Waste Chemical Disposal
An overview of hazardous waste management issues and procedures including selected "cradle to grave" requirements of RCRL
Need Help? Some Available RCRA Hotlines
q Ohio EPA Small Business Assistance Office, 6147288575 q Ohio EPA Division of Hazardous Waste Management, Technical Assistance, 614 6442917 q Ohio Statewide Environmental Network, 18009270436 q USDOT Technical Information, 1800 4674922, Option #1
Essential Communication
q Do not joke about hazardous waste. q Do not talk with the press or general public (unless authorized to do so within the scope of the question posed). q Instead, defer to the "company spokesperson." q Do not smile when acknowledging a mistake, to anyone.
Essential Communication (Continued)
q If a "wrong" has been committed, make every attempt within your means possible to correct the error. q Do not let the sun go down on your mistake without mitigation. q Fines are bad. q If you do not know, ASK . . . The next available, conscientious authority for clarification concerning an issue.
Essential Communication (Continued)
q Ignorance is not bliss in Environmental Management (particularly Haz. Mat.). q Be prepared with an answer for common questions associated with your field. q If you do not have an immediate answer, learn where to find it in a timely manner. q Make referrals to reputable sources if you are not qualified to give an answer.
Essential Communication (Continued)
q Always seek new information on updates to the rules and regulations governing Hazardous Material Management, learning as many specifics as you can commit to memory. q Do the best you can to learn other aspects of specialties within the field of Environmental Management.
Poignant Federal Environmental Laws to Control Toxic Substances
q Federal Food, Drug and Cosmetic Act (FFDCA) 1938 q Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) 1947 q Clean Air Act (CAA) 1970 q Occupational Safety and Health Act 1970 lead to the Occupational Safety and Health Administration (OSHA)
Federal Acts (Continued)
q Clean Water Act (CWA) 1972
The Convolution of Environmental Progression
q Rivers and Harbors Act 1899, limited floating refuse in navigable water ways. q Most environmental laws start here with the Rivers and Harbors Act, or "Refuse Act," but, it was the only water pollution control in affect until, q The Federal Water Pollution Control Act (FWPCA) 1972
Can you keep up? Progressive Convolution (Continued)
q Significant amendments in 1977 lead to retroactive reference of FWPCA as the Clean Water Act (CWA) 1972 q There were 28 total amendments of the FWPCA up to late 1992.
Federal Acts (Continued)
q Clean Water Act (CWA) 1972 q Safe Drinking Water Act (SDWA) 1974
Federal Acts (Continued)
q Clean Water Act (CWA) 1972 q Safe Drinking Water Act (SDWA) 1974 q Hazardous Materials Transportation Act (HMTA) 1975
Federal Acts (Continued)
q Clean Water Act (CWA) 1972 q Safe Drinking Water Act (SDWA) 1974 q Hazardous Materials Transportation Act (HMTA) 1975 q Toxic Substances Control Act (TSCA) 1976
Federal Acts (Continued)
q Clean Water Act (CWA) 1972 q Safe Drinking Water Act (SDWA) 1974 q Hazardous Materials Transportation Act (HMTA) 1975 q Toxic Substances Control Act (TSCA) 1976 q Resource Conservation and Recovery Act (RCRL) 1976
Federal Acts (Continued)
q Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) "Super fund" 1980 q Superfund Amendments and Reauthorization Act (SARA) 1986 q Pollution Prevention Act 1990
Resource Conservation Recovery Act (RCRL) 1976
q Solid Waste Disposal Act (SWDA) 1965, prompting studies q Earth Day, April 22, 1970, a grassroots catalyst of public outcry q Refuse Recovery Act 1970, MORE STUDIES q Originally designed to control municipal solid waste q RCRA added the word "hazardous" to waste.
"Cradle to Grave"
q RCRA, Subtitle C, implemented to track hazardous waste from point of generation to disposal site with a paper trail, not promulgated as regulation until 1980. q The manifest system q Subtitle D, deals with solid waste q Hazardous and Solid Waste Amendments (HSWA) 1984, contains the bulk of RCRA.
