The scenario describes a situation where a generator of hazardous waste in Colorado is attempting to determine the appropriate management standards for their waste. The waste is a spent solvent from a metal cleaning process, which has been analyzed and found to contain listed hazardous constituents. Specifically, the waste exhibits characteristics of ignitability and toxicity based on the Colorado Hazardous Waste Management Regulations (6 CCR 1007-3). Under these regulations, a hazardous waste is managed according to its hazardous waste codes. For spent solvents that are listed and also exhibit a characteristic, the generator must manage it according to the most stringent applicable requirements. The question focuses on the regulatory framework for managing hazardous waste in Colorado, particularly concerning listed wastes and characteristic wastes. The Colorado Hazardous Waste Management Regulations, which are largely aligned with the federal Resource Conservation and Recovery Act (RCRA) Subtitle C, define specific management standards for different types of hazardous wastes. When a waste is both listed and exhibits a characteristic, it must be managed in accordance with the regulations applicable to both. However, the specific management requirements for a spent solvent like the one described, which is listed (e.g., F003 or F005 if it’s a spent non-halogenated solvent) and also exhibits a characteristic (e.g., D001 for ignitability or D007 for chromium if present in the metal cleaning process), are determined by the waste codes assigned. The core principle is that all applicable management standards must be met. The regulations provide specific treatment standards for listed wastes under the Land Disposal Restrictions (LDR) program. If the spent solvent meets the criteria for a listed hazardous waste (e.g., from the F-list or K-list) and also exhibits a characteristic (e.g., ignitability D001, corrosivity D002, reactivity D003, or toxicity D004-D011), it must be managed to meet the treatment standards for the listed waste, which often involve specific treatment technologies or performance standards before land disposal. The question tests the understanding of how Colorado regulates hazardous waste that falls under multiple categories, emphasizing the need to comply with all relevant provisions. The crucial aspect is identifying the regulatory framework that dictates the management of such waste, which is the Colorado Hazardous Waste Management Regulations.

The Colorado Hazardous Waste Management Act (CHWMA), specifically under the Colorado Department of Public Health and Environment (CDPHE) regulations, outlines stringent requirements for managing hazardous waste. When a generator determines that a waste is hazardous, they must comply with specific storage, labeling, manifesting, and reporting requirements. The generation of a hazardous waste notification form is a critical step in initiating the regulatory oversight process. This form serves as the primary notification to the state that a facility is generating hazardous waste, enabling the CDPHE to track generators and ensure compliance with federal and state hazardous waste management programs, primarily RCRA (Resource Conservation and Recovery Act) as implemented by Colorado. Failure to submit this notification within the prescribed timeframe, which is typically within 30 days of becoming a hazardous waste generator, can result in penalties. The notification process is distinct from the initial waste determination, which is the generator’s responsibility. While a waste determination might involve laboratory analysis or applying knowledge of the process, the notification is a procedural requirement that follows that determination. The manifest is used for tracking waste from generation to final disposal, and the biennial report is a periodic summary of hazardous waste activities, both of which are subsequent compliance steps.

The question probes the understanding of the Colorado Hazardous Waste Management Act’s (CHWMA) requirements for the management of hazardous waste, specifically concerning the manifest system and record-keeping. Under the CHWMA, generators of hazardous waste are responsible for ensuring that their waste is transported by licensed hazardous waste transporters to permitted treatment, storage, or disposal facilities (TSDFs). The manifest system is a critical component of this oversight, serving as a tracking document from the point of generation to final disposition. A generator must obtain the signed manifest from the transporter and retain it for a specified period, typically three years, to demonstrate that the waste was properly managed. Failure to maintain these records or to ensure proper shipment can result in significant penalties. The CHWMA, in alignment with federal RCRA regulations, mandates this cradle-to-grave tracking. The core principle is accountability and proof of responsible management. Therefore, a generator must retain the signed manifest for at least three years from the date the waste was accepted by the initial transporter.

