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Is Your Waste Hazardous?

PRESENTED BY JOHN CRAWFORD

Presenter

John Crawford◦25 Years with IDEM Hazardous Waste Compliance program

◦Enforcement case manager, inspector

◦18 years as Section Chief

◦On-call Manager, Emergency Response Program

◦Founder, HW Environmental LLC

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Presentation•Overview

•Waste identification

•Exclusions

•Recycling

•Waste Determinations

•Used Oil and Universal Waste

•Generator categories

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IN THE BEGINNINGOut of Sight, Out of Mind

Dilution is the Solution

Love Canal

Seymour Recycling

Valley of the Drums

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Alphabet Soup

RCRA

◦ Resource Conservation and Recovery Act

IDEM

◦ Indiana Department of Environmental Management

TSD

◦ Treatment, Storage and Disposal facility

LQG

◦ Large Quantity Generator

SQG

◦ Small Quantity Generator

CESQG

◦ Conditionally Exempt SQG

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RCRA in Perspective

16 permitted TSDs in Indiana

◦ 11 Commercial TSDs

◦ 1 Commercial Landfill

550 LQGs

1000 SQGs

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Indiana Rankings

Indiana is ranked # 10 in the number of LQG’s.

Indiana is ranked # 8 in total volume of HW generated.

Indiana is ranked # 5 in total quantity shipped.

Indiana is ranked # 4 in total quantity received.

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“Hazardous Waste” definition

•Has a specific regulatory meaning

•Is a subset of “hazardous substances” (CERCLA & OSHA)

•Has different regulatory meaning than “hazardous materials” (DOT)

Haz Material

Haz Substance

Haz Waste

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Waste Determinations

•A person who generates a solid waste must determine if that waste is a hazardous waste using the following method:

Determine if it is excluded

Determine if it is listed

Determine if it is characteristic by either:

• Testing

• Applying knowledge

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And the #1 violation is...

Lack of Waste Determination

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“Hazardous Waste” definition

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A material is a RCRA hazardous waste if

• It is a solid waste.

• It is not excluded, and

• It is Listed or exhibits a Characteristic

Definition of Solid Waste

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A solid waste is any discarded material.

A discarded material is any material which is:

• Abandoned

• Recycled

Materials are solid waste if they are abandoned by being:

• Disposed

• Burned/Incinerated

• Accumulated, stored or treated before or in lieu of being abandoned by being disposed or burned

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Regulated RecyclingA material is recycled (i.e. discarded) if◦It is applied to or placed on the land

◦Burned for energy recovery

◦Reclaimed◦Accumulated speculatively

◦Accumulated, stored, or treated before recycling

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Solid Waste

Exempted Recycling

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Materials used or reused as ingredients to make a product (no reclamation involved)

Used or reused as effective substitutes

for commercial products

Returned to the original process (no

reclamation involved)Solid

Waste

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Exclusions42 exclusions in two categories

Materials which are not solid waste◦Examples: closed-loop reclamation, scrap metal

Solid wastes which are not hazardous waste◦Examples: oil filters, household waste, ag waste, treated wood, UST media and debris

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Listed Waste

• Non-Specific Sources

• F003 and F005 spent solvents such as perc., methylene chloride, trichlor, xylene, acetone, toluene, MEKF

• Specific Industrial Sources

• K062 pickle liquor generated by steel finishing operations of facilities within the iron and steel industry (SIC Codes 331 and 332)K

• Commercial Chemical Products

• Acute, regulated at 2.2 poundsP

U • Commercial Chemical Products

• Toxic, Off-Spec, Sole Active Ingredient

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Characteristic Waste

D001 Ignitable (liquid, flashpoint < 140)

D002 Corrosive (aqueous, pH <2 or > 12.5)

D003 Reactive (reacts w/ H2O, explosive)

D004-D0043 Toxic (TCLP)

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TCLP

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40 constituents: Metals, Pesticides, Volatiles, Semi-volatiles

Examples:TCLP Contaminants

EPA HW

No.

Contaminant Regulatory Level

(mg/L)

D006 Cadmium 1.0

D007 Chromium 5.0

D008 Lead 5.0

D009 Mercury 0.2

D018 Benzene 0.5

D035 Methyl ethyl ketone 200

D039 Tetrachloroethylene 0.7

D040 Trichloroethylene 0.5

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Generator Knowledge

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Is it a solid waste?

Yes

Is it excluded?

No

Is it a listed waste?

No

Is it a characteristic

waste?

Not regulated as a Hazardous Waste.

Dispose of all waste properly.

No

Yes

Yes

YesNo

Waste Determination

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Find Your Hidden Waste

Use outside eyes.

Walk the facility.

Ask process team.

Dumpster dive.

Take out the trash.

Possible sources:

◦ Filters, maintenance activities, tank clean-outs, process clean-outs, sumps, pits, troughs, maintenance shop, under benches, behind equipment, material storage, outbuildings, trailers, closets, lofts, labs, secondary containment, buckets, boiler rooms, bag houses, cabinets (esp. chemical/fire), basements

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Waste Inventory

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HW Generator Categories

CESQG SQG LQG

Rate <220 lbs

(.5 drum)

220-2,200

(.5-5 drums)

>2,200

>2.2 lbs of acute

Max. amount on-site

2,200 lbs

(5 drums)

13,220 lbs

(30 drums)

NA

Accumulation time

NA 180 days 90 days

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Basic Generator Requirements

Disposal EPA

ID #

Manifest Container

Standards

Documented

Training

Written

Contingency

Plan

Fee

CESQG MSW

SQG TSD X X X

LQG TSD X X X X X X

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Thanks!Contact Info:

John CrawfordFounder, Senior Project Manager

HW Environmental LLC317 964 1823Hwenviro.com

john@hwenviro.com