Hazardous and Solid Waste Amendments (HSWA) 1984
q Brought Small Quantity Generator under regulation q Regulates Under Ground Storage Tanks (USTs) containing hazardous materials q Created LandDisposal Restrictions "Land Bans" for hazardous waste not meeting treatment criteria q Corrective action deterring RCRA facilities from becoming Superfund sites
RCRA Subtitle C
q Title 40, Code of Federal Regulation, Chapter I, Subchapter I, Parts 260281 q Part 260, General,Definitions and Petitions q Part 261, Hazardous Waste Identification q Part 262, Generator Requirements q Part 263, Transporter Requirements q Part 264, Treatment Storage and Disposal Facilities (TSDs)
RCRA Subtitle C (Continued)
q Part 265, Interim Status for TSDs q Part 266, Recycling streams and facilities q Part 267, Interim Standards for new Land Disposal Facilities (LDFs) q Part 268, Land Disposal Restrictions q Part 270, EPA Haz. Waste Permit Program TSD Conditions, special conditions, transfer, modification and renewal
RCRA Subtitle C (Continued)
q Part 271, Requirements for State authorization of RCRA programs q Part 272, Listing of authorized States q Part 280, Underground Storage Tanks (UST) requirements for technical standards and corrective action q Part 281, State authorization for USTs
The Scope of Regulated, Chemical Materials
q Control of chemical materials across the different environmental laws involves between 300400 substances. q Major environmental laws regulate or focus on the same group of chemicals
For Example: Benzene
q Hazardous Waste, RCRA (D018) q Hazardous Substance, CERCLA q Hazardous Chemical, OSHA q Hazardous Air Pollutant, CAA q Hazardous Material, HMTA (DOT Class 3) q Toxic Pollutant, CWA q Toxic Chemical, EPCRA
What is a Hazardous Waste?
q As defined by the EPA, RCRA Subtitle C, Part 261 q Product of a process or accident with no direct use onsite as a raw material without some form of treatment q A raw material that is unusable due to age or considered to be offspecification q Leftovers from previous occupants
What is a Hazardous Waste? (Continued)
q "Solid" waste means gas, liquid, semi liquid or solid, any waste that has mass q A waste must be a solid waste before being considered a hazardous waste q Just because something is considered to be a hazardous material or substance does not make it a hazardous waste or even a solid waste.
What is a Hazardous Waste? Exceptions
q Circumstantial "delisting," under the Definitions/Petitions RCRA Subtitle C, Part 260, details concerning caseby case regulatory scenarios on; q Recycleables q Variances q Certain waste stream exclusion from regulation of hazardous waste that otherwise would be, automatically.
What is a Hazardous Waste? (Continued)
q When hazardous waste is added to solid waste, the whole volume then becomes "hazardous waste." q Hazardous Waste Identification Rule (HWIR), following court proceedings in an Oil Company case regarding "the mixture and derivedfrom rules." q Universal Waste, standards for Small and Large Quantity Handlers
What is a Hazardous Waste? (Continued)
q There are two ways for a solid waste to be considered "hazardous" by RCRA. q If it appears on one or more of four lists of hazardous waste, then it is a "Listed Waste." q If it exhibits one or more of the four characteristics of hazardous waste, then it is a "Characteristic Waste."