The Colorado Hazardous Waste Act, specifically referencing the Resource Conservation and Recovery Act (RCRA) as adopted by the state, establishes a framework for managing hazardous waste from its generation to its final disposal. A key aspect of this framework is the definition of hazardous waste, which includes characteristic wastes and listed wastes. Characteristic wastes are defined by their properties: ignitability, corrosivity, reactivity, and toxicity. Toxicity is determined through the Toxicity Characteristic Leaching Procedure (TCLP). If a waste exhibits any of these characteristics, it is considered hazardous. Listed wastes are those specifically identified by the U.S. Environmental Protection Agency (EPA) or the Colorado Department of Public Health and Environment (CDPHE) as hazardous due to their origin or specific constituents. For a generator to determine if their waste is hazardous, they must first consult the listed waste codes. If the waste is not a listed waste, they must then determine if it exhibits any of the hazardous characteristics. The question asks about a waste stream generated from a solvent recovery process at a facility in Denver, Colorado. This process involves used solvents, some of which are known to be flammable. Flammability is one of the four characteristics that define a hazardous waste under Colorado’s regulations, mirroring federal RCRA. Therefore, a waste that is ignitable, as indicated by its flammability, would be classified as hazardous. The specific process and location, while providing context, do not alter the fundamental characteristic that defines the waste as hazardous under the law. The determination hinges on whether the waste exhibits any of the defined hazardous characteristics or is a listed hazardous waste. In this scenario, the ignitable nature of the solvents is the decisive factor.

The Colorado Hazardous Waste Management Act (CHWMA), codified in Title 25, Article 15 of the Colorado Revised Statutes, establishes the framework for hazardous waste management in the state. The Act delegates authority to the Colorado Department of Public Health and Environment (CDPHE) to implement and enforce regulations. Specifically, under CRS § 25-15-301, the CDPHE is empowered to develop and adopt rules and regulations for the generation, transportation, treatment, storage, and disposal of hazardous waste. These regulations must be consistent with, and at least as stringent as, the federal Resource Conservation and Recovery Act (RCRA) as administered by the U.S. Environmental Protection Agency (EPA). When considering a facility that generates hazardous waste in Colorado, the primary regulatory authority and the source of applicable standards for managing that waste, including manifesting and record-keeping requirements, is the state’s own regulatory framework, which mirrors and often expands upon federal RCRA provisions. Therefore, adherence to Colorado’s specific hazardous waste regulations, as promulgated by CDPHE, is paramount for compliance.

The Colorado Hazardous Waste Act, specifically concerning the management of hazardous waste, requires generators to determine if their waste is hazardous. This determination is crucial for proper handling, storage, transportation, and disposal. Colorado follows the federal Resource Conservation and Recovery Act (RCRA) framework for hazardous waste identification. A generator must assess if their waste exhibits any of the four hazardous characteristics: ignitability, corrosivity, reactivity, or toxicity. If the waste does not exhibit these characteristics, it is considered non-hazardous. However, if the waste is specifically listed as hazardous by the U.S. Environmental Protection Agency (EPA) or Colorado Department of Public Health and Environment (CDPHE), it is hazardous regardless of its characteristics. For a waste stream that is not a listed hazardous waste, the generator must conduct testing or use process knowledge to determine if it exhibits any of the characteristic hazardous properties. If the waste is a mixture of a hazardous waste and a non-hazardous waste, it remains hazardous unless it meets specific delisting criteria. The question posits a scenario where a Colorado facility generates a waste stream that is not a listed hazardous waste. The facility’s internal analysis indicates that the waste exhibits a pH of 1.5. This pH value signifies that the waste is acidic. According to the hazardous waste regulations, a waste is considered corrosive if it is aqueous and has a pH less than or equal to 2 or greater than or equal to 12.5, or if it is a liquid and corrodes steel at a specified rate. Since the waste has a pH of 1.5, it meets the criteria for characteristic hazardous waste due to corrosivity. Therefore, the generator must manage this waste as hazardous. The correct classification is that the waste is hazardous due to corrosivity.

The scenario involves a generator of hazardous waste in Colorado that ships waste to a permitted treatment, storage, and disposal facility (TSDF) in New Mexico. Under the Resource Conservation and Recovery Act (RCRA) and Colorado’s hazardous waste regulations, which are largely authorized to be at least as stringent as federal regulations, a generator is responsible for ensuring that hazardous waste is managed properly from “cradle to grave.” This responsibility extends to the point where the waste is ultimately treated or disposed of in a permitted facility. The manifest system is a key component of this cradle-to-grave tracking. The generator initiates the manifest and must receive a signed copy back from the designated TSDF, confirming that the waste arrived at the facility. If the generator does not receive this signed copy within a specified timeframe (typically 30 days from the date the waste was accepted by the initial transporter), they are required to notify the EPA and the relevant state agency (in this case, the Colorado Department of Public Health and Environment – CDPHE). This notification is crucial for identifying potential problems in the waste management chain, such as lost shipments, improper disposal, or diversion of waste. Therefore, the absence of the signed manifest copy within the regulatory timeframe triggers a specific reporting obligation for the generator to the CDPHE.

