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FREQUENTLY ASKED QUESTIONS
ABOUT RCRA
What Is RCRA?Questions
RCRA is a federal law that encourages environmentally sound methods for managing
commercial and industrial waste as well as household and municipal waste. It regulates facilities that
STATE
REQUIREMENTS
generate, transport, treat, store, or dispose of hazardous waste. The vast majority of motor freight
and railroad transportation facilities are considered hazardous waste generators, rather than
treatment, storage, and disposal facilities (TSDFs), which are subject to more rigorous regulations.
Y ou may be reg-
ulated both by
your state hazardous
The term RCRA is often used interchangeably to refer to the law, the regulations, and EPA waste agency and EPA.
policy and guidance. The law describes the waste management program mandated by Congress that RCRA allows states to
gave EPA authority to develop the RCRA program. EPA regulations carry out the Congressional receive legal permission,
intent by providing explicit, legally enforceable requirements for waste management. EPA guidance known as authorization,
documents and policy directives clarify issues related to the implementation of the regulations. to implement the RCRA
hazardous waste pro-
All of the RCRA hazardous waste regulations can be found in the Code of Federal Regulations gram. You must always
(CFR), Title 40, Parts 260 to 279. The CFR can be purchased through the U.S. Government
contact your state
Printing Office (GPO).
authority to determine
which state require-
Who Is Regulated? ments apply to your
Any motor freight or railroad transportation facility that generates hazardous waste is potentially business.
subject to RCRA. You must conduct tests required by the regulations or use your knowledge of and To operate a haz-
familiarity with the waste you generate to determine whether it is hazardous waste (as opposed to ardous waste program, a
other types of waste). You might be subject to substantial civil and criminal penalties if you fail to states regulations must
properly or completely identify hazardous waste generated by your business. be consistent with, and
at least as stringent as,
the federal program.
What Is Hazardous Waste? Some states adopt more
To be considered hazardous waste, a material first must be classified as a solid waste. EPA defines stringent requirements
solid waste as garbage, refuse, sludge, or other discarded material (including solids, semisolids, for facilities handling
liquids, and contained gaseous materials). If your waste is considered solid waste, you must then hazardous waste, which
determine if it is hazardous waste. Wastes are defined as hazardous by EPA if they are specifically are considered part of
named on one of four lists of hazardous wastes (listed wastes) or if they exhibit one of four
the authorized program.
characteristics (characteristic wastes). Each type of RCRA hazardous waste is given a unique
hazardous waste code using the letters D, F, K, P, or U and three digits (e.g., D001, F005, P039).
See pages 10 to 14 for additional information on motor freight and railroad transportation waste MORE
codes. QUESTIONS?
Listed Wastes. Wastes are listed as hazardous because they are known to be harmful to human
health and the environment when not managed properly, regardless of their concentrations. The
lists include the following three types of waste: C all the RCRA
Hotline at
800 424-9346 or TDD
Non-Specific Source Wastes. These are material-specific wastes, such as solvents, generated
by several different industries. Waste codes range from F001 to F039. Examples include ethyl 800 553-7672 for addi-
benzene, methylene chloride, and toluene. tional information about
Specific Source Wastes. These are wastes from specifically identified industries. Waste codes RCRA rules and regula-
range from K001 to K161. Motor freight and railroad transportation facilities typically do not tions. In the Washington,
generate specific source wastes.
DC, area, call 703 412-
Discarded Commercial Chemical Products. Off-specification products, container residuals, 9810 or TDD 703 412-
spill residue runoff, or active ingredients that have spilled or are unused and that have been, or
are intended to be, discarded. Waste codes for acutely hazardous chemicals range from P001 to 3323.
P205 and U001 to U411. An example is U159, unused methyl ethyl ketone.
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AM I REGULATED
BY RCRA OR
Frequently
Characteristic Wastes. Even if your waste does not appear on one of the hazardous waste lists, it still
might be regulated as hazardous waste if it exhibits one or more of the following characteristics:
SUPERFUND? Ignitability. Ignitable wastes create fires under certain conditions or are spontaneously combustible,
and have a flash point less than 60C (140F). One example is spent solvents from motor freight and
R CRA regulates the
treatment, storage,
and disposal of hazardous
railroad transportation operations. The waste code for these materials is D001.
Corrosivity. Corrosive wastes are acids or bases that are capable of corroding metal containers,
such as storage tanks, drums, and barrels. Acidic waste from motor freight and railroad
waste being generated now
transportation surface preparation is a good example. The waste code for these materials is D002.
and in the future.
Superfund was created to Reactivity. Reactive wastes are unstable under normal conditions. They can cause explosions,
pay for the identification, toxic fumes, gases, or vapors when mixed with water. Examples include lithium-sulfur batteries
inspection, investigation, and explosives. The waste code for these materials is D003.
ranking, and cleanup of
Toxicity. Toxic wastes are harmful or fatal when ingested or absorbed. When toxic wastes are
abandoned or uncon-
disposed of on land, contaminated liquid might drain (leach) from the waste and pollute ground
trolled hazardous waste
water. Toxicity is defined through a laboratory procedure called the Toxicity Characteristic
sites that people responsi-
Leaching Procedure (TCLP). Certain chemicals in pigment wastes generated from motor freight
ble for contamination are
and railroad transportation staining and painting are examples of potential toxic wastes. The
unable or unwilling to
waste codes for these materials range from D004 to D059.
clean up. Call the RCRA
Hotline for more
information. How Are Generators Regulated?
If your motor freight or railroad transportation business generates hazardous waste, you must
HOW IS USED manage it according to regulations for your specific generator type. Hazardous waste generators are
OIL HANDLED? divided into three categories, according to how much they generate in a calendar month:
Large Quantity Generators (LQGs). LQGs generate greater than or equal to 1,000 kg
R
CRA contains spe-
(approximately 2,200 lb) of hazardous waste per month or greater than 1 kg (approximately 2.2
cial provisions for
lb) of acutely hazardous waste per month.
the management of used
oil destined for recycling. Small Quantity Generators (SQGs). SQGs generate greater than 100 kg (approximately 220
These management stan- lb) but less than 1,000 kg (approximately 2,200 lb) of hazardous waste per month.
dards apply to oil refined
Conditionally Exempt Small Quantity Generators (CESQGs). CESQGs generate less than
from crude oil or any syn-
or equal to 100 kg (approximately 220 lb) of hazardous waste per month and less than or equal to
thetic oil that has become
1 kg (approximately 2.2 lb) of acutely hazardous waste per month.
contaminated through use
by chemical or physical Some states do not recognize the CESQG class. Contact your state environmental agency to find
impurities. Used oil that out if the CESQG status is recognized. To find your appropriate state contact, call the RCRA
will be recycled or reused Hotline at 800 424-9346.
is subject to special man-
Under the federal RCRA requirements, your generator status might change from one month to
agement standards, rather
the next as the quantity of waste you generate changes. State requirements vary widely. You must
than the hazardous waste
comply with whichever standard is applicable for a given month. In many cases, small businesses
standards, unless it is
that fall into different generator categories at different times choose to always satisfy the more
treated as a waste (i.e., you
stringent requirements (usually state requirements) to simplify compliance. Generators must
decide to send the used oil
count the amount of waste generated, which involves adding up the total weight of all quantities
for treatment and disposal
of characteristic and listed waste generated at a particular facility. Certain wastes, such as those that
rather than recycling). The
are reclaimed or recycled continuously on site, may not be counted for the monthly total calculation
used oil regulations can be
under the federal regulations.
found in 40 CFR 279.
4 RCR A IN FOCUS
