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Common Hazardous Waste Acronyms and Abbreviations

If I were going to stick with the old saying, I would say that “if you had told me a few years ago that I would one day have a job that required me to look up RCRA waste regulations on a regular basis I would have laughed in your face.” In reality though, I probably would have asked you what RCRA even stood for (for the record, it’s the Resource Conservation and Recovery Act).

Since working in this field I have realized that outside of those of us who deal with it on a regular basis, many people don’t know what the different abbreviations and acronyms associated with waste regulations and recycling. Luckily, at one of our RCRA courses I was given the following list of “Common Hazardous Material/Waste Acronyms and Recognized Abbreviations.”  Hopefully you will find the list as helpful as I do!

  • ACM – Asbestos Containing Material
  • AST – Aboveground Storage Tank
  • BDAT – Best Demonstrated Available Technology
  • BIF – Boiler & Industrial Furnaces
  • CAMU – Corrective Action Management Unit
  • CAS RN – Chemical Abstracts Service Registry Number
  • CERCLA – Comprehensive Environmental Response, Compensation, & Liability Act (“Super-fund”)
  • CERCLIS – Comprehensive Environmental Response, Compensation, & Liability Information System (Inventory), formerly the ERRIS List
  • CESQG – Conditionally Exempt Small Quantity Generator
  • CFR  – Code of Federal Regulations
  • 40 CFR – Protection of the Environment – U.S. EPA
  • 49 CFR – Transportation – U.S. DOT
  • 29 CFR – General Industry Standards – OSHA
  • CHEMTREC – Chemical Transportation Emergency Center (CMA)
  • CKD – Cement Kiln Dust
  • CMA – Chemical Manufacturers Association
  • CMBST – Combustion: Incineration/Fuel Substitution (Specified Technology Treatment Standard)
  • CMS – Corrective Measures Study
  • CWA – Clean Water Act
  • CWT – Centralized Waste Treatment Industry
  • DEACT – Deactivate (Specified Technology Treatment Standard)
  • DOT – U.S. Department of Transportation
  • EPA – U.S. Environmental Protection Agency
  • EPCRA – Emergency Planning & Community Right to Know Act (Title III of SARA)
  • FR – Federal Register
  • HHW – Household Hazardous Wastes
  • HMT – Hazardous Materials Table (49 CFR 172.101)
  • HMTA – Hazardous Materials Transportation Act
  • HOC – Halogenated Organic Compound (Appendix III of 40 CFR Part 268)
  • HSWA – Hazardous & Solid Waste Amendments of 1984 (to RCRA)
  • HTMR – High Temperature Metal Recovery
  • HWIR – Hazardous Waste Identification Rule
  • HWM – Hazardous Waste Management
  • LDR – Land Disposal Restrictions
  • LQG – Large Quantity Generator
  • MCL – Maximum Contaminant Level
  • MSDS – Material Safety Data Sheet
  • NCP – National Oil & Hazardous Substances Pollution Contingency Plan (National Contingency Plan – 40 CFR Part 300)
  • NIOSH – National Institute for Occupational Safety & Health
  • Non WW – Non-Wastewater (category)
  • Nos – Not Otherwise Specified
  • NPDES -National Pollutant Discharge Elimination System
  • NPL – National Priorities List
  • NRC – National Response Center
  • O/O – Owner/Operator
  • ORM – Other Regulated Material
  • OSHA – U.S. Occupational Safety & Health Administration
  • PCB – Polychlorinated Biphenyl
  • PEL – Permissible Exposure Limit
  • POTW – Publicly Owned Treatment Works (Sewage Treatment Plant)
  • PRP – Potentially Responsible Party (often Responsible Party (RP))
  • RCRA – Resource Conservation & Recovery Act of 1976
  • RFA/RFI – RCRA Facility Assessment/RCRA Facility Investigation
  • RI/FS – Remedial Investigation/Feasibility Study
  • RORGS – Recovery of Organics (Specified Technology Treatment Standard)
  • RQ – Reportable Quantity
  • RSPA – Research & Special Programs Administration (DOT)
  • SARA – Superfund Amendments & Reauthorization Act of 1986 (to CERCLA)
  • SDWA – Safe Drinking Water Act
  • SIC – Standard Industrial Classification (Code)
  • SPCC – Spill Prevention Control & Countermeasures (Plan)
  • SQG – Small Quantity Generator
  • SWDA – Solid Waste Disposal Act (RCRA Predecessor)
  • SWMU – Solid Waste Management Unit (often SMU)
  • SW-846 – Test Methods for Solid Waste: Physical/Chemical Methods
  • TAR – Toxics Along for the Ride
  • TC – Toxicity Characteristic
  • TCLP – Toxicity Characteristic Leaching Procedure
  • TLV – Threshold Limit Value
  • TPH – Total Petroleum Hydrocarbons
  • TRI – Toxic Release Inventory
  • TSCA – Toxic Substances Control Act
  • TSD – Treatment, Storage, or Disposal Facility (often TSDF)
  • UHC – Underlying Hazardous Constituents
  • UHWM – Uniform Hazardous Waste Manifest
  • UIC – Underground Injection Control
  • UST – Underground Storage Tank
  • UTS – Universal Treatment Standards
  • VOC – Volatile Organic Compound (Chemical)
  • WW – Wastewater (category)
  • WWT – Wastewater Treatment

10 Steps to Uniform Hazardous Waste Manifest Completion

This is another excerpt taken from our RCRA training literature. The following is a good list of steps to take to ensure proper hazardous waste manifest completion.

