit is needed for any facility that facilitates the treatment, storage, and disposal of hazardous waste.
Are Hazardous Waste Generators Permitted to Treat their Waste On-site without Obtaining a RCRA Permit?
It is normally required to have a permit from the federal or state EPA before you treat hazardous waste. However, RCRA regulations allow hazardous waste generators to manage a few waste treatment activities without applying for a permit (with some limitations).
- Disassembling Equipment – The EPA allows universal waste handlers to disassemble e-waste to remove components that might contain hazardous materials. For example, the removal of cathode ray tubes, or CRTs from old televisions are allowed. Once removed, items such as CRTs, batteries, and mercury ampules can be managed as hazardous waste.
- Mixing a flammable or corrosive material with solids can cause them to lose their characteristics. Typically, diluting hazardous waste is prohibited, however, the EPA authorizes absorbent materials to be added to the hazardous waste as long as it is added to the container before or at the start of when the hazardous waste is accumulated, and not after.
What are the Authorized Penalties for Non-compliance with RCRA?
The EPA is authorized to issue civil penalties of up to $27,500 per day, per violation. Criminal penalties are also authorized under certain circumstances.
HTS is a premier provider of RCRA waste management services to businesses across many industries. Our certified field techs will develop a comprehensive plan that works for your specific waste disposal needs. Contact us today to learn how we can help you manage your waste in compliance with state and federal laws and regulations. We serve cities all across Southern California, providing our clients with unsurpassed service.