4.0 Hazardous Waste Generator Requirements (Top)
The following describe the various requirements for managing hazardous waste for each of the different types of generators. Generator status is mainly dependent on the quantity of hazardous waste generated in a calendar month. Satellite Accumulation Area (SAA)
is the name given to the location (the lab or work area) where hazardous wastes are generated and stored before being moved to a central storage area.
4.1 Hazardous Waste Generation, Management, and Disposal (Top)
RCRA established a nationwide hazardous waste management law. The EPA promulgates federal regulations governing hazardous waste generation, management and disposal. Federal regulations for hazardous waste are found in 40 CFR 260-279.
DEC is authorized by the EPA to govern hazardous waste in New York State. The DEC’s regulations are slightly more stringent than the federal standards. When the university is inspected by the EPA under the RCRA regulations, the DEC’s regulations are what our compliance is measured against. New York State regulations for hazardous waste are found in 6 NYCRR 360-376.
4.2 Hazardous Waste Transportation (Top)
The US Department of Transportation (DOT) regulations govern the labeling, packaging and transportation of all hazardous materials in commerce. EHS provides campus access to the current DOT hazardous materials shipping regulations through a subscription to Label Master – you may access these regulations here:
DOT Haz Mat Regulation Link
Federal regulations governing the transport of hazardous materials are found in 49 CFR 171-173 & 177.
4.3 Generator Status (Top)
Facilities that create hazardous waste are regulated by their “generator status.” This status is divided into three possible categories. Each category is regulated by standards which relate to the total volume of hazardous waste generated at the facility each calendar month, as well as the total amount of hazardous waste in storage. Requirements for management of hazardous waste can vary greatly depending on the facility’s generator status, which can legally change on a month-by-month basis for some facilities.
The EPA and DEC regulate facilities generating hazardous waste in one of the three following categories of generator status: Conditionally Exempt Small Quantity Generator, Small Quantity Generator, and Large Quantity Generator.
4.3.1 Conditionally Exempt Small Quantity Generator (Top)
By regulation, facilities are categorized as Conditionally Exempt Small Quantity Generators (CESQG) if:
- They generate less than 100 kilograms (220 pounds) of hazardous waste in any given calendar month.
- No more than 2,200 pounds of hazardous waste (or 2.2 pounds of acutely hazardous waste, P-listed) may be on site at any one time.
CESQG hazardous waste is exempt from most RCRA regulations. However, these facilities:
- Must identify all hazardous wastes they generate.
- May send wastes to a facility that:
- Beneficially uses or reuses, or legitimately recycles or reclaims, waste.
- Is permitted by EPA or the state to treat waste prior to beneficial use or reuse, or legitimate recycling or reclamation.
4.3.2 Small Quantity Generator (Top)
By regulation, facilities are categorized as Small Quantity Generators (SQG) if:
- Facility generates ≤ 100 kilograms and no more than 1000 kilograms (2200 pounds) of hazardous waste in any calendar month.
- Onsite accumulation time does not exceed 180 days.
- No more than 1 kilogram (2.2 pounds) per month of acute waste is generated.
- Total onsite accumulation cannot exceed more than 6,000 kilograms (13,200 pounds).
(Note: If the onsite accumulation exceeds 6,000 kilograms, the facility is considered a Treatment Storage and Disposal Facility (TSDF) and must have an approved permit.). SQGs are required to have one emergency coordinator who is either on the premises or on call.
SQG Container Management
Containers of hazardous waste generated in any accumulation area at Cornell should comply with the following requirements:
- Use of the original chemical product container for hazardous waste storage is a good management practice. Cornell University does not allow hazardous waste to be stored in containers that previously held household products such as bleach, detergents, or any food products.
- It is not permitted to put the following types of solid materials into containers of liquid hazardous waste: pipettes, magnetic stirrers, vials, test tubes, filters, pH paper.
- Personnel generating hazardous waste must make a conscious effort to prevent chemical contamination of exterior surfaces of waste containers.
Additionally, the following are state and federal regulatory requirements for the management of hazardous waste containers:
- Containers must be compatible with the waste in them.
- Containers must be kept closed except when waste is actually being added.
- Containers must not be leaking, bulging, rusting, damaged, or dented.
Go to Section 7.7 for information on management of empty containers.
180-Day Container Storage
- Containers of hazardous waste must be marked with the date accumulation began, the words HAZARDOUS WASTE, and with other words that identify the contents of the containers. NOTE: The start date is when the first waste is poured / placed into the waste container at the 180-day accumulation point OR the date when the filled container is moved from the satellite accumulation point to the 180-day central storage area. If more than 55 gallons of waste is generated at a satellite area, the excess of 55 gallons must be dated and moved to the 180-day central storage within 72 hours.
- Weekly inspections must be conducted at 180-day storage area.
- There must be sufficient aisle space to allow unobstructed movement of personnel, fire protection equipment, spill control equipment, and decontamination equipment to any area of the operation.
- Required equipment is easily accessible and in working condition and is tested to ensure it is in working condition.
- There is internal communications or alarm system capable of providing immediate emergency instruction to personnel.
- There is a telephone or hand-held two-way radio capable of contacting local and emergency responders.
- There are portable fire extinguishers and fire control equipment, including special extinguishing equipment (foam, inert gas, or dry chemicals).
- There is spill control equipment.
- There is decontamination equipment.
- There are fire hydrants or other source of water (reservoir, storage tank, etc.) with adequate volume and pressure, foam producing equipment, automatic sprinklers, or water spray systems.
- When waste leaves the 180-day storage area, it either is going for disposal, treatment, or recycling.
- No Smoking signs must be conspicuously placed wherever there is a hazard from ignitable or reactive waste.
- Personnel must be thoroughly familiar with waste handling and emergency procedures relevant to their responsibilities during normal facility operation and emergencies.
- SQGs must have an EPA identification number.
- SQGs must use Uniform Hazardous Waste Manifests when sending waste offsite for disposal or recycling.
- SQGs must maintain a copy of each signed manifest for 3 years or until the SQG receives a signed copy from the designated facility which received the waste. The returned signed copy is retained as a record for at least 3 years from the date the waste was accepted by the initial transporter.
- SQGs are required to keep records of waste analyses, tests, and waste determinations for 3 years.
- Emergency information must be posted by the phone.
- If the waste being disposed of is restricted from land disposal, the manifest files should contain a copy of the Land Disposal Restrictions (LDR) notice.
- Documentation of weekly inspections of the 180 storage area.
4.3.3 Large Quantity Generator (Top)
By regulation, facilities are categorized as Large Quantity Generators (LQG) if the facility generates 1000 kilograms ( 2,200 pounds) or more hazardous waste in a given calendar month. These facilities must:
Meet all Small Quantity Generator (SQG) requirements, in addition to the following requirements:
- Place all volatile organic wastes in containers less than 26 gallons in size or in an applicable DOT container.
- Inspect all hazardous waste containers for condition and leaks at least weekly.
- Ship all hazardous waste off site within 90 days of the date the waste was first placed into the RCRA 90 Day Storage Area.
- Develop a facility contingency plan for hazardous waste emergencies and ensure the presence of certain emergency equipment.
- Conduct employee training to ensure RCRA compliance and maintain training records.
- Maintain a 50-foot buffer zone from the facility boundary for container storage of ignitable or reactive wastes.