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REQUIREMENTS FOR REGULATED MOTOR FREIGHT & RAILROAD TRANSPORTATION FACILITIES
The following table presents an overview of the federal RCRA regulatory requirements for motor freight and railroad transportation facilities that are either LQGs,
SQGs, or CESQGs. As noted, your state might have different or more stringent requirements.

RCRA REGULATORY REQUIREMENTS

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REGULATORY
LQGS SQGS CESQGS IMPLEMENTATION EXPLANATION
REQUIREMENT
EPA Identification Obtain an EPA identification number for each facility within your company. EPA and states use this 12-character identification num-
Number ber to track hazardous waste activities.
Obtain an EPA identification number by submitting Form 8700-12 (Notification of Regulated Waste Activity), which is provided by

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your state hazardous waste agency. This is a one-time notification. Contact your state regarding the need for renotification if cir-
cumstances at your facility change.

Hazardous Waste Identify whether you generate hazardous waste to determine if you are subject to the RCRA hazardous waste regulations. Test
Identification procedures are described in Test Methods for the Evaluation of Solid Waste, Physical/Chemical Methods, SW-846 or tests can

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be performed by a local laboratory.

Used Oil Standards If you generate used oil, you are subject to a separate set of management standards from the hazardous waste management
standards if the used oil will be recycled. If the used oil is to be treated and disposed of, perform the hazardous waste identifica-
tion step listed above.

Waste Counting Determine how much hazardous waste you generate to determine your generator status.

Accumulation Area You can accumulate waste in a satellite accumulation area with minimal regulatory burden. This area must be at or near the
point of generation and under the control of the operator of the process generating the waste.
There is no time limit on accumulation in the satellite accumulation area for waste under 55 gallons.
There is a 55-gallon accumulation limit in the satellite accumulation area. Excess waste beyond the 55-gallon limit must be moved
from the satellite accumulation area within 3 days.
You must accumulate the waste in containers.
Waste containers must be marked with the words Hazardous Waste or other words that identify their contents.
This waste is exempt from other accumulation provisions while in the satellite accumulation area.

Other Accumulation If waste accumulation does not meet the requirements for satellite accumulation, it is subject to more stringent requirements.
Areas (Time and LQGs can accumulate waste on site for up to 90 days without a permit. SQGs can accumulate waste for 180 days, or 270 days if
Quantity Limits) the SQG must transport the waste more than 200 miles to a destination facility.
Begin counting accumulation time when waste is first placed in the accumulation unit.
Waste must be put in an exempt unit, recycled, or sent off site within the proper time period stated above.
If an LQG accumulates wastes beyond the allotted time period, the facility is fully subject to the requirements of a hazardous waste
storage facility unless granted an exemption. SQGs cannot accumulate more than 6,000 kg of hazardous waste at any time.
CESQGs cannot accumulate more than 1,000 kg of hazardous waste, more than 1 kg of acutely hazardous waste, or 100 kg of
spill residue from acutely hazardous waste at any time.

Storage Unit Accumulate waste only in units that are in good condition, remain closed except when adding or removing waste, are inspected at
Requirements least weekly, are compatible with the types of waste, and meet special standards for ignitable waste and incompatible waste.
LQGs can use accumulation tanks and containers that have been assessed for integrity, have a secondary containment system,
and are inspected each operating day. SQGs can use certain accumulation tanks as well.
LQGs can use containment buildings as well.
For all units, the date that the accumulation period begins must be clearly marked and visible on each container. All containers
and tanks must be clearly marked or labeled with the words Hazardous Waste and accumulation units must be shut down and
closed permanently in accordance with standards at the end of the unit life.
LQGs and SQGs can treat their waste without a RCRA storage permit in accumulation units that meet standards.

Air Emissions LQGs must comply with organic air emissions requirements.

Preparedness and LQGs and SQGs must comply with preparedness and prevention requirements, including the following:
Prevention - An adequate internal alarm or communications system.
- A device capable of summoning emergency personnel.
- Portable fire control equipment.
- Adequate water pressure to operate fire control systems.
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Preparedness and LQGs and SQGs must comply with preparedness and prevention requirements, including the following:
Prevention - An adequate internal alarm or communications system.
- A device capable of summoning emergency personnel.
- Portable fire control equipment.

