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XI. Solid and Hazardous Waste

Source: EPA 1994 Toxics Release Inventory
Public Data Release, Appendix A:
Questions and Answers

Q80 What role do TRI data play in chemical accident prevention?

A TRI data are used to support two activities related to chemical accident prevention:

TRI data are used to identify chemical handling facilities that could benefit from information on chemical process safety for preventing accidental chemical releases.

TRI data are used as one source of background material in learning more about facility activities. For example, these data can assist a team in preparing for a chemical safety audit at a particular chemical-handling facility.

Q81 How can a Local Emergency Planning Committee (LEPC) use the TRI data?

A LEPCs can use the TRI data for emergency planning for response to chemical accidents. The LEPCs receive notifications of accidental releases under EPCRA section 304. They can compare the data received under section 304 to the TRI data to help screen the risks posed by manufacturing facilities in their community. They also can review TRI information along with chemical inventory information submitted by facilities under sections 311 and 312 of EPCRA to obtain a "chemical profile" of their community for use in planning for response to chemical accidents.

Q82 Are the TRI chemicals regulated under the provisions of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)?

A Of the 343 individually listed TRI chemicals reportable for 1994, 322 are also CERCLA hazardous substances. TRI chemicals that are also CERCLA hazardous substances are subject to all of the requirements of CERCLA, as amended by SARA, such as reporting, liability, and penalties.

Q83 How do the EPCRA section 313 reporting requirements compare to CERCLA reporting requirements?

A There are few similarities between the reporting requirements of EPCRA section 313 and those of CERCLA section 103. Section 313 requires the owner or operator of a facility where a toxic chemical is manufactured, processed, or otherwise used to submit a toxic chemical release form to EPA when the quantity of the toxic chemical exceeds the threshold quantity established by section 313(f) of EPCRA.

The reporting requirements of section 103 of CERCLA require any person in charge of a vessel or facility to report the release of a hazardous substance into the environment, in a quantity equal to or greater than its "reportable quantity," to the National Response Center. The purpose of reporting under CERCLA section 103 is to allow the Federal government to assess each reported release to determine if a response action is warranted.

Q84 How many TRI chemicals are regulated under the Resource Conservation and Recovery Act (RCRA)?

A Approximately two-thirds of the 343 individually listed TRI chemicals reportable for 1994 are regulated under RCRA. Forty of the individually listed TRI chemicals are currently used to identify a waste as a characteristic hazardous waste under RCRA. When such chemicals are found in the waste above specified levels, the waste is subject to RCRA regulation. In addition, 153 of the individually listed TRI chemicals are also listed as hazardous wastes when they are unused or discarded in commercial chemical products under RCRA.

Q85 How many facilities are regulated by the RCRA program and what is the overlap with facilities that report for TRI?

A Under Subtitle C, RCRA regulates about 5,000 Treatment, Storage, and Disposal facilities (TSDs). RCRA also regulates more than 200,000 large- and small- quantity generators (LQGs and SQGs) and about 18,000 transporters.

Of the generators that are regulated under Subtitle C of RCRA, approximately 17,000 LQGs report RCRA waste generation and management activities biennially via the National Hazardous Waste Report (biennial report). Approximately 7,000 of the LQGs report to the TRI. These sites and facilities are listed in the Resource Conservation and Recovery Information System (RCRIS) and may be cross-checked with TRI facilities by EPA ID number.

Q86 How are TRI releases of hazardous wastes regulated under RCRA?

A Hazardous wastes must be stored, treated, or disposed of in hazardous waste management units regulated under the RCRA or under authorized state laws. Hazardous waste land disposal units, including landfills, land treatment, surface impoundments, and waste piles, must meet applicable design and operating controls, such as liners and leak detection systems and groundwater monitoring systems to detect releases out of the unit. All facilities that store, treat, or dispose of hazardous wastes are subject to corrective action requirements to clean up hazardous wastes or hazardous constituents that migrate from any waste management unit at the facility.

Q87 Are all land releases reported under TRI regulated under RCRA?

A Some land releases may be accidental releases of chemicals in wastes that are not regulated by RCRA. Most of the land releases reported to TRI fall under one of the following categories: on-site disposal of hazardous wastes which are regulated under RCRA or authorized state hazardous waste programs; and industrial solid waste or waste from mining and mineral processing activities that would be regulated under state solid waste management programs insofar as they do exist. Some mineral processing wastes are regulated as hazardous wastes.

Under EPCRA section 313, facilities that manufactured or processed 25,000 pounds or used 10,000 pounds of a listed chemical must report. Under RCRA, those facilities that generate more than 100 kilograms (220 pounds) of hazardous waste per month must report.

Q88 Can direct comparisons be made between TRI data and RCRA data for amounts of toxic waste generated, waste minimization, etc.?

A It is difficult to make comparisons for several reasons:

TRI reports individual chemical constituent data; RCRA requires reporting on a total waste stream that represents a substantially larger volume than any single chemical contained in the waste stream. A RCRA hazardous waste stream may or may not contain TRI chemicals.

RCRA distinguishes between regulated and exempt wastes. A particular TRI chemical may occur in a waste that is exempt and need not be reported under RCRA. For example, certain wastewater treatment activities are exempt from RCRA, as are the activities of small-quantity generators who generate less than 100 kg/month of hazardous waste.

Currently, only facilities in SIC codes 20-39 are required to report to TRI; RCRA reporting is not limited by SIC code.

Under RCRA, hazardous waste generators are required to report on existing or planned waste minimization activities at facilities on a biennial basis. The current reporting forms request information on reduction of the volume of waste generated. These data differ from TRI data in that they represent specific RCRA waste streams rather than individual chemical constituents. EPA's Office of Solid Waste is exploring approaches to refine the utility of the waste minimization data collected through the biennial reporting system and to coordinate the results with TRI data.

Source: USEPA 1994 Toxics Release Inventory Public Data Release (EPA 745-R-96-002, June 1996).

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