The Colorado Hazardous Waste Act, specifically the regulations promulgated by the Colorado Department of Public Health and Environment (CDPHE) under the authority of the Hazardous Waste Control and Waste Management Act (C.R.S. Title 25, Article 15), establishes a framework for managing hazardous waste. When a generator of hazardous waste ceases to operate, they are considered a “former generator.” The responsibility for managing any remaining hazardous waste, including its proper storage, treatment, or disposal, continues even after cessation of operations. This responsibility is not automatically transferred to a subsequent owner or occupant of the property unless explicitly assumed through a contractual agreement or regulatory action. Therefore, the former generator retains the legal obligation to ensure that all hazardous waste generated during their operation is managed in accordance with Colorado’s hazardous waste regulations. This includes proper manifesting, transportation by licensed hazardous waste haulers, and disposal at permitted Treatment, Storage, and Disposal Facilities (TSDFs). Failure to comply can result in significant penalties and liability for cleanup costs. The key principle is that the generator of the waste is ultimately responsible for its cradle-to-grave management, regardless of whether they are currently operating.

The Colorado Hazardous Waste Act, specifically under the authority granted by the Colorado Department of Public Health and Environment (CDPHE), mandates a cradle-to-grave management system for hazardous waste. This system is designed to track hazardous waste from its generation through its transportation, treatment, storage, and final disposal. The core of this system relies on a manifest document, which serves as a legal record accompanying hazardous waste shipments. When a generator sends hazardous waste to a permitted treatment, storage, and disposal facility (TSDF) within Colorado, the TSDF must return a signed copy of the manifest to the generator, confirming receipt of the waste. This signed manifest is crucial evidence that the waste has reached its intended destination and is under the care of a licensed facility. Failure to obtain this signed manifest within a specified timeframe, typically 35 days from the date the waste was accepted by the initial transporter, triggers a reporting requirement. The generator must then notify the CDPHE in writing about the missing manifest. This notification is not merely an administrative formality; it is a critical compliance step to ensure accountability and prevent uncontrolled or improper disposal of hazardous materials, upholding the state’s commitment to environmental protection. The regulations, often mirroring federal Resource Conservation and Recovery Act (RCRA) requirements but with Colorado-specific nuances, emphasize prompt notification to address any potential discrepancies or issues in the waste management chain.

The Colorado Hazardous Waste Management Act (CHWMA), codified at \(C.R.S. § 25-15-101 et seq.\), governs the generation, transportation, treatment, storage, and disposal of hazardous waste within the state. Specifically, \(C.R.S. § 25-15-301\) addresses the responsibilities of hazardous waste generators. This section mandates that generators maintain records of hazardous waste generated, the methods of management employed, and the quantities of waste. The prescribed record retention period is a minimum of three years from the date the waste was last generated or sent for treatment, storage, or disposal, unless a longer period is required by federal regulations or a specific permit. This requirement ensures accountability and allows for retrospective review of waste management practices. Failure to comply with record-keeping provisions can result in penalties and enforcement actions by the Colorado Department of Public Health and Environment (CDPHE). The intent is to provide a traceable chain of custody for hazardous materials from cradle to grave, facilitating proper environmental protection.

The Colorado Hazardous Waste Act (CHWA), codified at C.R.S. Title 25, Article 15, establishes the framework for managing hazardous waste within the state. This act grants the Colorado Department of Public Health and Environment (CDPHE) the authority to implement regulations that are, at a minimum, equivalent to federal regulations promulgated under the Resource Conservation and Recovery Act (RCRA). When a generator of hazardous waste in Colorado determines that a waste is hazardous due to its characteristics or listing, they must comply with specific management standards. This includes obtaining an EPA identification number, adhering to accumulation time limits, proper container management, labeling, manifesting for off-site transport, and ensuring treatment, storage, or disposal occurs at a permitted facility. Failure to comply can result in significant penalties. The scenario presented involves a facility generating a waste exhibiting the characteristic of ignitability. This determination triggers specific management requirements under Colorado’s hazardous waste regulations, which are largely aligned with federal RCRA requirements. The core of the question lies in understanding the immediate regulatory obligation upon making such a determination. The generator must then manage the waste according to the applicable hazardous waste rules, which include proper storage, labeling, and eventual transport and disposal at a permitted facility. The key is that the determination itself mandates compliance with the established regulatory framework.

