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Disposing Of Hazardous Waste

By BOMI Institute

As industry develops and manufactures useful products, it also creates a dreadful by-product: industrial waste. Before laws were enacted to control waste creation and disposal, industries were dumping hazardous substances in their own backyards, in local dumps and landfills, or wherever they assumed they would not be observed or the public would not be affected—a practice called midnight dumping.

In response to drastic dumping practices, the U.S. Environmental Protection Agency (EPA) has defined two categories of hazardous waste: listed and characteristic. In order for a material to be a hazardous waste, it must first meet the definition of a solid waste.

A solid waste is any discarded material (garbage, refuse, sludge, liquid, or other waste). This EPA definition focuses not on the physical state of the material but on the physical act of discarding it, whether the intent is to abandon, recycle, reclaim, treat, store, or dispose of the material.

By this definition, a solid waste can take the physical form of a solid, a semisolid, a liquid, or even a contained gas. Note that not all solid wastes are hazardous.

Meeting The Criteria
If something meets the definition of solid waste, and is not exempt from being a hazardous waste, it then can considered to be a hazardous waste if it meets one of the following criteria:
• It is included on one of the four lists of hazardous wastes found in the Federal Resource Conservation and Recovery Act (RCRA) regulations.
• It exhibits one of the four defined hazardous waste characteristics of ignitability, corrosivity, reactivity, or toxicity.

However, there are noted exceptions to RCRA hazardous waste definitions; some waste generating groups have exempt status, and some wastes such as PCBs and asbestos are regulated by other authorities and acts. Some applicable RCRA excluded wastes include: industrial wastewater discharges permitted under the Federal Water Pollution Control Act; household and domestic wastes; certain mining and agricultural wastes (excluding pesticides); nuclear wastes regulated under the Atomic Energy Act; and conditionally exempt small quantity generator wastes from businesses generating less than 220 pounds of hazardous waste per month.

Listed Hazardous Wastes
The EPA has identified many wastes that are listed as hazardous and must be managed and discarded properly. They are divided into three categories to help business and industry recognize their potential responsibilities. Knowing the specific waste, waste process, and waste chemicals makes it possible to profile the waste from the lists that follow.

Generic wastes. This F-list (a four-digit code starting with the letter F, followed by three numbers—for example, F001) identifies nonspecific industries' wastes from common manufacturing processes. Identifying these wastes requires knowledge of the manufacturing processes and the chemicals involved; however, identifying the specific industry is not important.

Source specific wastes. This K-list identifies wastes from specific industries and industrial sources. An example is the bottom sediment sludge from the treatment of waste waters from wood-preserving processes that use creosote and/or pentachlorophenol (K001).

Commercial chemical products. This classification is intended for discarded chemical products—"off-spec" chemicals produced by manufacturers or old chemicals to be discarded in industry. This classification is subdivided into two categories based on the relative toxicity of the chemical. The U-list identifies many products in industry, such as chloroform (U044) and creosote (U051); the P-list identifies acutely hazardous chemicals, such as cyanide compounds (P029—copper cyanide, and others) and pesticides (P037—dieldrin, and others).

To be a U- or P-list hazardous waste, the chemical contaminant in the off-spec product must be "the sole active ingredient" in that product. If there were more than one active ingredient, the product, when disposed of, would not be a U- or P-list waste.

The only way to know whether a waste is EPA listed is to gather information about the waste and search each list, as appropriate. If a waste is identified on these lists, it must be treated as a hazardous waste and must be designated by the EPA waste code. If a waste does not appear on these lists, it does not necessarily mean it is nonhazardous. In this case, the waste must be examined to see whether it exhibits any characteristics associated with a hazardous waste.

Characteristics Of Hazardous Wastes
If a solid waste that is not listed is examined to determine if it has the characteristics described and is found not to have those characteristics, then the examination should be documented and the documentation placed in the generator's files. The purpose of the documentation is to protect the generator from possible enforcement action in the future, should the regulatory agency decide the waste in fact does have one of the following characteristics.

Ignitability. Ignitable waste can cause a fire under certain conditions. These types of wastes are classified as EPA code D001 if they are any of the following:

• A flammable liquid with a flash point below 140°F (exempt: solutions containing less than 24% alcohol by volume);
• A nonliquid that can cause a fire through friction, absorption of moisture, or spontaneous chemical changes and, when ignited, burns so vigorously and persistently that it creates a hazard;
• An oxidizer; or
• An ignitable compressed gas.

Corrosivity. Corrosive waste is classified as EPA code D002 and exhibits the following properties:
• Has a pH of less than 2.0 or greater than 12.5; and
• Is a liquid capable of corroding steel at a rate of 6.35 mm/year at a temperature of 130°F.

Corrosive wastes can be neutralized by the generator without requiring a treatment permit to render them noncorrosive.

Reactivity. Reactive waste is generally unstable and is classified as EPA code D003. These types of wastes exhibit the following properties:

• React violently, form a potentially explosive mixture, or generate toxic fumes when mixed with water;
• Explode or are otherwise capable of detonating or exploding at standard temperatures and pressure or if subjected to an ignition source;
• Are cyanide or cyanide-bearing wastes that generate toxic gas (hydrogen cyanide) when subjected to certain pH conditions; and
• Are sulfide or sulfide-bearing wastes that generate toxic gas (hydrogen sulfide) when subjected to certain pH conditions.

Toxicity. Toxic waste is identified through laboratory testing known as the toxic characteristic leaching procedure (TCLP). This test simulates a scenario under acid rain conditions showing what will leach out of the waste in a landfill and possibly contaminate groundwater.

These wastes, categorized as EPA codes D004 through D043, will be identified for each toxin that will leach in excess of the TCLP-established limits. Because there are specific toxic elements and organic compounds of interest, knowledge of the waste can be very important.

Beyond these RCRA definitions, two other issues must be addressed. First, although waste may not fit the RCRA definition, it may still cause significant harm. For instance, mineral spirits, when disposed of, probably do not meet the definitions of either "listed" or "characteristic" hazardous wastes; yet it would be imprudent to dispose of mineral spirits along with ordinary trash, because mineral spirits could easily be a significant source of combustion.

Second, remember that the solution to pollution is not dilution. That is, a hazardous waste cannot be legally rendered nonhazardous simply by diluting the hazard. If a nonhazardous solid waste is mixed with a hazardous waste, the resulting mixture is treated as a hazardous waste.

The EPA has approved levels of treatment that can be achieved by various non-dilution treatment technologies. These treatments can chemically and/or physically alter a hazardous waste to render it nonhazardous. A generator typically does not treat its waste, choosing rather to have it transported to a permitted treatment and/or disposal facility.

The challenge for facility managers and employees is to understand how these laws and regulations apply to their businesses, develop the appropriate compliance program, and implement it on a long-term basis. The key to success, as with any effort, is teamwork. All levels of the organization must be on the same page, whereby everyone understands his or her role and communicates the problems and issues that arise daily.

This article is excerpted from BOMI Institute's newly updated Technologies For Facility Management, © 2002, a requirement in BOMI's Facility Management Administrator (FMA) professional designation program. For further information, call BOMI Institute at (800) 235-2664 or visit www.bomi-edu.org.