DEEP: RCRA Help!

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RCRA HELP!
 
Overwhelmed by hazardous waste requirements?
 
Don’t know where to start?
 
Try this one-stop guide to get you on your way to compliance.
 
 
Introduction
 
“RCRA” or the “Resource Conservation and Recovery Act” is the federal law that sets standards to ensure that hazardous wastes are stored, handled, recycled and disposed of safely.  The State of Connecticut’s Hazardous Waste Management Regulations incorporate the federal hazardous waste regulations, along with additional state requirements.
 
This web page is designed to help you figure out which hazardous waste requirements apply to you.  It is broken down into several sections that are arranged in a special order.  If you are just starting out, begin with the first section and work your way down.  If you are looking for information on a specific requirement, then select the link below for the section on which you need help.
 
 
 
 
Connecticut’s Hazardous Waste Management Regulations apply to hazardous wastes that are generated by any industrial, commercial, public, or other non-residential operation.  These regulations do not apply, however, to wastes generated by residents in their homes (i.e., “Household Hazardous Wastes”).  See the DEEP Household Hazardous Waste web page for more information on residentially generated wastes. 
 
If you generate hazardous waste from any sort of non-residential activity, then at least some of Connecticut’s Hazardous Waste Management Regulations will apply to you.  The following sections provide information on how to determine which of your wastes are hazardous, and which set of hazardous waste generator requirements apply to you.
 
 
Step One:  Inventory your wastes
 
The first step is to make a list of all the kinds of waste that you generate at your facility other than ordinary trash.  This would include manufacturing wastes, maintenance wastes, wastewater treatment sludges, wastes generated by air pollution control equipment (e.g., sludges, dusts, etc.), and unwanted commercial chemical products.
 
There are some wastes that are commonly overlooked.  Here is a list of wastes that generators often forget when inventorying their potentially hazardous wastes:
 
Fluorescent lamps*
Batteries (e.g., lead-acid, nickel-cadmium)*
Used electronics (e.g., computers, monitors, TVs, copiers, printers, etc.)*
Absorbents (Speedi-Dri, clay-based absorbents, absorbent pigs, etc. contaminated with oil or chemicals)
Rags/wipers
Waste gasoline
Spent antifreeze
Grinding dusts
Blasting media
Filters
Paint-related wastes
Old/overstock unused products
Wastewaters treated in evaporators
Abandoned materials
 
* Although they are often hazardous, fluorescent lamps, batteries, and used electronics are subject to a special set of requirements known as "The Universal Waste Rule." See the Universal Waste section for information on the requirements that apply to these wastes.
 
Step Two:  Determine which of your wastes are hazardous
 
Once you have made a list of all of the wastes you generate, you must now evaluate each of them to find out which are hazardous.  This process is commonly called a “Hazardous Waste Determination.”  There are two acceptable ways to do this:
  1. Have a sample of the waste tested at a laboratory that is licensed as an Environmental Laboratory by the State of Connecticut.  These laboratories are private laboratories that analyze wastes for a fee.  To find a licensed laboratory in your area, see the List of Certified Testing Laboratories
  2. Use your knowledge of the process that generates the waste and the raw materials that are used in the process to determine whether or not the waste is hazardous.
The above two methods can be used separately or together in evaluating a particular waste stream.  However, no matter which method(s) are chosen, it must result in the waste being thoroughly and correctly classified as hazardous or non-hazardous.
 
For more information on performing hazardous waste determinations, see the DEEP fact sheet, Hazardous Waste Determinations/Knowledge of ProcessNote: There are special testing requirements for used oil.  Used oils can include waste oils such as spent crankcase and other automotive oils, hydraulic oils, machining coolants, heat-transfer oils, quenching oils and virgin oils of these types that are unwanted or discarded.  See the Used Oil section for more information on how to test and manage these materials.
 
Important!
 
Connecticut’s Hazardous Waste Management Regulations require that you update your hazardous waste determinations annually, and whenever there are changes to the process that generates the waste.
 
Also, Connecticut’s regulations require that anyone using “knowledge of process” information to determine whether or not their waste is hazardous must document that information.  This documentation may include many different types of information, such as Material Safety Data Sheets (MSDSs), disposal facility waste profile sheets and analyses, raw product technical specifications, and other similar documents.
 
In order to ensure that your hazardous waste determinations are properly documented, DEEP recommends that you summarize the information you used to make each determination in writing. To assist with this, DEEP has developed a Hazardous Waste Determination Summary Sheet that you may find a helpful tool for this purpose.  Note: This Summary Sheet is provided only as a helpful aid to compliance. It is not required by law and using it does not necessarily guarantee that you will be in compliance.
 