The Colorado Hazardous Waste Management Act, specifically under the Hazardous Materials and Waste Management Act (HMMA) and its implementing regulations found in the Colorado Hazardous Waste Regulations (6 CCR 1007-3), establishes the framework for managing hazardous waste within the state. When a generator of hazardous waste ships waste off-site to a permitted treatment, storage, and disposal facility (TSDF), they are required to use a manifest system. This manifest serves as a tracking document from the point of generation to the final disposition of the waste. The generator must retain a copy of the manifest for at least three years from the date the waste was accepted by the initial transporter. This retention period is crucial for demonstrating compliance and accountability throughout the waste management process. The manifest provides evidence of the waste’s characterization, quantity, and its ultimate destination, ensuring that it is handled and disposed of in accordance with regulatory requirements. Failure to maintain these records can result in significant penalties. The three-year period is a standard requirement across many hazardous waste regulations in the United States, including those at the federal level under the Resource Conservation and Recovery Act (RCRA), which Colorado’s program is largely based upon.

The Colorado Hazardous Waste Act, specifically concerning the management and disposal of hazardous waste, mandates that generators of hazardous waste must comply with specific record-keeping requirements. These requirements are designed to ensure accountability and traceability of hazardous waste from its generation to its final disposition. Under the regulations, generators are obligated to maintain records of hazardous waste shipments, including manifests, for a minimum period of three years from the date the waste was last sent to a permitted facility. This three-year retention period is crucial for regulatory oversight and for demonstrating compliance with cradle-to-grave management principles. The manifest document itself serves as a critical piece of evidence, detailing the type and quantity of hazardous waste, the transporter, and the designated treatment, storage, or disposal facility. Failure to maintain these records can result in significant penalties. The rationale behind this requirement is to provide a historical trail for hazardous waste, allowing regulators to investigate potential improper management or disposal practices if incidents occur. This ensures that responsible parties can be identified and held accountable for their actions.

The Colorado Hazardous Waste Management Act (CHWMA), codified in Colorado Revised Statutes (C.R.S.) Title 25, Article 15, establishes the framework for managing hazardous waste within the state. This act grants the Colorado Department of Public Health and Environment (CDPHE) the authority to promulgate regulations that are often more stringent than federal requirements under the Resource Conservation and Recovery Act (RCRA). Specifically, the CHWMA mandates that generators of hazardous waste must comply with specific storage requirements to prevent releases into the environment. These requirements often include limitations on the accumulation time for hazardous waste on-site, the types of containers used, and the need for proper labeling and secondary containment. For a large quantity generator, the accumulation time limit for hazardous waste in a central accumulation area is typically 90 days, though extensions may be granted under specific circumstances. The primary objective of these regulations is to ensure that hazardous waste is managed in a manner that protects public health and the environment throughout its lifecycle, from generation to final disposal. Failure to adhere to these accumulation time limits can result in significant penalties and enforcement actions by the CDPHE.

The Colorado Hazardous Waste Act, specifically under the authority granted by the Solid Waste Disposal Act, mandates that the Colorado Department of Public Health and Environment (CDPHE) implement a comprehensive hazardous waste management program. This program is designed to protect public health and the environment from the potential dangers of hazardous waste. The Act defines hazardous waste based on characteristics and listings, aligning closely with federal definitions under the Resource Conservation and Recovery Act (RCRA). A key aspect of Colorado’s program is the requirement for generators, transporters, and treatment, storage, and disposal facilities (TSDFs) to obtain permits or comply with specific management standards. The CDPHE is responsible for developing and enforcing these regulations, including setting standards for waste identification, manifesting, record-keeping, reporting, and emergency preparedness. Furthermore, the Act allows for state-specific regulations that may be more stringent than federal requirements, reflecting Colorado’s commitment to environmental protection. When a facility generates hazardous waste that is listed by the EPA or exhibits hazardous characteristics, it must comply with the applicable generator standards, which dictate how the waste is managed from its point of generation to its final disposition. This includes proper containerization, labeling, accumulation time limits, and ensuring transportation by a permitted hazardous waste transporter to a permitted TSDF. Failure to comply can result in significant penalties.