Listed Waste
q F001F039, Hazardous Waste from a nonspecific source
F Listings, Non-specific Sources
q F001F005, Spent solvents q F006F012, F019, Electroplating wastes q F020F023, F026F028, Dioxin wastes q F024, F025, Chlorinated aliphatic hydrocarbon production wastes q F032, F034, F035, Wood preserving wastes q F037, F038, Petroleum refinery sludge q F039, Leachate waste from land disposal
Listed Waste
q F001F039, Hazardous Waste from a nonspecific source q K001K151, Hazardous Waste from a specific source
K Listings, Specific Industrial Sources
q Wood preservation q Inorganic pigments q Organic chemicals q Inorganic chemicals q Pesticides q Explosives q Petroleum refining q Iron and Steel refining q Primary Copper/lead /zinc/aluminum refining q Ferroalloys q Secondary lead q Veterinary pharmaceuticals q Ink formulation q Coking
Listed Waste
q F001F039, Hazardous Waste from a nonspecific source q K001K151, Hazardous Waste from a specific source q P001P122, Acutely toxic hazardous waste, LD50<=500mg/Kg white lab rat q U001U359, Nonacute toxic hazardous waste, LD50>=500mg/Kg white lab rat
Sole Active Ingredient
q When a P or U listed chemical is the only active ingredient of a product, for the function of that product, or, q Of the active ingredients, only one of those constituents is for the function of that product, then, q The waste receives that respective P or U code
Characteristic Waste
q D001, Ignitability q D002, Corrosivity q D003, Reactivity q D004D043, Toxicity, in mixture, solution or as a pure, raw material
D001, Ignitability
q Flash Point < 140oF (DOT Class 3) q Not a liquid, but capable of causing fire at STP through friction, absorption of moisture, or spontaneous chemical changes and when ignited, burns to create a hazard (DOT Class 4.1) q Ignitable compressed gas(DOT Class 2.1) q An Oxidizer (DOT Class 5.1)
D002, Corrosivity
q An aqueous material with 2 > pH > 12.5 q A liquid that corrodes steel (SAE1020) at a rate > 0.250 ins./yr. At 130oF q DOT Class 8 q Note: Solids do not qualify under this criteria, therefore Not a hazardous waste, considered a hazardous material by DOT
Reactivity, D003
q Normally unstable and readily undergoes violent change without detonating q Reacts violently with water (DOT Class 4.3) q Generates toxic gases, vapors, or fumes when mixed with water to present a danger (DOT Class 4.3) q Cyanide of sulfide bearing
Reactivity, D003 (Continued)
q Capable detonation of or explosion when subjected to strong initiating source or heated under confinement (DOT Class 4.2) q Capable of explosive decomposition, detonation, or reaction at STP (DOT Class 1.11.6) q Forbidden explosives (DOT)
Toxicity, D004-D043
q 8 Heavy Metals q 6 Pesticides q 25 New Organic Chemicals, or, q When a representative sample of waste exhibits a maximum concentration of contaminants for one or more of these specific toxicity characteristics at the listed regulatory levels
Know these: D004-D011, 8 Heavy Metals
q D004, Arsenic q D005, Barium q D006, Cadmium q D007, Chromium q D008, Lead q D009, Mercury q D010, Selenium q D011, Silver
Generators Defined
q RCRA Subtitle C, Part 262 q Large Quantity Generator, LQG
Large Quantity Generator
q Required to follow 40 CFR Parts 26070 q Production of 1000Kg (2,200lbs.) / calendar month hazardous waste q Generation of 1 kg (2.2lbs.) of "acute hazardous waste" / calendar month q Generation of 100kg (220lbs.) residue from waste, spill cleanup of contaminated soil, or debris of acute haz. waste ("F" listed Dioxin waste and "P" listed waste)
Large Quantity Generator Requirements
q Comply with all RCRA regulations 40 CFR 260270 q Comply with generation rates q Onstorage not to exceed 90 days, extensions of 30 days may be granted q Exception reporting if manifest is not returned within 45 days
Large Quantity Generator Requirements (Continued)
q Comply with Preparedness and Prevention Program in Subpart C or Part 265 and have a Written Contingency Plan from Subpart D q Comply with RCRA Personnel Training Requirements in Part 265.16, HAZWOPER q Comply with Subpart I of Part 265 for container storage q Comply with Subpart J of Part 265 for
Large Quantity Generator Requirements (Continued)