All test results and “knowledge of process” information for each of your wastes must be kept for at least three years.  This includes not only the wastes that actually turn out to be hazardous, but also those that are determined to be non-hazardous.
 
Need More Help?
 
If you need help with performing hazardous waste determinations or interpreting laboratory or other data that you may have obtained, call DEEP's toll-free Hazardous Waste Compliance Assistance line at 1-888-424-4193. 
 
 
Once you have performed a Hazardous Waste Determination on each of the wastes you generate (see Which of my wastes are “Hazardous Wastes"?), you are now ready to determine what category of hazardous waste generator you are.
 
If none of your wastes are hazardous – Congratulations!  You are not a hazardous waste generator, and all you have to do is keep copies of test data and other information that you used to determine that your wastes are not hazardous for at least three years. You also must re-evaluate your wastes annually or whenever there are process or raw material changes that could affect your wastes.  The remainder of Connecticut’s Hazardous Waste Management Regulations do not apply to you.  Note:  If none of your wastes are hazardous but you generate non-hazardous used oil, you must also comply with certain used oil requirements.  See the Used Oil section for more information.
 
If any of your wastes are hazardous (see previous section), you must now determine the following for each of these wastes:
  1. How much of each waste you generate per calendar month; and
  2. The maximum amount of each hazardous waste you store on site at any one time.
In order to help you organize this information, DEEP recommends that you use our Hazardous Waste Generator Category Worksheet Note: This Worksheet is provided only as a helpful aid to compliance.  It is not required by law and using it does not necessarily guarantee that you will be in compliance. DEEP also recommends that you review this information annually for possible changes in the amount of waste you generate and accumulate on-site.
 
The hazardous waste regulations have different sets of requirements based on the amount of hazardous waste you generate and store on-site.  Use the table below to figure out your generator category based on the waste generation data that you calculated using the Hazardous Waste Generator Category Worksheet.  Each generator category is displayed as a single line in this table.  Your generator category is the lowest line on the table for which you meet both of the thresholds in columns two and three of the table. 
 

Hazardous Waste Generator Categories

Waste Generator Category

Amount of Waste Generated
Per Calendar Month

 

Amount of Waste Stored
On-Site
At Any One Time

CESQG

Conditionally Exempt Small Quantity Generator

No More than
100 kilograms*

And

No More than 1 kilogram* of
Acute Hazardous Waste 

AND


No More than
1000 kilograms*

And

No More than 1 kilogram* of
Acute Hazardous Waste
 

SQG

Small Quantity Generator


Between
100 - 1000 kilograms*

And

No More than 1 kilogram* of
Acute Hazardous Waste 

AND


No More than
1000 kilograms*

And

No More than 1 kilogram* of
Acute Hazardous Waste

LQG

Large Quantity Generator


1000 kilograms*
or More

Or

Greater than 1 kilogram* of
Acute Hazardous Waste 
 

OR


More than
1000 kilograms*

 Or

Greater than 1 kilogram* of
Acute Hazardous Waste

*See the Hazardous Waste Generator Category Worksheet for conversion factors from kilograms to pounds and gallons.

 
For additional information on determining you hazardous waste generator category, see the DEEP Fact Sheet, Determining Hazardous Waste Generator Category.
 
Once you have determined your generator category, see the Conditionally Exempt Small Quantity Generator, Small Quantity Generator, or Large Quantity Generator sections of this web page for information on the hazardous waste requirements that apply to you.
 
Important!
 
Additional hazardous waste requirements apply to anyone that does any of the following activities:
  • Transporting hazardous waste in or through the State of Connecticut.
  • Receiving hazardous waste from off-site.
  • Storing hazardous waste for longer than the timeframes allowed for generators.
  • Treatment of hazardous waste.
  • Disposal of hazardous waste.
Most of these activities require a permit from DEEP.  Therefore, unless you are a commercial hazardous waste handler that has received all required permits, you should be careful not to engage in any of the above activities.  One notable exception is on-site recycling.  Generators of hazardous waste are allowed to recycle their own hazardous waste on-site, provided that the waste is managed in compliance with hazardous waste requirements before it is recycled, and any residues from the recycling process are properly managed.  Also, the recycling of the hazardous waste must not include any process that involves incineration or land disposal.  If you have any questions on hazardous waste recycling, call the DEEP's toll-free hazardous Waste Compliance Assistance line at 1-888-424-4193.
 