The Colorado Hazardous Waste Act (CHWA) and its implementing regulations, found in the Colorado Code of Regulations (CCR) 6 CCR 1007-3, govern the management of hazardous waste within the state. Specifically, Part 262 of the federal Resource Conservation and Recovery Act (RCRA), which Colorado has adopted and supplemented, outlines the requirements for hazardous waste generators. A key aspect of these regulations is the determination of generator status, which dictates the specific management standards a facility must follow. Generator status is primarily determined by the amount of hazardous waste generated per calendar month. Very Small Quantity Generators (VSQGs) generate 100 kilograms (kg) or less of hazardous waste per month, or 1 kilogram (kg) or less of acute hazardous waste per month. Small Quantity Generators (SQGs) generate more than 100 kg but less than 1,000 kg of hazardous waste per month, and do not generate more than 1 kg of acute hazardous waste per month. Large Quantity Generators (LQGs) generate 1,000 kg or more of hazardous waste per month, or more than 1 kg of acute hazardous waste per month. The question scenario involves a facility in Colorado that generates 150 kg of hazardous waste in January, 200 kg in February, and 120 kg in March. Crucially, it also generates 0.5 kg of acute hazardous waste in March. To determine the generator status, one must consider the highest monthly generation rate for non-acute hazardous waste and the threshold for acute hazardous waste. The highest non-acute hazardous waste generation was 200 kg in February. However, the generation of 0.5 kg of acute hazardous waste in March does not exceed the 1 kg threshold for acute hazardous waste. Therefore, the facility’s generator status is determined by its non-acute hazardous waste generation, which peaks at 200 kg per month. This amount falls within the SQG category (more than 100 kg but less than 1,000 kg). The CHWA requires that facilities maintain records to demonstrate their generator status.

The question asks to identify the primary indicator from ISO 37120:2018 that would be most directly impacted by a significant, unmanaged release of hazardous waste into a city’s primary water source in Colorado. The scenario describes a severe environmental contamination event. ISO 37120:2018 focuses on city services and quality of life indicators. Hazardous waste contamination of a water source directly and severely affects public health and the safety of essential services. Among the listed indicators, the quality and safety of drinking water are paramount. While other indicators like waste management efficiency or air quality might be indirectly affected, the most immediate and critical impact of a hazardous waste spill into a water supply is on the potability and safety of that water for consumption. Therefore, the indicator that most directly reflects this specific type of environmental failure is related to drinking water quality and safety. This aligns with the core purpose of ISO 37120 to measure city service performance and its impact on citizens’ lives.

The Colorado Hazardous Waste Management Act (CHWMA), specifically as implemented through the Hazardous Waste Management Regulations (6 CCR 1007-3), governs the management of hazardous waste. A key aspect of this act is the definition of hazardous waste and the responsibilities of generators. Colorado generally adopts by reference the federal Resource Conservation and Recovery Act (RCRA) regulations found in 40 CFR Parts 260-279, with some state-specific modifications. A generator is defined as any person, by site, whose act or process produces hazardous waste or whose act first causes a waste to become subject to regulation under the CHWMA. This definition is crucial for determining who bears the primary responsibility for managing hazardous waste from its generation point. The regulations differentiate between small quantity generators (SQGs) and large quantity generators (LQGs) based on the amount of hazardous waste produced per month, which dictates the stringency of their management requirements. However, the initial act of producing or first causing a waste to become regulated defines the generator status, irrespective of the quantity initially produced if that production process inherently creates a listed or characteristic hazardous waste. The question probes the understanding of who is considered a generator under Colorado law. The scenario describes an industrial facility that, through its chemical synthesis process, produces a waste stream that exhibits the characteristic of ignitability as defined by 6 CCR 1007-3, Part 261. This characteristic waste is explicitly regulated. Therefore, the facility that creates this waste through its process is the generator. The act of refining or treating the waste by a subsequent entity does not alter the initial generator status of the facility that produced it. Similarly, the mere presence of the waste on a property does not make the property owner the generator unless they also contributed to its generation or first caused it to become regulated. The key is the “act or process” that produces the waste.

The Colorado Hazardous Waste Act, specifically referencing the Colorado Hazardous Waste Management Regulations (6 CCR 1007-3), mandates stringent requirements for the management of hazardous waste. When a generator determines that a waste is hazardous, they must comply with specific accumulation time limits and storage conditions. For a large quantity generator (LQG) in Colorado, the standard accumulation time limit for hazardous waste in a central accumulation area is 90 days. During this period, the waste must be managed in containers or tanks that meet specific design and integrity standards, and these containers must be clearly marked with the words “Hazardous Waste” and the accumulation start date. Furthermore, LQGs must maintain records of the quantity and types of hazardous waste generated and how it is managed. Failure to adhere to these regulations can result in significant penalties. The question probes the understanding of the maximum allowable storage period for a large quantity generator before the waste must be shipped off-site for treatment, storage, or disposal, assuming all other regulatory requirements for container management and labeling are met. The 90-day limit is a fundamental aspect of LQG hazardous waste management under both federal RCRA and Colorado’s equivalent regulations.

