ECAR Fact Sheet
for Tennessee
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 Tennessee
Department of Environment and Conservation (TDEC) has adopted the
federal hazardous waste regulations (40 CFR Parts 260-279). In
addition, the state has implemented additional requirements regarding
notification, annual reporting, on-site waste storage, off-site
shipments, pollution prevention and fees.
Although Tennessee
follows the federal regulations for identifying hazardous waste,
the state has only adopted a limited amount of the federal waste
exemptions. Therefore, more wastes are considered hazardous waste
in Tennessee.
The TDEC has
prepared guidance documents to help auto recyclers manage hazardous
waste. Much of the information is included in the fact sheet below
or you can access the TDEC’s Hazardous Waste Notification
and Reporting Requirements website for more information on managing
hazardous wastes.
To comply with
Tennessee’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. Tennessee uses the word
“waste” to denote solid waste. The term “solid waste,” as used in
Tennessee, means waste that is not hazardous. Hazardous waste is
considered a subset of waste.
Hazardous
Waste Determination. It
is the responsibility of all 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) of hazardous waste per month.
- Small Quantity Generator (SQG). You are considered an SQG if
you generate greater than 100 kilograms (220 pounds) but less
than 1,000 kilograms (2,200 pounds) of hazardous waste in a calendar
month.
- Large Quantity
Generator (LQG). You are considered an LQG if you generate
1,000 kilograms (2,200 pounds) or more of hazardous waste in a
calendar month. You also are considered an LQG if you generate
during a calendar month, or accumulate at any time, more than
one kilogram of acutely hazardous waste, or more than a total
of 100 kilograms (220 pounds) of any residue, contaminated soil,
waste, or debris from cleaning up a spill of any acutely hazardous
waste onto land or into water.
*The TDEC has
implemented additional generator requirements regarding annual reporting,
fees, notifications, ID numbers, and on-site storage of hazardous
waste without a permit.
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. See TDEC’s Hazardous Waste Notification
and Reporting Requirements for more details
Links to
the Regulations. Use
the following links to view the regulations pertaining to hazardous
waste management.
Tennessee’s
Hazardous Waste Management Requirements
Federal EPA Standards Applicable
to Generators of Hazardous Waste
Contacts
- For more information, contact the Tennessee Division
of Solid and Hazardous Waste Management at 615-532-0780.
- To report a spill or leak, call the Tennessee State
Emergency Operations Center 24-hour hotline at 800-262-3300, or
the National Response Center at 800-424-8802.
- To report an environmental incident or complaint, contact
the nearest regional office.
Other Relevant Resources
- Tennessee - Permitted
Hazardous Waste Transporters
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