As you may know, the federal Resource Conservation and Recovery Act (RCRA) and the implementing federal regulations at 40 CFR Parts 260-272 govern hazardous waste management. Many states also have their own, sometimes more stringent, regulations. Not only is hazardous waste management one of the most common environmental issues at college and university campuses, but the specific requirements for hazardous waste (RCRA) are so numerous, the tour has, as appropriate, split the content into three areas as follows:
- RCRA (Storage/Disposal)
- RCRA (Recordkeeping)
- RCRA (Training/Other)
A facility that stores hazardous waste needs to make sure that the storage area and containers or tanks pose no risk to the environment or human health and safety. Chances are if your school operates a hazardous waste storage area, then you are subject to certain inspection requirements (among others) under the Resource Conservation and Recovery Act (RCRA). These inspection requirements place the responsibility on the hazardous waste generator who stores hazardous waste for ensuring that any leaks, spills or other conditions of potential risk are identified systematically and soon enough to avoid larger incidents. The nature of these requirements varies according to how much waste your facility generates during a given month.
The overall intent of RCRA is to manage hazardous waste from generation to ultimate disposal. This "cradle to grave" approach has resulted in regulations governing hazardous waste generators, transporters, and treatment, storage, and disposal (TSD) facilities. Given that most university facilities do not themselves transport hazardous waste to an off-site hazardous waste disposal facility, treat hazardous waste, or operate a hazardous waste disposal facility, the regulations governing these activities are not addressed in the tour. More typically, your facility would generate, store the waste and then have a contractor transport the waste off site for disposal. The specific hazardous waste management requirements a facility must follow depend on the facility's generator status and the types of waste it produces. In other words, the generator status of the college or university will determine the type of requirements the facility may need to follow.
Most colleges and universities have Satellite Accumulation Areas. A Satellite Accumulation Area is a designated area near a process or location that generates hazardous waste where wastes are stored until they are moved to a central Hazardous Waste Accumulation area. Federal regulations allow generators to store up to 55 gallons of hazardous waste or one quart of an acutely hazardous waste in the satellite accumulation area. There is no limit on the amount of time to accumulate the waste. However, once a container is considered full, the generator has 72 hours to have the container transferred to the institution's hazardous waste storage area. From there the waste is shipped to a licensed hazardous waste treatment, storage or disposal facility.
If you operate an area for storing hazardous waste and want to learn more about required inspections, then continue on with this tour. You should also note that some individual states may have more stringent requirements than the federal requirements for hazardous waste storage area inspections; consult your state's environmental regulations for these requirements.