The Colorado Hazardous Waste Act, codified in the Colorado Revised Statutes (CRS) Title 25, Article 15, outlines the framework for managing hazardous waste within the state. This act grants the Colorado Department of Public Health and Environment (CDPHE) the authority to implement and enforce regulations that are at least as stringent as the federal Resource Conservation and Recovery Act (RCRA). Specifically, CRS Section 25-15-302 addresses the permitting of hazardous waste treatment, storage, and disposal facilities (TSDFs). Under this section, any person who owns or operates a TSDF must obtain a permit from the executive director of the CDPHE. The permitting process involves a thorough review of the facility’s design, operation, closure, and post-closure care plans to ensure they meet stringent environmental protection standards. Failure to obtain a permit or to comply with its terms can result in significant penalties, including fines and injunctive relief. The act emphasizes a cradle-to-grave management system for hazardous waste, meaning responsibility extends from the point of generation to final disposal. This includes requirements for waste identification, manifesting, record-keeping, and reporting. The state’s regulations, found in the Code of Colorado Regulations (CCR) 6 CCR 1007-3, further detail these requirements, often mirroring or exceeding federal RCRA standards. The core principle is to protect public health and the environment from the risks associated with hazardous waste.

The question pertains to the definition and application of “treatment” under the Resource Conservation and Recovery Act (RCRA), as implemented by Colorado’s hazardous waste regulations. Specifically, it probes the understanding of whether a process that merely reduces the volume or toxicity of a hazardous waste, without rendering it non-hazardous, constitutes “treatment” for the purposes of land disposal restrictions (LDRs). Under RCRA and Colorado’s equivalent regulations, treatment is defined broadly to include processes that alter the physical, chemical, or biological character of hazardous waste to reduce its hazard or volume. The key is that the process must be designed to achieve a specific treatment standard or to make the waste eligible for a particular disposal method. Simply reducing volume through evaporation or dewatering, without further stabilization or detoxification, might not meet the criteria for treatment if the residual waste remains hazardous and subject to LDRs. The Colorado Hazardous Waste Management Regulations (6 CCR 1007-3) mirror federal definitions and requirements concerning treatment standards for land disposal. For a waste to be considered treated to meet LDRs, it must meet specific treatment standards outlined in the regulations, which often involve concentration limits for hazardous constituents or performance-based standards. A process that solely reduces volume without addressing the underlying hazardous characteristics or meeting a defined treatment standard would not qualify as treatment for LDR purposes. Therefore, a process that only reduces the volume of hazardous waste without meeting the applicable treatment standards for land disposal, as defined by Colorado’s hazardous waste regulations which are largely aligned with federal RCRA, does not exempt the waste from further treatment or specific disposal requirements.

The Colorado Hazardous Waste Act, specifically referencing the Hazardous Waste Management Act (C.R.S. Title 25, Article 15), and its implementing regulations found in the Colorado Code of Regulations (6 CCR 1007-3), establishes a framework for managing hazardous waste. When a generator initially determines that a solid waste is a hazardous waste, they must obtain an EPA identification number. This number is crucial for tracking hazardous waste from its point of generation to its final disposal. The regulations specify that a generator must notify the Administrator of the EPA of their hazardous waste activities. Furthermore, Colorado law, mirroring federal RCRA requirements, mandates that generators maintain records of hazardous waste generated. The period for record retention is typically three years from the date the waste is generated or the date the record is created, whichever is later, unless a longer period is required by applicable federal or state law or agency policy. This recordkeeping requirement is a fundamental aspect of cradle-to-grave management, ensuring accountability and compliance with environmental protection standards. The initial notification and subsequent record-keeping are not optional but are mandatory steps for any entity generating hazardous waste in Colorado.