Re-examine your waste generation activities
 
Now that you have figured out what your generator status is, you should take a hard look at the wastes you generate and ask yourself the following questions:
  • Can I eliminate any of these hazardous wastes by changing my process or switching to non-hazardous raw materials?
  • Can I reduce the amount of hazardous waste that I generate each month?
  • Can I reduce the amount of hazardous waste that I store at any one time?
Reducing or eliminating the amount of hazardous waste that you generate or store could put you into a lower hazardous waste generator category, and reduce the number of hazardous waste requirements that apply to you.  Reducing or eliminating waste is referred to as waste minimization, and is strongly encouraged not just as a way to make compliance easier, but also to protect the environment and save money.
 
DEEP has a lot of information on waste minimization and pollution prevention.  Some of this information may relate to specific industries, whereas other information may apply to everyone.  Look down through the following list of links for topics that may apply to your operation.
 
 
 
 
 
 
 
Need More Help?
 
If you need help determining your generator status, call the DEEP's toll-free Hazardous Waste Compliance Assistance line at 1-888-424-4193.
 
 

A Conditionally Exempt Small Quantity Generator (or "CESQG") is the least-regulated type of hazardous waste generator.  CESQGs are not required to submit a Hazardous Waste Notification Form to DEEP or obtain an EPA Identification Number. CESQGs only have to comply with some basic requirements for waste testing and recordkeeping, and ensure that their hazardous wastes are shipped by permitted hazardous waste haulers to permitted recycling, treatment, storage, or disposal facilities.

For complete information about the requirements that apply to CESQGs, see DEEP's CESQG Guidance Manual.

See also the Used Oil, Universal Waste and Related Topics and Additional Information sections below for information on other waste management issues that may apply to CESQGs.

Information For Small Quantity Generators ("SQGs")

A Small Quantity Generator (or "SQG") is subject to more requirements than a Conditionally Exempt Small Quantity Generator, but less than a Large Quantity Generator. SQGs must submit a Hazardous Waste Notification Form to DEEP and obtain an EPA Identification Number.  SQGs must also comply with specific requirements for waste testing and recordkeeping, on-site waste storage, waste inspections, personnel training, emergency preparedness and prevention, and other requirements.

For complete information about the requirements that apply to SQGs, see DEEP's SQG Guidance Manual.

Another resource for SQGs is DEEP's Hazardous Waste On-Line Training Course.  This is an Internet-based training course that provides detailed instruction in hazardous waste requirements for small and large quantity generators.

See also the Used Oil, Universal Waste and Related Topics and Additional Information sections below for information on other waste management issues that may apply to SQGs.

Information For Large Quantity Generators ("LQGs")

Large Quantity Generators (or, "LQGs") are the most highly-regulated types of hazardous waste generators. LQGs submit a Hazardous Waste Notification Form to DEEP and obtain an EPA Identification Number.  LQGs must also comply with specific requirements for waste testing and recordkeeping, on-site waste storage, waste inspections, personnel training, emergency preparedness and prevention, and other requirements.  Some of these requirements involve the preparation of written documents, such as an inspection schedule and log, a personnel training plan, and a contingency plan.  See the links below for more information on the requirements that apply to LQGs.

Hazardous Waste On-Line Training Course:  This is an Internet-based training course that provides detailed instruction in hazardous waste requirements for small and large quantity generators.

Hazardous Waste Container Management

Hazardous Waste Manifest Requirements

Hazardous Waste Personnel Training

Hazardous Waste Inspections

Hazardous Waste Contingency Plan

Biennial Hazardous Waste Reporting


Used Oil

Many generators of hazardous waste also generate used oil. If used oil is contaminated with certain hazardous constituents, it must be managed as hazardous waste.  If it is not contaminated with such constituents, used oil may be managed under a special, reduced set of requirements that are separate from those for hazardous waste.

See the DEEP's Used Oil web page  for more information. In particular, to find out whether your used oil must be managed as a hazardous waste or as a used oil, see the links for Used Oil Fact Sheets #7 and #8, each of which includes a step-by-step procedure for determining whether a used oil must be managed as a hazardous waste. These fact sheets also provide detailed information on how to properly handle used oils that are found to be non-hazardous.

Universal Waste

Certain types of hazardous waste are eligible for management under a special, streamlined set of hazardous waste requirements known as "The Universal Waste Rule."  The wastes that are considered "universal wastes" include:

  • batteries,
  • mercury thermostats and other mercury-containing equipment,
  • certain pesticides,
  • mercury lamps (for example, fluorescent lamps), and
  • used electronics.

See the DEEP's Universal Waste Rule web page for more information about the proper management of Universal Waste.

Important Note

Even though they are hazardous wastes, Universal Wastes do not have to be counted when determining your hazardous waste generator status.