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- Adequate water pressure to operate fire control systems.
- Adequate testing and maintenance of all emergency systems.
- Access to communication or alarm systems during waste handling activities.
- Adequate aisle space for emergency response.
- An arrangement with local emergency response authorities.
Contingency Plan LQG facilities must prepare a facility contingency plan in accordance with regulations.
The contingency plan must be designed to minimize hazards from fires, explosions, or any unplanned release of hazardous waste
or constituents.
A copy of the contingency plan must be kept on site and an additional copy must be submitted to all local emergency services
providers.

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LQGs and SQGs must have an emergency coordinator on site or on call at all times to respond to emergencies.
Emergency response information must be posted next to the telephone.
In the event of a fire, explosion, or release that could threaten human health outside the facility, or when a spill has reached sur-
face water, the emergency coordinator must notify the National Response Center at 800 424-8802.

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Personnel Training LQGs must have a personnel training program in accordance with regulatory standards.
- Training must instruct facility personnel about hazardous waste management procedures and emergency response.
- Training must be completed within 6 months from the applicability of requirements.
- The facility must undertake an annual review of initial training.
SQGs must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures relevant to
their responsibilities.

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DOT Packaging Before being transported, waste must be packaged, labeled, and marked in accordance with applicable DOT requirements. Call
the DOT hazardous materials information line at 202 366-4488 for information.

Offsite Management Hazardous waste sent off site for handling may only be sent to a hazardous waste TSDF or recycling facility unless otherwise exempt.
of Waste CESQGs: See onsite management of waste below.

Onsite Management CESQGs may either treat waste on site, if it qualifies as one of the following types of facilities, or ensure delivery of waste to one
of Waste of the following types of facilities: permitted RCRA TSDF; interim status TSDF; state-authorized to handle hazardous waste; per-
mitted, licensed, or registered by state to handle municipal solid waste according to standards; permitted, licensed, or registered
by state to handle nonmunicipal waste; if managed after January 12, 1998, facility is permitted, licensed, or registered by state to
handle nonhazardous waste in accordance with standards; facility beneficially uses or reuses, or legitimately recycles or reclaims
its waste; facility treats its waste prior to beneficial use, reuse, or legitimate recycling or reclamation; or a universal waste handler
in accordance with standards.

Manifest Hazardous waste sent off site must be accompanied by a manifest, a multipage form that documents the waste's progress
through treatment, storage, and disposal. It can usually be obtained from your state agency.
The manifest must have enough copies to provide the generator, each transporter, and the destination facility with one copy for
their records and a second copy to be returned to the generator after completion by the destination facility operator.
SQGs that have a contractual agreement with a waste reclaimer that specifies the types and frequencies of shipments do not
need to manifest the wastes if they retain a copy of the agreement in their files.

Land Disposal Waste must meet certain treatment standards under the Land Disposal Restrictions program when waste is land disposed. Waste
Restrictions must be treated to reduce the hazardous constituents to levels set by EPA or the waste must be treated using a specified technol-
Notification ogy. All waste sent off site for treatment, storage, and disposal must be accompanied by appropriate LDR program notifications
and certifications. There are no required forms, but these papers must indicate whether or not wastes meet treatment stan-
dards or whether the waste is excluded from the definition of hazardous or solid waste, or is otherwise exempt.

Hazardous Waste To encourage generators to produce less hazardous waste, LQGs are required to have a program in place to reduce the volume
Minimization and toxicity of waste generated to the degree economically practicable, and must select a currently available treatment, storage,
or disposal method that minimizes present and future threats.
LQGs and SQGs must sign a certification of hazardous waste minimization on the manifest.
SQGs must make a good faith effort to minimize waste generation and to select the best available waste management method
that they can afford.
Biennial Report LQGs must submit biennial reports of waste generation and management activity by March 1 of every even-numbered year. EPA,

other agencies, and the public use this information to track trends in hazardous waste management.
Recordkeeping LQGs must maintain personnel training records until the facility closes.
LQGs must keep copies of each biennial report for 3 years.
LQGs and SQGs must keep a copy of each manifest for 3 years.
LQGs and SQGs must keep records of test results, waste analyses, and other hazardous waste determinations for 3 years.