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What are the RCRA 8 Metals?


MetalsIn the past we’ve discussed several of the criteria for identifying hazardous wastes including hazardous waste characteristics and wastes which are listed.   RCRA monitors a long list of elements and solid wastes that are considered environmentally hazardous because they exhibit characteristics of corrosivity, toxicity, ignitability, or reactivity.

On this list there are eight RCRA monitored metals, known as the RCRA 8s.  These eight metals include: arsenic, barium, cadmium, chromium, lead, mercury, selenium and silver.  Each metal is discussed further below with the designated degrees of concentration identified for each metal.


The first RCRA 8 metal is arsenic.  While small quantities of arsenic can be found in food, water, and household products it becomes very dangerous at high concentrations.  At 250 parts per million (ppm) it becomes toxic.  As you may know, arsenic is monitored by RCRA because it is toxic to humans.  The Environmental Protection Agency (EPA) hazardous waste code for arsenic is D004, and its allowable limit in waste is 5 ppm.


Barium is a rather common element which has a multitude of applications.  Barium is used as rat poison, in the coloring of fireworks, and in the productions of items like fluorescent light bulbs and tiles.  It can often be found on the tips of drill bits at oil refineries.  “Barium most commonly finds its way to humans through well water supplies and near oil refineries. Barium's EPA hazardous waste code is D005, and its regulated level is 100 ppm.”


According to the Agency for Toxic Substances and Disease Registry (ATSDR), “Cadmium is a natural element in the earth's crust. It is usually found as a mineral combined with other elements such as oxygen (cadmium oxide), chlorine (cadmium chloride), or sulfur (cadmium sulfate, cadmium sulfide).  Most cadmium used in the United States is extracted during the production of other metals like zinc, lead, and copper. Cadmium does not corrode easily and has many uses, including batteries, pigments, metal coatings, and plastics.” Cadmium's EPA hazardous waste code is D006, and its regulated level is 1 ppm.


Small amounts of chromium, an element found naturally in rocks, soil, plants, and even animals, are needed for human health.  That said, when it is included in compounds created during the manufacture of other products it can become dangerous.  Chromium's EPA hazardous waste code is D007, and its regulated level is 5 ppm.


Lead is a naturally occurring element which can be found in small quantities in the earth’s crust.  The majority, however, comes from human activities like burning fossil fuels, mining, and manufacturing.  In recent years the use of lead has been diminished but it is still needed and used in things like the production of batteries, ammunition, metal products (solder and pipes), and devices to shield X-rays.  Lead's EPA hazardous waste code is D008; its regulation level is 5 ppm.


According to eHow, “Mercury is a naturally occurring metal that in the past was used in thermometers, dental fillings and batteries. Mercury enters the atmosphere from burning coal, manufacturing plants and mining. When combined with other elements, the resulting mercury compounds become more dangerous to human health.”  The EPA hazardous waste code for mercury is D009, and its regulated level is 0.2 ppm.


Much like chromium, small doses of selenium are necessary to maintain good health.  It is exposure to large doses that becomes dangerous.  According to the ATSDR, “most processed selenium is used in the electronics industry, but it is also used: as a nutritional supplement; in the glass industry; as a component of pigments in plastics, paints, enamels, inks, and rubber; in the preparation of pharmaceuticals; as a nutritional feed additive for poultry and livestock; in pesticide formulations; in rubber production; as an ingredient in antidandruff shampoos; and as a constituent of fungicides.”  Selenium's EPA hazardous waste code is D010; its regulation level is 1.0 ppm.


Silver is a naturally occurring substance which according to ATSDR is, “often found as a by-product during the retrieval of copper, lead, zinc, and gold ores. Silver is used to make jewelry, silverware, electronic equipment, and dental fillings. It is also used to make photographs, in brazing alloys and solders, to disinfect drinking water and water in swimming pools, and as an antibacterial agent. Silver has also been used in lozenges and chewing gum to help people stop smoking.”  Silver's EPA hazardous waste code is D011, and its regulation level is 5 ppm.


Quoted and cited information (unless otherwise noted) for this blog post was gathered from the eHow article, A List of RCRA Metals and the Agency for Toxic Substances & Disease Registry.  As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations. 

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The 3 R’s of Solid Waste Management


3 R'sI think it’s safe to say that we’ve all heard about the three R’s of waste management; reduce, reuse, and recycle.  But do you know why they are in that order and what each one entails?  In order to fully understand the meanings of the three R’s we need to talk about the impact solid waste has on the earth annually.  For example, did you know that each year, Americans throw away 50 billion food and drink cans, 27 billion glass bottles and jars, and 65 million plastic and metal jar and can covers [1].  So how can we cut back on these numbers?  That’s where the three R’s come in to play.