q Comply with Closure Performance Standard for 90day unit in Part 265.111 and 265.114
Generators Defined
q RCRA Subtitle C, Part 262 q Large Quantity Generator, LQG q Small Quantity Generator, SQG
Small Quantity Generator
q Required to follow 40 CFR Parts 26070, with some exceptions q Production of hazardous waste > 100kg (220lbs.) but still <1000kg(2,200lbs.)/ calendar month q Accumulation of hazardous waste > 6,000kg (13,200lbs.) onsite at any time, subject to RCRA permit
Small Quantity Generator Requirements (Continued)
q Comply with generation rate and accumulation quantities q Onsite storage not to exceed 180 days (270 days if TSDF is over 200 miles away) a casebycase extension of 30 days q Comply with Tank Storage requirements, Part 265.201 q Comply with Container Storage requirements Subpart I Part 265
Small Quantity Generator Requirements (Continued)
q Comply with Preparedness and Prevention Program requirements Part 265 q Not required to submit a biennial report (Annual Report in Ohio) q Exception reporting if manifest is not returned within 60 days from TSD, rather than 45 days for LQG q Not required to have a written Contingency Plan
Small Quantity Generator Requirements (Continued)
q Not required to conduct RCRA Personnel Training, however, all employees have to be familiarized with proper waste handling and emergency procedures particular to their responsibilities and position, so document all inhouse training activities.
Generators Defined
q RCRA Subtitle C, Part 262 q Large Quantity Generator q Small Quantity Generator q Conditionally Exempt Small Quantity Generator, CESQG
Generators Defined (Continued) Conditionally Exempt SQGs
q Generation < 100kg (220lbs.) / calendar month of hazardous waste, or, q <1 kg (2.2lbs.) of "acute hazardous waste" / calendar month q Generation of <100kg (220lbs.) residue from waste, spill cleanup of contaminated soil, or debris of acute haz. waste ("F" listed Dioxin waste and "P" listed waste)
Conditionally Exempt Small Quantity Generator (Continued)
q Accumulation of hazardous waste > 1,000kg (2,200lbs.) onsite at any time, subjected to SQG regs. and Parts 263270 q Generation of >1kg of acute haz. Waste, or, 100kg (220lbs.) residue from waste, spill cleanup of contaminated soil, or debris, subjected to LQG regs., and Parts 263270
Conditionally Exempt Small Quantity Generator Requirements
q Comply with generation rate and accumulation quantities q Identify storage times within generation rates and accumulation quantities q No EPA Identification Number q Shipment of Hazardous Waste: Transportation and TSDF rules apply
Satellite Accumulation Sites
q Only portable devices may be used "containers" q In good condition; no creases, dents, rust or storm water accumulation q Should be located near point of hazardous waste generation q Within site of the operator of the waste producing activity generator, or, under lock and key
Satellite Accumulation Sites
q Hazardous waste placed immediately into container upon generation q Container must be compatible with hazardous waste stored in it. q Container must be marked with the words "Hazardous Waste." q Unless waste is being added or removed, container must be closed at all times.
Satellite Accumulation Sites(Continued)
q 55 gal. Max. When a 55 gal. drum is full it must be transferred to a 90day storage facility within three days of filling up. q The date that the 55 gal. limit was exceeded should be marked on the container. This is the official starting date.
Transportation
q Pretransportation requirements of generators are found in 49 CFR Sub Chapter A, Part 106178 q Separate DOT packaging requirements for nonbulk and bulk packaging
Non-Bulk Packaging Limits
q 119 gals. or less for a liquid q 882 lbs. or less for a solid q a water capacity of 1,000 lbs. or less for a gas q Bulk packaging may have similar volume or weight limits placed on it, but can be much larger than these limits. For example, a 55 gal. closed head drum is used for bulk quantities.
Package Selection
q See DOT Hazardous Materials Table to select the proper packaging for a given Hazardous Material/Waste, 49 CFR Ch. 1, SubChapter C, ...