1. What is a Hazardous Waste?

There are two ways a waste may be considered a hazardous waste: (1) if it is Characteristically Hazardous, or (2) if it is a Listed as a hazardous waste. Characteristically hazardous wastes are wastes that exhibit any one of the four characteristics listed below.

• IGNITABILITY - liquid wastes with a flash point lower than 140°F, ignitable solids, and materials that are designated by the U.S. DOT as oxidizers.
  
  
• CORROSIVITY - liquid wastes with a pH less than or equal to 2.0, or greater than or equal to 12.5.
  
  
• REACTIVITY - materials that are: normally unstable; react violently, explode, or emit toxic fumes when mixed with water; or, are capable of exploding at room temperature and pressure or when heated under confinement.
  
  
• TOXICITY - materials containing greater than the regulated concentration of any of 40 contaminants listed in the federal hazardous waste regulations.
  
  

The complete definition of each of these types of characteristically hazardous wastes is available on the Electronic Code of Federal Regulations Web Site.

Listed hazardous wastes are wastes that are specifically identified in one of four lists developed by U.S. EPA in the federal hazardous waste regulations. Each hazardous waste listing includes a description of a specific type of waste that EPA considers hazardous enough to warrant regulation. The four groups of listed hazardous wastes are easily identified by the letter that begins their 4-digit EPA waste code (i.e., "F," "K," "U," or "P"). The four groups are classified as follows:

• "F" WASTES - wastes from certain common, nonspecific industrial activities
  
  
• "K" WASTES - Wastes from certain specific industrial processes
  
  
• "U" WASTES - discarded commercial chemical products, off-spec products, container residues, and spill residues of such products
  
  
• "P" WASTES - acutely hazardous discarded commercial chemical products, off-spec products, container residues, and spill residues of such products

The complete definition of each of these types of characteristically hazardous wastes is available on the Electronic Code of Federal Regulations Web Site.


2. What Types of Hazardous Wastes are Typical in a Marina or Boatyard?

Typically, marinas and boatyards do not generate "K" listed wastes, and only on rare occasions, if ever, do they generate "U" or "P" listed wastes. What marinas and boatyards do typically generate are spent solvents (acetone and parts washer solutions), which may be an "F" listed waste and several characteristically hazardous wastes. These may include: waste gasoline, old signal flares, waste nitric acid, lead-acid batteries, waste muriatic acid, caustic paint strippers, bottom paint sanding dust, old drain cleaners, etc.


3. How do I determine whether My Wastes are Hazardous Wastes?

A generator must determine whether his waste is a hazardous waste by testing the waste or applying his knowledge of the wastes source of generation and characteristics to make the determination. In many cases it will be necessary to sample and analyze the waste to make a full determination. This determination must be updated and documented every twelve (12) months. Detailed instructions on how to perform and document your waste determinations may be found in the Connecticut DEP's Environmental Program Fact Sheet: Hazardous Waste Determinations / Knowledge of Process.


4. What Kind of Hazardous Waste Generator am I?

Once you have determined whether you generate a hazardous waste, you must determine which category of hazardous waste generator you are. If after completing step 3, above, you determined that you do not generate a hazardous waste you need to keep copies of your hazardous waste determinations on-site to document your status.

A more likely scenario is that you do generate at least some hazardous waste and will need to determine what kind of generator you are. There are three kinds of generators:

1. Conditionally Exempt Small Quantity Generators (CESQG): facilities generating less than 220 pounds (about 26 gallons) per month and accumulating no more than 2,200 pounds of hazardous waste on-site at any one time and that generate less than 2.2 pounds per month of acutely hazardous waste.*

2. Small Quantity Generators (SQG): facilities generating between 220 and 2,200 pounds (about 26 to 260 gallons) per month and accumulating no more than 2,200 pounds on-site of hazardous waste at any one time and that generate less than 2.2 pounds per month of acutely hazardous waste.*

3. Large Quantity Generators (LQG): facilities generating more than 2,200 pounds per month or accumulating more than 2,200 pounds on-site at any one time of hazardous waste, or that generate more than 2.2 pounds per month of acutely hazardous waste.*

*Acutely hazardous wastes are a subset of hazardous wastes that are particularly hazardous, and are therefore regulated in much smaller amounts than regular hazardous wastes. Typically, the wastes generated by marinas will not fall into this category, although certain wastes may (for example, certain pesticides which are "P" listed wastes).

Detailed instructions on how to determine what category of generator you are may be found in the Connecticut DEP's Environmental Program Fact Sheet: Hazardous Waste Generator Category (4/96) [.pdf].

5. Hazardous Waste Generator Requirements

Once you have determined what category of generator you are, you can determine what hazardous waste requirements apply to you.

Most, but not all, marinas and boatyards in Connecticut appear to be Conditionally Exempt Small Quantity Generators (CESQG) and are therefore subject to the least stringent management and reporting requirements. If you determine that you are a CESQG, read the CESQG Requirements for Facilities [.pdf] that are generators of RCRA Hazardous Waste.

If you are a Small Quantity Generator (SQG) or a Large Quantity Generator (LQG) and do not already have an EPA ID Number you will need to file a Notice of Regulated Waste Activity (EPA Form 8700-12). You can obtain a PDF formatted copy of the Form and Instructions. If you determine that you are an SQG, or LQG, read the SQG or LQG Requirements for Facilities [.pdf] that are generators of RCRA Hazardous Waste.


6. Guidance Documents for Hazardous Waste Generators

Conditionally Exempt Small Quantity Generators	Small Quantity Generators	Large Quantity Generators
Haz. Waste Det. / Knowledge	Haz. Waste Det. / Knowledge	Haz. Waste Det. / Knowledge
Haz. Waste Gen. Category	Haz. Waste Gen. Category	Haz. Waste Gen. Category
Non-RCRA Haz. Waste	Non-RCRA Haz. Waste	Non-RCRA Haz. Waste
Universal Waste Rule / Facilities	Universal Waste Rules / Facilities	Universal Waste Rules / Facilities
Uniform Hazardous Waste Man.	Uniform Hazardous Waste Man.	Uniform Hazardous Waste Man.
Haz. Waste Man. Streamlined	Haz. Waste Man. Streamlined	Haz. Waste Man. Streamlined
	Haz. Waste Container Mgt.	Haz. Waste Container Mgt.
	Haz. Waste Inspections	Haz. Waste Inspections
	Haz. Waste Personnel Training	Haz. Waste Personnel Training
SQGs	SQGs	Haz. Waste Contingency Plan

If you are a marine-related business owner, we encourage you to consider Joining the CMTA - because we are the voice of Connecticut's recreational boating.