The EPA’s cradle‐to‐grave hazardous waste management system is an attempt to track hazardous waste from its generation point (the “cradle”) to its ultimate disposal point (the “grave”) (Figure 4.16). Arguably, the most notable provisions of the RCRA statute are included in Subtitle C, which directs EPA to establish controls on the management of hazardous wastes from their point of generation, through their transportation and TSD. Because RCRA requires controls on hazardous waste generators (i.e. sites that generate hazardous waste), transporters, and treatment, storage and disposal facilities (TSDFs) (i.e. facilities that ultimately treat/dispose of or recycle the hazardous waste), the overall regulatory framework has become known as the “cradle‐to‐grave” system. The program imposes stringent record keeping and reporting requirements on generators, transporters, and operators of TSDFs handling hazardous waste.
The uniform hazardous waste manifest (the manifest) is the key to cradle‐to‐grave waste management (Section D.6). Through the use of a manifest, generators can track the movement of hazardous waste from point of generation to the point of ultimate TSD.
Nonhazardous Solid Wastes
Nonhazardous solid wastes include certain hazardous wastes which are exempted from the Subtitle C regulations, such as hazardous wastes from households and from conditionally exempt small quantity generators. Oil and gas exploration and production wastes, such as drill cuttings, produced water, and drilling fluids are categorized as “special wastes” and are also exempt from Subtitle C (USEPA 2002b), Subtitle D also includes garbage (e.g. food containers, coffee grounds), nonrecycled household appliances, residue from incinerated automobile tires, refuse such as metal scrap, construction materials, and sludge from industrial and municipal wastewater facilities and drinking water treatment plants.
Underground Storage Tanks
Background
The operation of underground storage tanks (USTs) became subject to the RCRA regulatory program with enactment of the Hazardous and Solid Waste Amendments of 1984. At that time there were about 2.1 million tanks subject to federal regulation, and the EPA program led to closure and removal of most substandard tanks. As of 31 March 2019 there were approximately 548 700 active USTs at 198 000 sites subject to federal regulation (USEPA 2019a).
The new regulations include a number of exclusions:
- Hazardous waste UST systems
- Regulated wastewater treatment facilities
- Any UST system of less than 41.5 l
- Any UST system containing a de minimis (negligible) concentration of regulated substances
- Any emergency spill or overflow containment system that is expeditiously emptied after use
Transportation of Hazardous Waste
This section covers important aspects of transporting hazardous wastes. This should familiarize readers with the complexity of the risks and challenges involved. In 1975, the US Congress passed the Hazardous Materials Transportation Act. The intent of this law was to improve regulatory and enforcement activities by giving the Secretary of Transportation broad authority to regulate all aspects of hazardous material transport. The mode of such transportation includes aircraft, water‐craft, motor vehicle, and railway.
Table 4.12 Classification of hazardous materials for shipping and packaging.
Source: 40 CFR 173.
| Hazard | Class | Division |
| Forbidden materials | — | — |
| Forbidden explosives | — | — |
| Explosives (with a mass explosion hazard) | 1 | 1.1 |
| Explosives (with a mass projection hazard) | 1 | 1.2 |
| Explosives (with predominantly a fire hazard) | 1 | 1.3 |
| Explosives (with no significant blast hazard) | 1 | 1.4 |
| Very intensive explosives, blasting agents | 1 | 1.5 |
| Extremely insensitive detonating substances | 1 | 1.6 |
| Flammable gas | 2 | 2.1 |
| Nonflammable compressed gas | 2 | 2.2 |
| Poisonous gas | 2 | 2.3 |
| Flammable and combustible liquid | 3 | — |
| Flammable solid | 4 | 4.1 |
| Spontaneously combustible material | 4 | 4.2 |
| Dangerous when wet material | 4 | 4.3 |
| Oxidizer | 5 | 5.1 |
| Organic peroxide | 5 | 5.2 |
| Poisonous materials | 6 | 6.1 |
| Infectious substance (etiological agent) | 6 | 6.2 |
| Radioactive material | 7 | — |
| Corrosive material | 8 | — |
| Miscellaneous hazardous material | 9 | — |
| Other regulated materials | — | — |
The U.S. Federal Aviation Administration enforces regulations pertaining to air transportation. The U.S. Coast Guard enforces regulations pertaining to water transportation. Similarly, the U.S Federal Highway Administration enforced regulation associated with hazardous waste transportation by highways and railroads, respectively.
Table 4.12 lists the classifications of hazardous materials that are subject to federal transportation regulations. The purpose is to regulate materials likely to cause injury to public and the carrier personnel if they are accidently released during transport. The Hazardous Materials Table in 49 CFR 172.101 further defines the labeling, packing, and carrier requirements for specific hazardous chemicals (see Section 4.5.13).
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