1. Complete all federally required information.

2. Complete the state required information, if any, for the TSD state.

3. Complete the state required information, if any, for the generator’s state.

4. Complete TSD specific information, if any. (For example: a TSD may require waste stream numbers).

5. Review the manifest. Is all information complete and correct? Are all copies legible?

6. Read the generator’s certification and sign the manifest.

7. Complete, review, and sign LDR form, as applicable.

8. Have the first transporter sign the acknowledgement of receipt of materials. Be sure to check that the vehicle placarding and container labels are correct, check container counts and agree with driver.

9. Remove appropriate copies of the manifest. Retain a copy of the LDR, as applicable.

10. File appropriate copies of manifest, a copy of LDR form, and additional documents.

Some Additional Tips

  • After the initial completion of the manifest and subsequent signatures and changes, check to make certain all marks are legible on all copies.
  • Maintain a log, either written or by computer, to track open manifests and manifest document numbers.
  • Corrections that are made should be accompanied by initials and date (ASM 6/30/06). Corrections in type and quantity require contact between the generator and TSD. If these corrections are made by telephone, both parties should date and initial the change.
  • All changes should be made by line out and initials (F006 D008 ASM 6/30/94). Do not use correction tapes or liquids.
  • Maintain a working relationship with government agencies.

Solid Waste Recycling Exemptions

40 CFR defines solid waste as “any discarded material that is not excluded under §261.4(a) or that is not excluded by a variance granted under §260.30 and §260.31 or that is not excluded by a non- waste determination under §260.30 and §260.34.” Additionally, discarded material is, “any material which is: (A) Abandoned… (B) Recycled…(C) Considered inherently waste-like, …or (D) A military munition identified as a solid waste in §266.202.” This makes everything perfectly clear, right? Relative fuzziness aside, what I want to talk about today is the 40 CFR 261.2 recycling exemptions as they relate to solid wastes.

There are five types of material that can be considered for recycling exemptions:

  1. Spent materials – The EPA defines spent materials as “any material that has been used and as a result of contamination can no longer serve the purpose for which it was produced without processing.”
  2. Sludges – According to the EPA, a sludge is “any solid, semi-solid, or liquid waste generated from a municipal, commercial, or industrial wastewater treatment plant, water supply treatment plant, or air pollution control facility exclusive of the treated effluent from a wastewater treatment plant.”
  3. Byproducts – “A byproduct is a material that is not one of the primary products of a production process and is not solely or separately produced by the production process. Examples are process residues such as slags or distillation column bottoms. The term does not include a co-product that is produced for the general public’s use and is ordinarily used in the form it is produced by the process.”
  4. Commercial chemical products – These products are not being used but have not been spent for an intended purpose.
  5. Scrap metal

These five materials can have recycling exemptions in four different ways:

  1. Use constituting disposal – Used in a manner constituting disposal
  2. Burning waste or waste fuels for energy recovery or using wastes to produce a fuel.
  3. Reclamation of wastes – According to the EPA, “A material is reclaimed if it is processed to recover a usable product, or if it is regenerated. Examples are recovery of lead values from spent batteries and regeneration of spent solvents.”
  4. Speculative accumulation – This is one of the more detailed recycling exemptions.  According to the EPA, “A material is accumulated speculatively if it is accumulated before being recycled. A material is not accumulated speculatively, however, if the person accumulating it can show that the material is potentially recyclable and has a feasible means of being recycled; and that—during the calendar year (commencing on January 1)—the amount of material that is recycled, or transferred to a different site for recycling, equals at least 75 percent by weight or volume of the amount of that material accumulated at the beginning of the period.” More information about this can be found in 40 CFR §261.1.

Recycling exemptions are just a small portion of possible exceptions. Always check 40 CFR and state regulations for full information.

Substantive Vs. Procedural: Top Ten Hazardous Waste Violations

Maybe it’s just me, but I feel like it has really been a while since I last blogged. I hope everyone had a good holiday/new year and that we all can be ready to jump into 2013. In an attempt to start things strong, I want to write another post about something I learned at the RCRA training seminar in December.

I have written in the past about different things that are often viewed as “common hazardous waste violations.” You may remember the post about Hazardous Waste Reduction Plans or the one about Avoiding Weekly Hazardous Waste Inspection Violations. Today, however, I want to discuss the US EPA’s list of the top 10 violations. In particular, I will write about whether the issues are substantive or procedural and what those classifications mean.

