Obtaining a RCRA Site ID number – When, who and why?
When: WSDOT construction projects are typically Conditionally Exempt Small Quantity Generators because projects usually handle abandoned non-acute hazardous waste, which does not require a RCRA Site ID number. Non-acute dangerous/hazardous waste is determined by a toxicity characteristic leaching procedure (TCLP) test. A RCRA Site ID Number is obtained when there is a potential to generate more than 220 pounds of non-acute dangerous/hazardous waste. For WSDOT projects, this typically includes bridge painting or removal projects but may also include projects that generate contaminated soils that exceed the TCLP threshold for dangerous waste. Useful estimates for determining quantities are that a full 55 gallon drum of water weighs approximately 460 pounds. A full 55 gallon drum of compacted soil weighs approximately 882 pounds. These weights do not include the weight of the drum container which does not need to be included in the quantity. Who: It is recommended that a WSDOT Regional En