Waste minimization not only protects the environment; it also makes good economic and business sense. For example, reducing waste generation through waste minimization has helped some companies change their RCRA regulatory status from large quantity generators (1000 or more kilograms of hazardous waste generated per month) to small quantity generator (between 100 and 1000 kg of hazardous waste generated per month), or to conditionally exempt small quantity generators (up to 100 kg of hazardous waste generated per month). Some have managed to eliminate the generation of hazardous waste and avoid RCRA regulatory requirements altogether.
Source reduction and/or environmentally sound recycling, reuse, and reclamation practices have helped many organizations reduce:
- The quantity and toxicity of hazardous and solid waste generation;
- Raw material and product losses;
- Raw material purchase costs;
- Waste management recordkeeping and paperwork burden;
- Waste management costs;
- Workplace accidents and worker exposure;
- Compliance violations; and
- Environmental liability.
At the same time, waste minimization can improve:
- Production efficiency;
- Good neighbor image;
- Product quality; and
- Environmental performance
Waste Minimization is EPA’s preferred approach to protecting the environment. It refers to the use of source reduction and/or environmentally sound recycling methods prior to treating or disposing of hazardous wastes. Waste minimization includes: source reduction practices that reduce or eliminate waste generation at the source and environmentally sound recycling practices where source reduction is not economically practical. Waste minimization does not include waste treatment, i.e., any process designed to change the physical, chemical, or biological character or composition of a hazardous waste, or waste disposal. For example, compacting, neutralizing, diluting, or incineration are not waste minimization practices.
Source reduction includes any practice that reduces the quantity and/or toxicity of pollutants entering a waste stream prior to recycling, treatment, or disposal. Examples include: equipment or technology modifications, reformulation or redesign of products, substitution of less toxic raw materials, improvements in work practices, maintenance, worker training, and better inventory control.
Recycling includes the use, reuse and/or reclamation of waste residuals (that may be designated as a hazardous waste) or materials in a hazardous waste. A material is “used or reused” if it is used as an ingredient in an industrial process to make a product or if it is used as an effective substitute for a commercial product. A material is “reclaimed” if it is processed to recover a usable product, or if it is regenerated.
Scenario: An individual operates a dry cleaning business that has been generating hazardous waste since 1980. A new owner buys the facility in June 2003 and assumes the generator responsibilities, which includes keeping records of hazardous waste activities (e.g., signed manifests) for at least three years from the time the waste was first sent off site (40 CFR Section 262.40).
Question: Must the new owner or operator keep the records from the previous generator’s activities for a period of three years or does the new owner or operator begin the recordkeeping process on the date the individual becomes the generator (i.e., June 1, 2003)?
Answer: The new owner or operator must maintain records from the previous three years of activities at the site, not three years from the date on which the individual assumes the generator responsibilities. The requirement to have generators retain records of previous site activity for three years is not an unreasonable burden since most generators opt to keep copies for their own records. These records may demonstrate proper management of the waste by the generator should there be a problem in subsequent transportation, handling, or disposal (51 FR 10146, 10159; March 24, 1986). Therefore, in this scenario, records of hazardous waste sent off site from this facility in March 2002, prior to the ownership change, should remain in the new owner’s records until March 2005.
The amount of waste per MONTH determines generator status.
Question: An individual generates 75 kg of non-acutely hazardous waste each month from January to November. Instead of shipping this waste off site for disposal, the generator accumulates the waste on site in containers. In December, the generator produces an additional 75 kg of non- acutely hazardous waste and hires a transporter to ship a total of 900 kg off site for treatment and disposal. Is this generator subject to the conditionally exempt small quantity generator (CESQG) requirements or the small quantity generator (SQG) regulations during the month of December?
Answer: This generator is subject to the CESQG regulations during the month of December because it generated no more than 100 kg of non-acutely hazardous waste in that month and accumulated no more than 1,000 kg of non-acutely hazardous waste on site at any one time (40 CFR §261.5). Generator status is based upon the amount of waste generated per calendar month and the total amount accumulated on site at any one time. The amount of waste shipped off site at any one time does not affect generator status, provided the waste is shipped off site prior to exceeding accumulation limits. If the generator accumulates more than a total of 1,000 kg of hazardous waste on site at any one time, then it would be subject to all provisions applicable to SQGs, including the § 262.34(d) accumulation standards.
In addition, this individual can generate 1 kg or less of acutely hazardous waste per calendar month and remain subject to the reduced CESQG regulations for the acutely hazardous waste, provided that no more than 1 kg of acutely hazardous waste is accumulated on site at any one time. If the amount generated or accumulated on site exceeds these thresholds, then all of the acutely hazardous waste would be subject to full regulation as applicable to large quantity generators (§261.5(e)).
An EPA ID # is a registration number provided by a delegated State Agency with the approval of the Federal Environmental Protection Agency. The ID # is assigned to a physical location. The business and the property owners are associated with the registration. The ID # registers a physical location and identifies it as a place where hazardous waste is generated. Furthermore, the location identifies the volume and type of hazardous waste generated at that location. The volume and type of hazardous waste will place the generator into their generator classification, conditionally exempt small quantity generator (CESQG), small quantity generator (SQG) or large quantity generator (LQG).
Transportation businesses that handle hazardous waste are also required to register their location and obtain and EPA ID #.
RCRA stands for the Resource Conservation and Recovery Act of 1976. Congress outlined four major programs in RCRA, including:
- Solid Waste (Subtitle D): Focuses on traditional non-hazardous solid waste, such as municipal garbage, medical waste and industrial waste that is not classified as hazardous waste;
- Hazardous Waste (Subtitle C): Requires EPA to develop and manage a nationwide program that identifies wastes that are hazardous and set standards for safely managing this waste from the moment it is generated, through storage, transportation, recycling, treatment, and ultimate disposal. Other components of the hazardous waste program are described here;
- Underground Storage Tanks (UST–Subtitle I): Requires EPA to establish standards for the design and operation of USTs to prevent leaks into the ground.