To begin, we need to identify the difference between these types of requirements:

  • Substantive Requirements – Either provide material reduction in risk or materially increase environmental protection.
  • Procedural Requirements – Have an indirect impact on risk reduction but are significant in terms of regulatory agency assessment of compliance.

Both types are important and neither can be ignored if you and your company want to ensure EPA and RCRA compliance.

So now we can look at how the top ten violations can be seperated into these two categories.

Substantive Violations from the EPA Top 10 Waste Violations

  • Lack of proper waste determination
  • Container violations
  • Inadequate aisel space
  • Incompatible wastes in close proximity
  • Inadequate inspections*
  • Inadequate training*

Procedural Violations from the EPA Top 10 Waste Violations

  • Inadequate inspections*
  • Inadequate training*
  • Accumulation time exceedances
  • Satellite container issues
    • location, volume, marking
  • Inadequate contingency plan
  • LDR notice issues

As you can see, inadequate inspections and inadequate training can fall under both categories. This means they can both provide material reduction in risk or materially increase environmental protection and be significant in terms of regulatory agency assessment of compliance. Perhaps the most important take-away from this post is that while common violations can fall into two categories, both must be considered and followed in order to ensure RCRA complience.

For more information about common violations, look for our Top 10 Hazardous Waste Violations eBook coming soon.

Basic RCRA Waste Regulations

For starters, I want to apologize for missing a day of blogging last Thursday. I attended a Heritage RCRA refresher course in downtown Indianapolis and was without internet for most of the day. On the plus side, attending the course gave me ideas for several different blog posts!

Over the coming weeks, I will be singling out some of what I learned and sharing it on here. To begin, I will go over the basic federal requirements set forth by RCRA. It is always important to remember, however, that each state likely has additional requirements that must be met.

The first thing you will want to do is make some basic determinations. On an ongoing basis you should be asking and answering the following questions:

  • In relation to identifying waste streams –
    • What are all the wastes being generated at my facility?
    • What are the different departments generating?
  • In relation to hazardous waste determination –
    • According to the regulatory definitions, which of the wastes being generated are classified as hazardous?
  • In relation to determining regulatory categories –
    • How much waste do you have on site and what is done with it? (see form 8700-12)

Next, you will want to make sure your containers are up to standard. It must be ensured that containers are:

  • In good condition (not rusty, no corrosion, no leaking)
  • Compatible with the waste (you want to make sure the waste will not react with the container)
  • Labeled or marked “hazardous waste”
  • Marked with an accumulation start date
  • Kept closed (as a rule of thumb this means you could tip it over and it wouldn’t leak)
  • Managed to avoid damage and releases
  • Kept free of incompatible wastes; incompatible wastes must never be placed in the same container

The third thing to check is that you are following regulations regarding accumulation areas. For this section you will need to make sure:

  • Ignitable and reactive wastes are at least 50 feet from the property line
  • “No Smoking” signs are posted
  • Incompatible wastes are separated or protected from each other
  • Emergency equipment is available
  • There is adequate aisle space maintained (at least 2½ feet)

Additionally, someone needs to:

  • Inspect container accumulation areas weekly
  • Inspect emergency equipment at least monthly
  • Make shipments every 90 days if you are a large quantity generator
  • Make shipments every 180 days if you are a small quantity generator

Lastly, you must follow the compliance documentation rules. These rules include:

  • Having a contingency plan
  • Having personnel training program and records
  • Documentation of inspections
  • Manifests and LDR forms
  • Biennial Reports
  • Waste analyses/determinations
  • Documented waste minimization program on site

Remember, these guidelines are just a starting point. To ensure compliance you must look into all regulations as they apply to your business, both at federal and state level. Keep checking the blog in the coming weeks for more information about RCRA.

Things You Think You Know About Hazardous Waste – Pt. 3

This week we finish our things you think you know series contributed by Heritage Compliance Manager Mike Karpinski. The topic of this weeks post; as long as a business complies with EPA waste regulations they don’t have to worry about anything else.

Working at a national waste management company like Heritage, I often dream this was the case, but unfortunately there are many other federal agencies such as the Department of Transportation (DOT), Occupational Health and Safety Administration (OSHA), Department of Homeland Security, Drug Enforcement Agency and others that all have regulations pertaining to hazardous wastes and that’s not the end of it.

Each state (except for Iowa and Alaska) also has state specific regulations that are, at a minimum, equivalent to the federal regulations and may be stricter than the federal regulations.  Oftentimes, a state will have equivalent regulations, but different administrative requirements that cannot be ignored. For a company like Heritage that does business across all 50 states that means complying with a minimum of 196 different regulations relating to the proper management of hazardous materials (and I haven’t even mentioned all the city or county requirements yet…. I need an aspirin).

This reminds me, many of the statements made in the previous posts are based on general descriptions of federal regulations. Other Federal, State, or Local regulations may apply to your situation which may counteract these statements. This is one of the best reasons for working with a company like Heritage Environmental Services, LLC, we have experience dealing with these regulations and are trained to work closely with our customers to assist them in complying with these requirements.