Resource Conservation and Recovery Act Compliance (RCRA)
The Environmental Protection Agency (EPA) regulations on hazardous wastes are codified from the Resource Conservation and Recovery Act (RCRA) and can be found in title 40 of the Code of Federal Regulations. In New York state the Department of Environmental Conservation (DEC) has the responsibility for enforcing these regulations. The DEC’s version of the codified federal regulations have some additional requirements. These regulations specify what is a "hazardous waste." It is important to realize that a chemical waste can be hazardous to humans, but not be a "hazardous waste" under the regulations. At Cornell University, individuals generating chemical wastes are not required to understand these regulatory nuances, they just need to discriminate between whether a chemical waste is hazardous or not when determining what to do with it.
The EPA’s waste regulations recognize two basic types of chemical waste accumulation areas. Their terms for these are:
Satellite Accumulation Area – Each area where chemical waste is generated is considered by the EPA to be a satellite accumulation area. This includes such facilities as laboratories, shops, and photographic studios. Click here for a list of the requirements in a satellite accumulation area. To check if you are in compliance, EH&S has created a chemical waste self audit form and with an explanation.
90 Day Accumulation Area – Whenever chemical waste is moved from the room it was generated in to a centralized storage area, that centralized storage area is a 90 day accumulation area in the EPA’s eyes. As the name implies, wastes can only be accumulated for 90 days before they must be shipped to a permitted disposal facility. Cornell’s main 90 day accumulation area is managed by EH&S at 201 Palm Rd. Click here for the requirements for Chemical Wastes in a 90 Accumulation Area
A facility generating chemical waste is regulated by the EPA under one of the four following designations:
Conditionally Exempt Small Quantity Generator (CESQG) -Almost all of Cornell’s facilities away from the Ithaca campus fall under this definition.
Small Quantity Generator (SQG) – Only Geneva campus meets these requirements – Recently Geneva campus has been a LQG, due to remediation efforts.
Large Quantity Generator (LQG) – The Ithaca campus is a large quantity generator of Hazardous Waste
Treatment Storage and Disposal facility (TSD) – Cornell University has nothing regulated as a TSD.