The Colorado Hazardous Waste Management Act (CHWMA), codified at \(Colorado Revised Statutes Title 25, Article 15\), grants the Colorado Department of Public Health and Environment (CDPHE) the authority to regulate hazardous waste. Specifically, \(C.R.S. § 25-15-301\) outlines the responsibilities of the executive director of the department regarding hazardous waste. This includes the promulgation of rules and regulations for the identification, generation, transportation, treatment, storage, and disposal of hazardous waste. The CHWMA aims to protect public health and the environment from the adverse effects of hazardous waste. It mandates a cradle-to-grave tracking system for hazardous waste, requiring generators, transporters, and treatment, storage, and disposal facilities (TSDFs) to comply with specific requirements. The act also establishes a permitting program for TSDFs and provides for enforcement actions, including civil and criminal penalties for violations. Furthermore, the CHWMA addresses issues related to the cleanup of contaminated sites and the management of medical waste. The core principle is to ensure that hazardous waste is managed in a manner that minimizes risks to human health and the environment throughout its lifecycle. The regulatory framework is largely aligned with the federal Resource Conservation and Recovery Act (RCRA), but Colorado may have its own specific nuances and stricter requirements in certain areas.

The Colorado Hazardous Waste Act, specifically referencing the regulations promulgated under it, such as the Hazardous Waste Management Regulations (6 CCR 1007-3), establishes requirements for the management of hazardous waste. When a facility generates hazardous waste that meets the criteria for being a characteristic hazardous waste, such as ignitability, corrosivity, reactivity, or toxicity, it must be managed according to these regulations. The toxicity characteristic is determined by the Toxicity Characteristic Leaching Procedure (TCLP). If a waste exhibits any of these characteristics, it is considered hazardous. The generator is responsible for determining if their waste is hazardous. This determination can be made through knowledge of the process that generated the waste or by testing. For waste exhibiting toxicity characteristic, the TCLP test is performed. If the leachate from the TCLP test for a specific constituent exceeds the regulatory limit, the waste is classified as hazardous for that characteristic. For example, if a waste, when subjected to TCLP, results in a leachate concentration of lead exceeding the regulatory limit of 5.0 mg/L, it is classified as a D008 hazardous waste. This classification triggers stringent management requirements, including manifesting, proper storage, transportation by permitted haulers, and disposal at permitted treatment, storage, and disposal facilities (TSDFs). The act emphasizes cradle-to-grave responsibility for hazardous waste.

The Hazardous Waste Management Act (HWMA) in Colorado, specifically the regulations promulgated under the Colorado Department of Public Health and Environment (CDPHE), establishes a framework for identifying, managing, and tracking hazardous waste. A critical aspect of this framework is the generator status, which dictates the regulatory requirements a facility must adhere to. For a Colorado hazardous waste generator, the determination of their status is primarily based on the quantity of hazardous waste they produce per calendar month. Small Quantity Generators (SQGs) are defined as those generating between 100 and 1,000 kilograms of hazardous waste per month, or less than 1 kilogram of acutely hazardous waste per month. Large Quantity Generators (LQGs) generate 1,000 kilograms or more of hazardous waste per month, or more than 1 kilogram of acutely hazardous waste per month. Conditionally Exempt Small Quantity Generators (CESQGs) generate 100 kilograms or less of hazardous waste per month, or less than 1 kilogram of acutely hazardous waste per month. The scenario describes a facility in Denver, Colorado, that produces 850 kilograms of hazardous waste and 0.5 kilograms of acutely hazardous waste in a given month. To determine the generator status, we evaluate both quantities against the relevant thresholds. The 850 kilograms of hazardous waste falls within the 100-1,000 kg range, classifying it as SQG. The 0.5 kilograms of acutely hazardous waste is below the 1 kg threshold for acutely hazardous waste, which would also align with SQG status if that were the primary determinant. Therefore, based on the combined production, the facility is classified as a Small Quantity Generator.

The Colorado Hazardous Waste Management Act, specifically focusing on the identification and management of hazardous waste, aligns with the principles of cradle-to-grave responsibility. When a generator of hazardous waste ceases operations in Colorado, the responsibility for managing any remaining hazardous waste does not simply disappear. Instead, the responsibility transfers to the entity that acquires ownership or possession of the site where the waste is located, unless specific arrangements have been made. This ensures that the waste continues to be managed in accordance with Colorado’s stringent environmental regulations. The Colorado Department of Public Health and Environment (CDPHE) oversees these transfers of responsibility to prevent improper disposal and environmental contamination. The Generator Identification Number (GIN) is crucial for tracking hazardous waste from its point of generation to its final disposition, and any transfer of ownership or operational status necessitates updating these records to reflect the new responsible party.