As you can likely deduce from its being the first of the three R’s, reducing is the best way to go about managing solid waste.  It’s quite simple really, the less you use the less waste you will produce.  This R causes the most unease in consumers because we tend to think we need to cut back on everything or we won’t be making an impact.  This is not the case, though.  By just doing a few things to cut back you can noticeably reduce your waste without totally altering your lifestyle.  You could do this by:

  • Buying products with less packaging.  Did you know that 30% of the waste in our landfills comes from product packaging?  When shopping for items choose the ones in just one bog or bag as opposed to those that are double and triple packaged.
  • Buying products in bulk.  By buying more of the same item all at once you reduce the overall amount of packaging you will encounter.
  • Try to stay away from disposable goods.  In particular, paper plates, cups, and plastic utensils. 
  • Buy durable goods.  Especially when making a big purchase look into the history and reviews of the item you are buying.  By buying something that will last you help to make sure wastes will stay out of landfills for longer. 


The second R is for reuse.  This one is becoming more and more popular with the surge of upcycling and craft projects all over the web.  If you reuse something as opposed to throwing it away you keep waste out of landfills and create something new.  A quick internet search can open a world of ideas or you can try any of the following:

  • Don’t automatically throw away items that are broken, several can be reused and turned into great new things!
  • Use sealable containers rather than plastic wrap.
  • Invest in some reusable shopping bags or bring old plastic ones with you to the store.
  • Look into upcycling ideas for common household items, many have alternate uses you may never have thought about.
  • Embrace hand-me-downs.  As a younger sibling I can understand wanting clothes of your own but if you have kids of similar ages try to supplement wardrobes with some hand-me-downs as well.  Another option is to shop second hand stores or consignment shops.  That way the items will be totally new to you while still helping to reuse someone else’s potential waste. 


The final, and probably the best known, R stands for recycling.  As you probably know, recycling is the process of remanufacturing a product to be sold as new.  Along with the basics of paper, plastic, glass, and cardboard there are tons of items which can be recycled that you may not even realize.  And remember, recycling only works if you complete the process by buying recycled materials.  Start recycling today by doing any of the following:

  • Check with your municipal garbage company to see if they have a recycling option as well.  This can help make recycling even easier.
  • Check with local recycling facilities to see what items they accept.
  • Start an office recycling program.



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Surface Impoundment Inspection and Response Actions


Surface Impoundment Inspection and Response ActionsLast week we talked about the design and operation requirements for surface impoundments.  Today we’re going to continue on that topic by covering the inspection and response actions that must be completed by surface impoundment operators.  In case you’ve forgotten, surface impoundments are a lot like landfill cells.  The main difference being that surface impoundments are used for temporary storage or treatment and a landfill cell is designated for final waste disposal.

What are the Inspection Requirements for Surface Impoundments?

To start, we must note that these inspection requirements must be completed in conjunction with the general inspection requirements in §264/265.226.  The first additional requirement deals with design and structural integrity of the land disposal unit.  According to the EPA, “the owner and operator must inspect liners and covers for any problems after construction or installation and continue inspections weekly and after storms to monitor for evidence of deterioration, malfunctions, improper operation of overtopping systems, sudden drops in the level of the impoundment contents, and severe erosions of dikes and other containment devices.”

The second additional requirement addresses leak detection sumps.  According to this rule, on a minimum of a weekly basis owners and operators of land disposal units like surface impoundments must monitor their leak detection sumps in order to measure the amount of liquid within them and to determine whether or not the action leakage rate (ALR) has been exceeded.  Doing so makes sure that both the liner and the leachate pump are working efficiently.  If owners or operators discover that the ALR has been exceeded they must notify the Agency and respond “in accordance with the response action plan.”

What Response Actions must Surface Impoundments comply with?

Much like the inspection requirements, surface impoundments must also comply with two types of response actions. According to the EPA, “the response action for the performance of the unit is determined by the terms of the response action plan, triggered when the ALR has been exceeded (§264/265.223). If the action leakage rate has been exceeded, the owner and operator must notify the Regional Administrator or authorized state; determine what short-term actions must be taken (e.g., shut down of the facility for repairs); determine the location, size, and cause of any leak; and send the assessments to the Region or authorized state.”

The other response action deals with emergency repair provisions in the case of a unit design failure at permitted facilities. The EPA specifies that “if there is an indication of a failure of the containment system (e.g., a sudden drop in the level of the contents not attributable to changes in the flow in or out of the impoundment), the surface impoundment must be removed from service.”  If this happens the owners and operators of the surface impoundment must follow the plans laid out in the contingency plan.  This would include any emergency repairs that need to be made. 


