Comparison of State and Federal Hazardous Waste Rules
General Summary (find a description of Federal Rules here).
Connecticut follows the federal rules for hazardous waste management and also has more stringent state requirements.
1. Do I need an EPA ID number to handle hazardous wastes
In Connecticut, use the EPA Form 8700-12: Notification of Regulated Waste Activity Forms and Instructions, to determine if you are subject to the requirements under the Resource Conservation and Recovery Act (RCRA) for notifying the State of Connecticut of your regulated waste activities. You can also contact CT-DEP's Waste Engineering and Enforcement Division at 860-424-3023 and request EPA Form 8700-12, Notification of Hazardous Waste Activity. Send your completed form(s) to the designated contact listed in the instructions. For further information, view Connecticut's permit information web page.
2. How do I determine my generator status?
Connecticut generally follows the federal rules for defining generator status but defines SQG's and CESQG's differently.SQGs are generators who in a calendar month generates more than 100 but less than 1,000 kilograms (kg) of hazardous waste in that calendar month, provided that such waste does not include more than a total of: 1 kg of acute hazardous wastes or 100 kg of any residue or contaminated soil, waste, or other debris resulting from the cleanup of a spill, into or on any land or water, of any acute hazardous wastes, provided that there is no more than a total of 1 kg of acute hazardous waste contained in that residue, soil, waste, or debris. CESQGs are generators who in a calendar month generates no more than 100 kg of hazardous waste in that calendar month, provided that such waste does not include more than a total of: 1 kg of acute hazardous wastes or, 100 kg of any residue or contaminated soil, waste, or other debris resulting from the cleanup of a spill, into or on any land or water, of any acute hazardous wastes, provided that there is no more than a total of 1 kg of acute hazardous waste contained in that residue, soil, waste, or debris. CESQGs are prohibited from disposing of hazardous waste in solid waste facilities. CESQGs must also meet state requirements regarding mixtures of hazardous and nonhazardous waste, recordkeeping, and off-site transportation of hazardous wastes.
3. How can I tell if the waste materials I handle are considered
Connecticut generally follows the federal rules for defining hazardous wastes. All generators must determine whether their generated waste is a hazardous waste and must be made at least once during each 12-month period or whenever a process generating a waste changes. Connecticut has not adopted all of the federal exclusions as to what constitutes waste and hazardous waste.
4. How long can I store hazardous wastes on site?
Connecticut generally follows the federal rules for storing hazardous wastes and also has more stringent state requirements.Owners and operators of containers, hazardous waste storage tanks, and surface impoundments at permitted or interim-status hazardous waste storage facilities must pay the following fees: Storage permit application fee of $21,000; Annual permit fee of $1,500; and an annual groundwater monitoring fee of $750 (if the facility's permit requires groundwater monitoring) LQGs and SQGs are required to follow the federal rules for secondary containment for containers.LQGs and SQGs must also mark containers and tanks with other words that identify the contents of the container or tanks or with the chemical name. This includes satellite accumulation areas Generators must inspect their storage areas in accordance with federal inspection requirements.Satellite accumulation areas meet the following state requirements: Federal facility maintenance and operation standards to minimize the possibility of fire, explosion, or any unplanned sudden or nonsudden hazardous waste release; and the special federal requirements for incompatible waste LQGs and SQGs must meet federal closure performance standards.LQGs can store hazardous waste on-site for up to 90 days without a permit, if they comply with the federal accumulation rules and the following state provisions: Compliance with the general federal requirements for ignitable, reactive, or incompatible wastes; container secondary containment for containers; and waste analysis and trial tests on tanks in accordance with federal rules. SQGs can accumulate only up to 1,000 kg of hazardous waste on-site for 180 days or less, or for 270 days if the waste is to be transported over a distance of 200 miles for off-site treatment, storage, or disposal.SQGs can accumulate hazardous waste only in containers or tanks and is not allowed to operate uncovered tanks.SQGs must report any release that has been reported to the NRC separately to DEP by using the 24-hour emergency spill response telephone number and submit a written report.
5. Who can transport and receive the wastes I ship off site?
Connecticut generally follows the federal rules for shipping hazardous wastes.Hazardous waste generators must use DEP permitted transporters.Connecticut has additional requirements in connection with the manifest form, and the completion and distribution of the manifest. All in-state generators must use the state's manifest form. DEP must receive a copy of the manifest within seven days of the date that the transporter signs and accepts the manifest.There is no manifest exemption for SQGs having a contractual agreement with a reclaimer.
6. What records do I have to keep?
Connecticut generally follows the federal rules for recordkeeping. CESQGs must keep records of any test results, waste analyses, or other hazardous waste determination information for at least three years.
7. Do I have to file reports?
Connecticut generally follows the federal rules for reporting. LQGs must submit biennial reports. Generators may also be asked to submit information about other activities in addition to the information required under the federal rules.
8. What training requirements do I have to meet?
Connecticut generally follows the federal rules for training. Hazardous waste transporters must meet state training requirements in regard to safety equipment; first aid; loading and unloading hazards; manifests; waste properties and emergency procedures.
9. What differences between states may exist with regard to use of the the new standardized manifest form?
As of September 5, 2006, the new standardized manifest form (EPA Form 8700-22) and its continuation sheet (EPA Form 8700-22A) must be used in every state to track hazardous waste shipments. There will be no state variations of the new federal form and states may not require information to be included on the form that is in addition to that required by federal rules. That said, some differences between states may exist with regard to use of the form. For Connecticut these differences include:
Additional Wastes: None.
All SQGs in Connecticut must comply with the state's manifest requirements.
If the generator is located in Connecticut is the state in which the generator is located, or in the state where the hazardous waste shipment is manifested, the generator must send a copy of the manifest to DEP within seven days of the date on which the transporter accepts and signs the manifest.
Other Notes, Comments::
Connecticut has adopted the federal rule that allows hazardous wastes transported on a public or private right-of-way within or along the border of contiguous properties under the control of the same person, to be transported without a manifest. However, the state did not adopt the federal exemption from the hazardous waste labeling requirements for these wastes and limited the exemption to the generator of the wastes.
10. What are some other differences between federal and state
LQGs must pay a $100 annual fee to DEP. LQGs must pay $50 if they submit an application for status change from an LQG to an SQG.In Connecticut, 100 percent of materials that are accumulated before being recycled are to be recycled within one year of accumulation, or they are considered to be "accumulated speculatively" and are therefore solid wastes (and potentially hazardous wastes). Commercial chemical products are solid wastes when accumulated speculatively.Materials that are not solid wastes when reclaimed must meet specific requirements for storage, marking and inspection logs.