Cradle to Grave - The
Life and Times of Hazardous Waste (Part 2 of 2)
Handling, Transportation and Disposal
M. Alvarez, CSP
In last month's
Osh Basics, we indicated that there are three fundamental
components to the proper management of hazardous waste:
Accurate Waste Determination
(reference 40 CFR 261
and state equivalent)
Handling (reference 40 CFR 262 and state equivalent)
Transportation and Disposal (reference
40 CFR 263/264 and state equivalent)
We reviewed the
need for accurate waste determination and some important
items for you to consider. Now that you have accurately
determined the type of waste you have, you will need to
manage that waste properly and arrange for transportation
Since you have
determined that your waste is hazardous, you may be considered
a hazardous waste "generator". The first step
in proper waste handling is to determine what type of hazardous
waste generator you are.
What type of
generator are you?
There are numerous
waste management standards that generators of hazardous
waste must follow before their waste can be disposed of
or recycled. Use the following table to determine what
type of generator you are:
Large Quantity Generator (LQG)
>1,000 kg of hazardous waste per calendar month
>1 kg of acutely hazardous waste
Small Quantity Generator (SQG)
Between 100 kg and 1,000 kg of hazardous waste
per calendar month
Accumulates < 6,000 kg of hazardous waste at any
Small Quantity Generator (CESQG)
<100 kg of hazardous waste per calendar month
< 1 kg of acutely hazardous waste per calendar month
Accumulates < 1000 kg of hazardous waste, 1 kg of
acutely hazardous waste or 100 kg of any residue from
the cleanup of a spill of acutely hazardous waste
at any time.
Be aware that many states do not have the CESQG category
of generator. It is important that you review your state's
generator definitions so that you can understand which generator
standards apply to you.
Obtain an EPA
One way that EPA
monitors and tracks generator activity is by assigning EPA
ID numbers. If you generate hazardous waste, you must have
an ID number. Furthermore, it is important that you only
do business with transporters and disposal facilities that
also have EPA issued ID numbers. As a generator, you can
obtain an EPA ID number from your state hazardous waste
Place the waste
in appropriate containers
of hazardous waste first begins by placing the waste into
an appropriate container. Fixed tanks and portable containers
may be used for hazardous waste accumulation or storage.
Keep in mind that there are regulations pertaining to labeling,
air emissions and secondary containment from both tanks
tanks and containers must be in good condition, compatible,
closed at all times, properly labeled and ultimately managed
Labels help to
identify the material inside the tank or container as a
hazardous waste. Most tanks or containers need to be labeled
with the date that the first drop was placed into container.
/ accumulate the waste
Once the hazardous
waste has been placed into an appropriate container and
labeled, the waste should be moved to an area designated
for storage and/or accumulation of hazardous waste. Most
LQG's refer to this area as a "90 day storage area".
The reason for this is that most waste cannot be accumulated
onsite for longer that 90 days without obtaining a storage
permit. SQG's typically have 180 days or more for hazardous
waste accumulation and have different handling standards.
Be sure to check the regulations for specifics.
The Uniform Fire
Code also has requirements for proper waste storage. These
requirements include such items as aisle spacing and compatibility.
You can consult with your local fire department to determine
areas are often used at the point of waste generation.
EPA allows the placement of one 55-gallon drum at or near
the point of waste generation for the purpose of addressing
waste such as lab solvents that is more slowly generated.
Keep in mind that accumulation quantities may differ for
acutely hazardous and extremely hazardous waste.
You will need to
label the satellite drum as a hazardous waste drum, noting
the date that the first drop went in. For the most part,
you will have one year to fill the drum, three days to move
the drum to the 90-day area once filled and 90 days after
filling to dispose of the waste. Satellite accumulation
areas can be a good tool but do not let them get out of
hand. Proper inspection and inventory of satellite areas
is an essential part of most waste management programs.
Select a disposal
method and facility
You must now choose
how and where you would like your waste to be disposed of
or recycled. Listed below are several terms that you should
be familiar with as you begin evaluation of disposal options:
Treatment - Physical, chemical or biological alteration
of a hazardous waste to make the waste less hazardous.
Permits are typically required for any treatment with
a few exceptions.
Pack - A term used to describe the process of having
a waste disposal company arrive at your site and package
smaller quantities of hazardous waste into one consolidated
shipment. This typically occurs with off-specification
products, lab samples and lab waste.
- The process of removing the useful parts from your waste
stream for reuse elsewhere.
/ Reuse - To process so that basic raw material can
be used again.