The Colorado Hazardous Waste Act, specifically referencing regulations derived from the Resource Conservation and Recovery Act (RCRA) as implemented by the Colorado Department of Public Health and Environment (CDPHE), establishes stringent requirements for the management of hazardous waste. When a generator of hazardous waste ceases to operate or declares bankruptcy, the responsibility for managing any remaining hazardous waste on-site does not simply disappear. The law mandates that the generator, or its successor, must ensure that all hazardous waste is properly managed, treated, stored, or disposed of in accordance with applicable regulations. This includes situations where a facility may have generated waste historically but is no longer in operation. The generator’s liability for proper waste management persists until the waste is no longer considered hazardous or is disposed of in a permitted facility. Therefore, the cessation of operations or bankruptcy does not absolve the entity from its legal obligations under Colorado’s hazardous waste statutes. The correct approach involves identifying all hazardous waste, ensuring it is characterized, and then arranging for its compliant management, which may involve transfer to a permitted treatment, storage, and disposal facility (TSDF) or proper on-site treatment if permitted. The ultimate goal is to prevent environmental contamination and protect public health.

The Colorado Hazardous Waste Management Act (CHWMA), specifically referencing regulations found within the Colorado Code of Regulations (CCR) Series 25-15, outlines the requirements for hazardous waste generators. For large quantity generators (LQGs) in Colorado, a key aspect of compliance involves the management of their waste inventories. An LQG is defined by the amount of hazardous waste generated per month. Specifically, if a facility generates 1,000 kilograms (kg) or more of hazardous waste in a calendar month, or accumulates 1 kilogram (kg) or more of acute hazardous waste in a calendar month, it is classified as an LQG. Furthermore, LQGs are permitted to accumulate hazardous waste on-site for up to 90 days without a permit, provided they meet certain conditions. These conditions include marking containers with the words “Hazardous Waste” and the accumulation start date, and storing them in a designated area that is inspected regularly. The question probes the understanding of the regulatory distinction between generator categories and the specific time limits for on-site accumulation without a permit, which is a fundamental concept for compliance under Colorado’s hazardous waste program, mirroring federal RCRA regulations.

Colorado’s Hazardous Waste Management Act, codified primarily in the Colorado Hazardous Waste Regulations (6 CCR 1007-3), establishes a framework for the identification, management, and disposal of hazardous waste. When a generator produces hazardous waste, they must determine if it is a characteristic hazardous waste or a listed hazardous waste. If it is neither, it is considered non-hazardous. The regulations outline specific testing procedures for characteristics such as ignitability, corrosivity, reactivity, and toxicity. For toxicity, the Toxicity Characteristic Leaching Procedure (TCLP) is a key analytical method. However, the question pertains to a scenario where a generator believes their waste may be hazardous but lacks the specific analytical data to confirm its characteristics under Colorado law. In such a situation, the generator has a responsibility to make a good faith determination. If the generator has knowledge of the waste’s properties or its components, and this knowledge indicates it meets the definition of hazardous waste (either by characteristic or listing), they must manage it as such, even without formal TCLP results. This “knowledge-based” determination is a critical aspect of generator responsibility under RCRA, which Colorado largely mirrors. The failure to properly classify and manage waste, even in the absence of specific testing, can lead to violations. Therefore, the most appropriate action for the generator, given their belief and lack of testing, is to manage the waste as hazardous until proven otherwise through proper analysis. This proactive approach aligns with the precautionary principle inherent in environmental regulations.

The Hazardous Waste Management Act in Colorado, codified in the Colorado Revised Statutes (C.R.S.) Title 25, Article 15, establishes the framework for managing hazardous waste within the state. Specifically, C.R.S. § 25-15-302(1)(a) mandates that the Colorado Department of Public Health and Environment (CDPHE) shall adopt, by regulation, a hazardous waste management system. This system is to be consistent with, and in furtherance of, the Resource Conservation and Recovery Act (RCRA) of 1976, as amended, and regulations promulgated by the Administrator of the U.S. Environmental Protection Agency (EPA) under RCRA. The intent is to ensure that Colorado’s hazardous waste program provides a level of protection at least equivalent to the federal program. Therefore, when considering the definition of “hazardous waste” for regulatory purposes in Colorado, the state relies on the federal definition as established by RCRA and its implementing regulations, primarily found in 40 CFR Part 261, unless Colorado has adopted more stringent or specific state-only definitions or criteria that go beyond federal requirements. The core of Colorado’s regulatory authority stems from its ability to implement and enforce a program that is authorized by the EPA, which requires substantial alignment with federal standards.