waste that is being transported can be sent only to a permitted treatment, storage, and disposal facility (TSDF). It cannot be moved legally to an unpermitted holding facility if such movement requires transport along a public road, even if the public road and the receiving location are within the boundaries of an institution. This has caused serious management problems for some multibuilding institutions and companies.

Generators must obtain an EPA identification number, prepare the waste for transport, follow accumulation and storage requirements, manifest hazardous waste, and adhere to detailed record-keeping and reporting requirements. Although conditionally exempt small-quantity generators are partially exempt from these requirements, they must still

  • identify their waste to determine whether it is hazardous,

  • not accumulate more than 1,000 kg of hazardous waste, and

  • treat or dispose of the waste on site, or ensure that the waste is sent to a permitted TSDF or a recycling facility.

Also, generators producing more than 1 kg in a calendar month of "acute hazardous waste" (see below) are subject to full regulation under RCRA.

While some industrial research laboratories and a few large universities have on-site EPA-permitted TSDFs, most colleges and smaller universities and research institutions do not. Their hazardous waste is shipped off-site, treated, stored, and disposed of at commercial EPA-permitted TSDFs. The process and requirements for EPA-permitting of a TSDF are very complex, involving construction of costly facilities, detailed operational plans, and specialized staff.

It is important to note that state classification of generators may be different from the classifications outlined above. Some states regulate all generators of hazardous waste with no exemptions, and some states classify generators by waste type rather than by volume.

9.D.2 Definition of Hazardous Waste

RCRA defines "hazardous waste" as solid waste that, "because of its quantity, concentration, or physical, chemical, or infectious characteristics may: 1) cause, or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness or 2) pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed."

A "solid waste" under RCRA need not be solid! "Solid waste" is defined as "any ... discarded material, including solid, liquid, semisolid, or contained gaseous material ..." The term "discarded" includes any material that is abandoned, recycled, or "inherently wastelike.'' The term "hazardous waste" means any solid waste (as defined above) that:

  • exhibits any of the characteristics of a hazardous waste (i.e., ignitability, corrosivity, reactivity, or toxicity as determined by EPA's Toxicity Characteristic Leaching Procedure (TCLP) test);

  • has been listed as a hazardous waste by EPA regulation;

  • is a mixture containing a listed hazardous waste and a nonhazardous solid waste; or

  • is a waste derived from the treatment, storage, or disposal of a listed hazardous waste.

Certain otherwise hazardous wastes are excluded from regulation. These include samples sent for testing, household waste, agricultural waste (not including pesticides), oil and gas production waste, and others not generally associated with laboratory activities.

The RCRA regulations contain detailed provisions and testing procedures for determining if any particular chemical waste, not specifically listed in the regulations, is a "hazardous waste" within the RCRA definition.

"Acute hazardous wastes" are those listed as such in 40 CFR 261.31 (the F020-27 series, the dioxin precursors) and 261.33 (e), the P list.

9.D.3 Accumulation Times and Amounts

Under RCRA, a large-quantity generator may accumulate hazardous waste for up to 90 days without a special EPA permit, providing

  • the waste container is in good condition,

  • the container material or liner is compatible with the waste contained,

  • the container is kept closed except when actually adding or removing waste, and

  • the container is properly handled and stored.

To accumulate waste for a longer period, an EPA permit as a "storage facility" is required. Some larger institutions have a central EPA-permitted TSDF, and longer storage times are allowed in accordance with the regulations and the permit conditions applicable to that institution.

9.D.4 Satellite Accumulation

One RCRA regulation of particular relevance to academic and research laboratories is the provision that



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