- In simple terms, incineration is the process of burning
your waste and subsequently disposing of the remaining
stabilized ash into a landfill.
/ Encapsulation - The processes involved with "locking
up" the hazardous parts of your waste so that they
cannot change or leach out into the landfill. Sometimes
this can be as simple as mixing your waste with cement
or concrete substances and landfilling the hardened block.
- The direct disposal of your waste into a designated
excavation, or "cell". Hazardous waste landfills
come in all different shapes and sizes and typically only
accept dry materials. Since different classes of landfills
have different linings to protect the environment, be
sure that the landfill you choose is licensed to accept
the materials you will be sending.
technology there are new ways constantly being developed
to treat, recycle, reuse or otherwise dispose of hazardous
waste. Depending upon the composition of your waste, you
could be eligible for substantial discounts for useful materials
that can be reclaimed from your waste. Many states even
support online waste trading. Remember -- your waste could
be somebody else's pot of gold!
Regardless of which
disposal method or facility you choose, be sure to inspect
and research the facility that your waste is being sent
to. Remember that you, the generator, will be responsible
for this waste long after it has left your facility and
has been disposed of.
Disposal / Recycling Facility
Storage and Disposal Facilities (TSDF's) will want a sample
of your waste so that they may "profile" it.
Simply put, they want to know exactly what is being shipped
to them so that they can properly and safely manage it.
your sample, the TSDF will advise you of what treatment
options, if any, may be available at their facility.
Which is better,
disposal or recycle?
This is an answer
that only you and your business can determine. Many argue
that landfill costs are less and therefore landfilling is
better. Others argue that recycling, while sometimes more
expensive, is the right thing to do every time. Still others
believe that you should consider "lower total cost"
over "lower price per pound" each time.
must determine which environmental positions and risks your
facility or company is willing to take and how much they
are willing to spend. The responsibility for the waste
stays with the generator from cradle to grave.
Now that you have
selected a destination facility, you will need to select
a method to get the waste there.
Select a transporter
There are numerous
hazardous waste transporters from which to choose. A transportation
broker may be able to help you find the lowest rates. Keep
in mind that the EPA and Department of Transportation (DOT)
heavily regulate transportation of hazardous waste. Therefore,
make sure that you have researched the qualifications and
certifications of the trucking or rail company you choose.
waste containers for Transportation
EPA has adopted
DOT's pre-transport regulations for packaging, labeling,
marking and placarding. In summary, these regulations say
that hazardous waste must be properly packaged to prevent
leaking during normal transport. Additionally, the waste
containers must be labeled, marked and placarded so that
the characteristics and dangers associated with transport
are readily identifiable. Once again, many states enforce
stricter transportation requirements than that of the EPA.
Be sure that you are familiar with your state's requirements
for pre-transport of hazardous waste.
The Uniform Hazardous
Waste Manifest is the document used for transportation of
hazardous waste. This manifest creates a paper trail for
tracking hazardous waste.
The form is intended
to be uniform in structure but some states have their own
Since the generator
is legally responsible for completion of this document,
make sure that you have been properly trained to complete
and sign the hazardous waste manifest.
Many states have
requirements for returning a copy of the manifest to the
state within a certain amount of days after the waste has
arrived at the receiving TSDF. Make sure that you are familiar
with your state requirements regarding manifest reporting.
is an essential part of any waste management program. For
most documents involved in the hazardous waste process,
there is a three year record retention requirement.
are reporting requirements such as biennial reporting and
exception reporting. Good recordkeeping will aid you in
fulfilling your reporting requirements.
Be sure to check
with your state regarding required reports and record retention.
Whether you are
a LQG or a SQG, you will want to begin implementing waste
minimization programs immediately. Waste minimization or
source reduction programs are now required in many states.
Simply put, such a program will help you to reduce the quantity
of waste at the source. When all else fails and waste must
be generated, you should make every effort to recycle or
reuse the material in accordance with applicable laws and
Less waste generated
means a reduction in lab fees, handling expense, transportation
and disposal costs. Less waste generated means fewer compliance
exposures to your company. Less waste generated signifies
that you have an environmentally friendly company.
waste generated means less risk for everyone and for the
environment - from cradle to grave.
There are many
other regulations pertaining to the storage, accumulation,
transportation and disposal of hazardous waste. These include
such items as, employee training, emergency response plans,
source reduction, used oil recycling and land disposal restrictions
to name a few. You can obtain information on these items
and more at the Environmental
Protection Agency waste website .
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See you next month,