Quoted and EPA cited information (unless otherwise noted) for this blog post was gathered from the EPA document, Introduction to Land Disposal Units.”  As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations. 

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11 Ways to Reuse Plastic Bags


Plastic BagsI go through phases concerning what I do for lunch at work.  Lately I’ve been on a sandwich kick.  As you might expect, this means using plastic sandwich bags.  I tend to wrap my sandwiches in a paper towel before I put them in the plastic bag.  If you don’t do this I would recommend starting.  While it may seem counterintuitive to the idea of cutting back on waste it will help you to keep your bags clean.  That way you can use them more than once and they’ll be better prepped for some of the reuse ideas below.

1. ChasingGreen provides the following instruction for using a plastic bag to make your own baby wipes.  “Place soft paper towels in a sealable sandwich bag with a mixture of 1 tablespoon gentle antibacterial soap, 1 teaspoon baby oil, and 1/3 cup water. The mixture should be diluted enough to just moisten the towels, not drench them. Once your towels are sealed in the bags, you've got the thrifty parent's solution to expensive, store-bought baby wipes that quickly dry out!”

2. Use a plastic bag as an impromptu cold pack.  By wetting a cloth and putting it in a plastic bag you can create a cool cloth that won’t drip all over.  Additionally, you can keep a few of these premade in the freezer to use as icepacks. 

3. Make a frosting bag. Instead of buying premade frosting bags just use a Ziploc bag.  Simply scoop your frosting into the bag, trim off a corner, and you’re ready to go!

4. Make an emergency pack for your vehicle.  This is a great way to reuse larger sized Ziploc bags.  Fill one with items such as a small bottle of water, a power bar, a thermal blanket, a flashlight, and a candle.  Then if you find yourself in a tight spot you’ll have everything in one place.

5. Much like the frosting bag, a plastic bag can work as a quick funnel.  Just pour whatever you need funneled into your bag, pick the corner up and snip the end off, and place it into the opening you’re funneling into.   

6. Keep ice off the top of your ice cream.  If you place your open container of ice cream in a sealed plastic bag it will help to prevent ice from building up on the surface of your favorite frozen treat.  

7. Another idea from ChasingGreen, “Place small portions of…prepared cookie dough in sandwich bags, add drops of food coloring, and then squish the dough around until the color is uniform. Your hands will be dye-free and because the dough is already bagged, you can either bake it immediately or put it in the freezer for later use.”

8. Keep your valuables safe in the water.  If you’re canoeing or swimming place items like cellphones and car keys in a sandwich bag filled with air.  Not only will this protect them from the water should they get wet but it will keep them afloat if they fall off the dock or out of the boat. 

9. Make a portable doggy water dish.  If you and your canine companion like to walk or hike consider filling a gallon bag with water and keeping it in your bag.  If Fido gets thirsty just grab it out and hold it open so he can get a drink.

10.  Keep padlocks from freezing in the winter.  Zip a bag up as much as possible around your padlock to keep moisture out and prevent your lock from freezing up.  This is especially helpful if your snow removal equipment is in that padlocked shed!

11. Although not a reuse idea, you could also consider using other items in place of your plastic bags such as washable containers or reusable bags.

So what will you do with your plastic bags?  Let us know any other ideas in the comments section!  

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Surface Impoundments: Design and Operation


Surface ImpoundmentsWhen the EPA was designing the cradle-to-grave system for managing hazardous wastes they developed nine different land disposal units.  These units include landfill, surface impoundment, waste pile, injection well, land treatment facility, salt dome formation, salt bed formation, underground mine, and underground cave.  Four of these nine unit types required additional technical standards set forth by the EPA.  Today we will be covering the design and operating standards of one of those four, surface impoundments.  

Surface impoundments are a lot like landfill cells in that, “both units are either a natural topographic depression, manmade excavation, or diked area formed primarily of earthen materials, such as soil.”  Additionally, both may be lined with manmade materials.  Their uses, however, are what make them so different.  According to the EPA, “surface impoundments are generally used for temporary storage or treatment, whereas a landfill is an area designated for final waste disposal.”  Because of this, the closure and post-closure standards are very different. 

How are surface impoundments designed?

When the EPA began developing the design and operation standards for surface impoundments they operated with the goal of minimizing the formation and migration of leachate to the adjacent subsurface soil, groundwater, and surface water in mind. 

