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Hazardous Waste Law

Hazardous Waste Law. Class 2: The RCRA Regulatory Scheme. Key Policies. Cradle to Grave Approach Reduce Reuse Recycle How are we protecting Impact on business community What about consumers. Big Picture. Is it a waste If so, who must care: “Generators” Transporters Disposers

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Hazardous Waste Law

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  1. Hazardous Waste Law Class 2: The RCRA Regulatory Scheme

  2. Key Policies • Cradle to Grave Approach • Reduce • Reuse • Recycle • How are we protecting • Impact on business community • What about consumers

  3. Big Picture • Is it a waste • If so, who must care: • “Generators” • Transporters • Disposers • You and me • What must be done: handle, transport & dispose of with care.

  4. Is it Hazardous waste or one person’s garbage is another’s treasure…. • A hazardous waste is a solid waste, this is: any solid, liquid, or contained gaseous material that is discarded by being disposed of burned or incinerated, or recycled (with a few exceptions for recycling). • 40 C.F.R. Section 261 - recycling

  5. Has a Congress person gotten you off the hook? Exclusions from RCRA’s cradle to grave: • Domestic sewage or mixtures through POTW • Industrial waste water discharges permitted under CWA • Mining wastes • Household waste not hazardous waste • Solid wastes generated by Ag (plant material and animal manure) and land applied • Universal wastes – household batteries, etc.

  6. What makes a solid waste hazardous? A “listed” waste: • known to be harmful to human health and the environment when not managed properly. • 40 C.F.R. Part 261 - 263 • Over 500 listed wastes

  7. Just cause it ain’t listed doesn’t mean its not hazardous Characteristic Wastes: • Ignitable • Paints, degeasers, solvents, fuels • Corrosive • Rust removers, cleaning fluids, battery acid • Reactive • cyanide • Toxic • Heavy metals like mercury and lead • TCLP: appropriate scenario?

  8. One bad apple… • The Mixture Rule – Dillution is not the solution to pollution • Mixing hazardous waste with solid waste & mixture exhibits characteristics of hazardous waste • Mixture of solid waste and listed hazardous waste • The Derived From Rule • Any solid waste derived from the TSD of hazardous waste

  9. Generators • Category • Small, medium or large • 2% of generators produce over 99% waste • Degree of regulation varies based on amount • Requirements • Determination & EPA ID Number • Manifest • Packaging & Labeling: DOT Regulations • Record Keeping • Storage requirements, time & quantity limits

  10. Transporters • DOT Hazardous Materials Transportation Act • Manifest • Permits, routing, placards, labeling, container specifications, spill cleanup • Transporters as generators and vice versa

  11. TSD Requirements • Land Ban: NO Haz waste can be land disposed unless: • Specific finding of no adverse effect • Pretreatment to reduce adverse effects • Type specific • Landfills • Double liners • Leachate collection • Groundwater monitoring • Record keeping • Closure • Financial Assurance

  12. What happens when its too complicated and too expensive?

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