rcra flash cards

What is RCRA?

RCRA (Resource Conservation and Recovery Act, 1976)** is the primary U.S. law regulating the generation, transportation, treatment, storage, and disposal of hazardous waste.

- Administered by the EPA, but Vermont enforces its own program (Vermont Hazardous Waste Management Regulations, which are at least as stringent as RCRA).

Key RCRA Subparts You Must Know**

#### A. RCRA Subtitle C (Hazardous Waste Regulation)

- Cradle-to-Grave System: Tracks hazardous waste from generation to disposal.

Generator Requirements** (40 CFR Part 262):

  - Large Quantity Generators (LQGs) – Generate ≥1,000 kg/month.

  - Small Quantity Generators (SQGs) – Generate 100-1,000 kg/month.

  - Conditionally Exempt Small Quantity Generators (CESQGs) – Generate ≤100 kg/month.

A waste is hazardous if it is

Listed** (F, K, P, U lists).

  - Characteristic (Ignitable, Corrosive, Reactive, Toxic).

- Vermont-Specific Rules: Some wastes not federally regulated may be hazardous in Vermont.

Containers must be

Compatible with waste.

  - Labeled with accumulation start date and hazards.

  - Inspected weekly (for LQGs).

- Satellite Accumulation Areas (SAAs) allow ≤55 gallons near generation points.

How do you determine if a waste is hazardous under RCRA?

First, check if it’s listed (F, K, P, U). If not, test for characteristics (ignitability, corrosivity, reactivity, toxicity). Vermont may have additional listings."

What are the storage requirements for hazardous waste?

Containers must be labeled, closed, inspected weekly (for LQGs), and stored in a designated area with secondary containment."*

What’s the difference between an SQG and an LQG?"

LQGs generate ≥1,000 kg/month and have stricter rules (weekly inspections, contingency plans). SQGs generate 100-1,000 kg/month.

What is a hazardous waste manifest?

It’s a tracking document required for transporting hazardous waste, ensuring proper disposal. Vermont requires electronic manifests."*

How does Vermont differ from federal RCRA?

Vermont has stricter universal waste rules, additional hazardous waste listings, and may require extra reporting."

How would you handle a spill of hazardous waste?

Follow OSHA/Vermont spill response: secure the area, notify supervisors, use PPE, contain the spill, and report if required.

Describe a time you ensured compliance with RCRA.

At my last job, I conducted weekly inspections, ensured proper labeling, and trained staff on waste segregation

How do you stay updated on hazardous waste regulations?

I follow EPA/ANR updates, attend training, and review Vermont’s hazardous waste bulletins."*