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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 state of Montana has received RCRA authorization from the federal Environmental Protection Agency (EPA). In addition, Montana has implemented additional requirements that make their regulations more stringent than federal regulation. The Montana Department of Environmental Quality (DEQ) has prepared a guidance document to help auto recyclers manage hazardous waste. Much of the information is included in the fact sheet below. To comply with Montana’s hazardous waste requirements, you must follow the steps below:
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.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.
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.
Compying 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. It is important to note that other state government agencies or city and county regulatory agencies may have additional requirements for managing hazardous waste. Contact your County Regulatory Personnel or call the MT DEQ, Air & Waste Management Bureau at (406) 444-3490 for more information. Links to the Regulations. Use the following links to view the regulations pertaining to hazardous waste management. Montana’s Hazardous Waste Management Requirements Montana’s Motor Vehicle Recycling and Disposal Requirements Federal EPA Standards Applicable to Generators of Hazardous Waste Contacts
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