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Regulatory Information

Stop 09: Equipment Cleaning

Highlighted Topic:  Hazardous Waste Generation

Tour Stop 09These workers are cleaning an open process tank.  As they do so, they may well be generating hazardous waste.

RCRA, the Resource Conservation and Recovery Act, provides special requirements that cover the generation, storage, handling, and management of hazardous wastes. RCRA regulations are quite detailed and stringent, so it is important to fully understand your responsibilities here.  RCRA is a federal law, but may be implemented by your state environmental agency.

What is hazardous waste? First, it is waste – i.e. some "discarded material". Second, it is waste that is not covered by the Clean Air Act or Clean Water Act; that is, not air or water emissions. Third, it is waste that either 1) exhibits certain specific hazardous characteristics (e.g., is corrosive), or 2) is listed as a hazardous waste by EPA.

Under RCRA, facilities must determine if they generate hazardous waste, through waste testing or other means. If so, the facility must obtain an EPA identification number, and follow a series of specific recordkeeping, handling, and management requirements. These include:

  • cradle-to-grave tracking
  • proper labeling
  • proper storage
  • limited accumulation times (usually less than 90 days without a permit).

Other Regulatory Issues:

Maintenance activities will also likely generate air and/or water emissions, and so would be regulated by the Clean Air Act and Clean Water Act.