Hazardous Wastes

ECAR Fact Sheet for Alabama
Hazardous Wastes

The intent of the hazardous waste program is to provide a cradle-to-grave management system for hazardous wastes to ensure that these wastes are not mismanaged in a way that will impact human health or the environment.

The Alabama Department of Environmental Management (ADEM) follows the federal hazardous waste regulations (40 CFR Parts 260-279) and has implemented other state-specific requirements.

The ADEM has prepared guidance documents to help auto recyclers manage hazardous waste. Much of the information is included in the fact sheet below. ADEM guidance documents include:

To comply with Alabama's hazardous waste requirements, you must follow the steps below:

Determine whether any hazardous waste is generated.
Determine your facility's generator status.
Determine which regulations must be complied with depending upon your facility's generator status, and comply with those requirements.

Regulations

Definition of Solid Waste. In order for a waste to be considered a hazardous waste, it must first meet the definition of solid waste. The term "solid waste" can be somewhat misleading. The word "solid" does not refer to the physical state of the waste. Solid waste can be a solid, liquid, or contained gas. Under the hazardous waste rules, a solid waste is any material that will no longer be used for its original intended purpose, or a material that must be reclaimed before reuse. You will need to look at each of the waste streams generated (e.g., antifreeze, used oil, solvents, etc.) and determine whether it is a solid waste. Note that not all solid wastes are considered hazardous wastes. Certain solid wastes, such as used oil destined for recycling, are excluded from the hazardous waste rules.

According to the Alabama Hazardous Wastes Management and Minimization Act, a hazardous waste is a waste that, because of its quantity, concentration or physical, chemical or infectious characteristics may: a) cause, or significantly contribute to, an increase in mortality or an increase in serious irreversible, or incapacitating

reversible, illness; or b) pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported or disposed of, or otherwise managed.

Hazardous Waste Determination. It is the responsibility of all solid waste generators to determine whether their waste is hazardous. The procedure for this is called a "hazardous waste determination." You may assume a waste is hazardous based on its characteristics or on past laboratory analysis provided there is no change in how the waste was generated. In some cases, you may use your knowledge of a waste to make a determination as to whether the waste is a characteristic hazardous waste. If you use such information to classify a waste as nonhazardous, you must maintain documentation supporting this determination. If you are not sure, have the waste tested. Keep in mind that a non-hazardous waste may become hazardous if contaminated or mixed with other materials and re-testing would be needed.

Wastes can be hazardous if they are either "listed" or "characteristic", or if they are a mixture of a listed hazardous waste and other wastes.

A.Listed wastes. Waste is considered hazardous if it is found on any one of four "lists". These "lists" are called the "F", "K", "P" and "U" lists.

B.Characteristic wastes. Once a facility has reviewed the F, K, P and U lists, and determined whether generated wastes are found on any of the lists, a determination will need to be made to see if these wastes are "characteristic" hazardous wastes. There are four different characteristics: ignitability, corrosivity, reactivity, and toxicity.

IGNITABLE - combustible under certain conditions
CORROSIVE - highly acidic, basic and/or capable of corroding metal
REACTIVE - unstable under normal conditions and capable of creating explosions and/or toxic fumes, gases, and vapors when mixed with water
TOXICITY - wastes contain dangerous amounts of metals, pesticides, herbicides, and organic chemicals that could be released to the groundwater.

C.Mixtures of listed wastes and other wastes. A mixture containing a non-hazardous solid waste and any amount of a listed hazardous waste is considered a hazardous waste. For example, if a pint of spent solvent such a toluene or benzene (an F005 listed hazardous waste) is mixed with a 55 gallon drum of waste antifreeze, the entire mixture (e.g., 55 gallons plus one pint) is considered a hazardous waste (as opposed to only one pint being a hazardous waste had the two wastes not been mixed). Hence, it is very important to keep wastes segregated. Not only is it better for the environment, but it will reduce disposal costs (it's more expensive to dispose of hazardous waste than it is solid waste).

D.Universal Wastes. Universal wastes have fewer waste management rules that apply to them. For more information about the generation, storage, transportation, disposal and recycling of universal wastes, refer to the state's universal waste requirements.

Generator Status. If you manage hazardous waste, you must determine your generator status. Your facility will fall under one of these three classifications.

Conditionally Exempt Small Quantity Generator (CESQG). You are considered a CESQG in a calendar month if you generate no more than 100 kilograms (220 pounds) or 2.2 pounds of acute hazardous waste per month. A CESQG cannot accumulate more than 2,200 pounds of hazardous waste or 2.2 pounds of acute hazardous waste at any time.

Small Quantity Generator (SQG). You are considered an SQG if you generate less than 2,200 pounds of hazardous waste and no more than 2.2 pounds of acute hazardous waste in a calendar month. An SQG cannot accumulate more than 13,200 pounds of h hazardous waste or 2.2 pounds of acute hazardous waste at any time. Normally, hazardous waste cannot be accumulated on-site for more than 180 days (up to 300 days for special circumstances).

Large Quantity Generator (LQG). You are considered an LQG if you generate 2,200 pounds or more of hazardous waste or more than 2.2 pounds of acute hazardous waste in a calendar month. Normally, hazardous waste cannot be accumulated on-site for more than 90 days (up to 120 days for special circumstances).

Complying with Hazardous Waste Rules. Once you have determined whether you generate hazardous waste and your generator status, you can determine which requirements apply to you.

Links to the Regulations. Use the following links to view the regulations pertaining to hazardous waste management.

Alabama Hazardous Waste Management Requirements (Division 14)

Federal EPA Standards Applicable to Generators of Hazardous Waste

Hazardous Waste Listings

Contacts

For more information, contact the Alabama Department of Environmental Management (ADEM) Land Division, Hazardous Waste Branch, at 334-271-7730.
To report a spill or leak, call the ADEM's 24-hour hotline at 800-843-0699, or the National Response Center at 800-424-8802.
To report an environmental incident or complaint, contact the nearest regional office.

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ECAR Fact Sheet for Alabama Hazardous Wastes

Contacts

ECAR Fact Sheet for Alabama
Hazardous Wastes