Related Topics and Additional Information 

Listed below are links for additional information on hazardous waste and related topics that you might find helpful.  Also see the DEEP's Hazardous Waste main page for more information.

List of Certified Environmental Testing Laboratories.  Environmental testing laboratories that do business in Connecticut must be certified by the Connecticut Department of Public Health. The DPH’s Environmental Laboratory web page includes two lists of certified laboratories – one for labs that are located in Connecticut and a second list for labs located outside Connecticut. Note: Not all DPH-certified labs are capable of doing hazardous waste testing. The DPH lists described above provide some information about the kinds of testing that each lab performs. However, DEEP recommends that you call and check with a lab to determine if they can do the kind of testing that you need. Also, labs that perform the TCLP test (to determine if a waste is "toxic") must have a separate certification from the U.S. EPA. If you are sending samples for TCLP testing, be sure to confirm that the lab is EPA-certified for this test.

Hazardous Waste Determination Summary Sheet.  DEEP recommends that you use this summary sheet to help you determine which of the wastes you generate are hazardous, and to document information about each of your wastes. The sheet is available in two forms:

  • PDF Format.  You can print this version of the Sheet and fill it out manually. However, it cannot be filled in electronically.
  • MS Word Format. If you have Microsoft Word, you can download this version and fill it out electronically. The check boxes may be checked or unchecked simply by clicking on them, and text may be entered in the text boxes in each section of the Summary Sheet. Note: After you fill out the Summary Sheet for a waste stream, don’t forget to save it with a unique file name and print out a copy for your records.

Hazardous Waste Generator Category Worksheet.   DEEP recommends that you use this worksheet to determine your hazardous waste generator status. Note: You must evaluate all of your wastes to determine which of them are hazardous before completing this worksheet. The worksheet is available in two forms:

  • PDF Format.  You can print this version of the Sheet and fill it out manually. However, it cannot be filled in electronically.
  • MS Word Format. If you have Microsoft Word, you can download this version and fill it out electronically. Note: After you fill out the Worksheet, don’t forget to save it and print out a copy for your records.

List of Permitted Hazardous Waste Haulers.  Generators of hazardous waste must use permitted hazardous waste haulers when they ship their waste for off-site recycling, treatment, storage, or disposal.  This link provides a listing of the transporters that generators in Connecticut may use when shipping their waste off-site.  Some of these haulers are located in Connecticut, whereas others are based out-of-state, but provide transportation services to customers  located in Connecticut.

List of Permitted Hazardous Waste Facilities. Provides a listing of facilities in Connecticut that are permitted to receive hazardous waste for recycling, treatment, storage, or disposal.  There are many other facilities outside of Connecticut that are permitted by their home states to receive hazardous waste.  You can find out more about these out-of-state facilities by contacting your permitted waste hauler, or by checking the web sites of other states' environmental agencies.

Non-RCRA-Hazardous Waste ("Connecticut-Regulated Waste"). There are certain types of commercial and industrial waste that are not hazardous waste, but that may still not be disposed of as ordinary trash in Connecticut.  This fact sheet describes these so-called "Connecticut-Regulated Wastes" and how they must be managed.

Polychlorinated Biphenyls (PCBs). PCBs are a class of chemicals that were used in a wide variety of products and applications, including transformer oils, hydraulic fluids, fluorescent light ballasts, and many others.  PCBs are not classified as hazardous waste, but are regulated under a separate set of requirements.  This link provides information on the types of materials that may contain PCBs, and how PCBs must be managed.

DEEP Hazardous Waste Inspection Forms. Provides copies of the inspection forms used by DEEP inspectors during inspections at various kinds of hazardous waste handlers.  See in particular the inspection form that matches your generator status (i.e., CESQG, SQG, or LQG), since it provides a good way for you to self-audit your facility and double-check your compliance with hazardous waste requirements.

DEEP Property Transfer Requirements. In addition to the hazardous waste requirements, generators of hazardous waste may also be subject to DEEP’s Property Transfer Law when selling their place of business, or engaging in certain other regulated financial transfers. This law requires the submission of special DEEP forms and the cleanup of contamination caused by spills or releases that may have occurred at the site.

DEEP Policy on Incentives for Self-Policing.  Provides information about a DEEP policy that provides incentives for companies to evaluate their compliance with environmental requirements and correct violations on their own.

Spill Reporting and Response. Spills of hazardous waste and other materials must be reported to DEEP immediately, and properly addressed.  This link provides spill reporting telephone numbers and other information relating to DEEP's spill response requirements.

Content last updated December 5, 2016