According to the EPA, “these comprehensive technical requirements for surface impoundments are the minimum technological requirements (MTRs) mandated by RCRA.  These sections require a double liner, a LCRS, and a leak detection system.”  The MTRs are applicable to all new units, lateral expansions, and replacement units constructed or reused after July 29th of 1992. 

First things first, we’ll talk about the double liner.  This system includes, “a top liner to prevent migration of hazardous constituents into the liner and a composite bottom liner consisting of a synthetic geomembrane and three feet of compacted soil material.” 

In addition to this liner system, the unit has to have a leachate collection and removal system (LCRS) which also serves as a leak detection system.  According to the EPA, “The LCRS, along with the leak detection system drainage layers, must be designed with a bottom slope of at least one percent, be made of materials chemically resistant to the wastes placed in the unit, and be able to remove the liquids at a specified minimum rate. The LCRS itself must be designed to collect liquids in a sump and subsequently pump out those liquids. In addition to the performance and design requirements, the LCRS must be located between the liners immediately above the bottom composite liner, enabling the LCRS to collect the largest amount of leachate, while also representing the most efficient place to identify leaks.”

Making sure that material can’t leak back into the earth is not the only consideration that must be made, however.  Surface impoundments also must be designed to prevent liquids from flowing over the top (called overtopping) and “ensure the structural integrity of any dikes.”  The owner or operator must also develop a site-specific flow rate for leachate which is called the action leakage rate or ALR.  This is used to indicate when a units system is not functioning as it should.

Because of the importance of these design regulations (and since none of the aforementioned technologies will work if the impoundment is not installed correctly or made of quality materials) the EPA requires a construction quality assurance (CQA) program to make sure that an impoundment meets all technical criteria.  According to the EPA, “The CQA program requires a CQA plan that identifies how construction materials and their installation will be monitored and tested and how the results will be documented (§264.19). The CQA program is developed and implemented under the direction of a registered professional engineer, who must also certify that the CQA plan has been successfully carried out and that the unit meets all specifications before any waste is received.”


Quoted and EPA cited information (unless otherwise noted) for this blog post was gathered from the EPA document, Introduction to Land Disposal Units.”  As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations. 



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10 Summer Energy Saving Tips


Summer Energy TipsIn the past we’ve done a couple of posts on saving energy in the winter but I don’t think we’ve discussed ways to do so in the summer.  Since the goal is to save energy year round I took to the internet to compile some of the best tips out there. 

1. Minimize the extra heat in your home.  You can do this by running your dishwasher and dryer at night as opposed to during the day.  Since it is cooler at night you won’t notice the increase in temperature so much.  You could also consider line drying clothes and turning off the “heated dry” option on your dishwasher so dishes will air dry.

2. Limit the use of your oven.  Much like the idea above, limiting the use of your oven is a great way to cut down on your summer energy consumption.  The oven will heat up your house and lead you to using more air conditioning.  Cook in a toaster oven or on the grill outside to cut back on the heat generated in your home. 

3.  Prep your home cooling system.  Before the heat really sets in have someone come tune up your central air system to make sure it’s running at peak efficiency.  Then make sure to replace your filters every month to keep it running smooth. 

4. Understand the sun.  Since it is at its highest and hottest during the day make sure to keep your windows, curtains, and blinds shut.  Once it cools off at night open them again.

5. Try not to run the air conditioning too much.  The generally agreed upon temperature to try to have your thermostat set on while you’re at home is 78°.  Consider ticking it up to around 83°-85° when you’re away.  Installing a programmable thermostat can help even the most forgetful of us to manage this system.

6. Turn your water heater down to 120 degrees Fahrenheit.  Unlike the cold winter months, summer doesn’t usually inspire hot hot showers.  Cut down on your energy use by not heating the water hotter than necessary.

7. Make use of your ceiling fans.  Even if you have central air, remember to not neglect your ceiling fans.  They help with circulating the air around your home and provide a nice breeze.  If you really want to embrace the fan life consider installing a whole house fan.  These can be run at night and help to capture the cooler air so you don't need to use your air conditioning so much the next day.

8. Seal up leaks.  Just like your heat can escape in the winter your cool air can escape in the summer.  Weather-strip, seal, and caulk around any leaky doors or windows.  Consumer Energy Center also recommends installing foam gaskets behind outlet covers.

9. Break out the shorts and tank tops!  Many of us tend to lounge around the house in whatever clothes we wore to work that day.  Ditch the khakis and button downs once your home and opt for lighter summer duds instead.   

10. Style At Home touts the benefits of “strategic gardening.”  They recommend “plant[ing] deciduous trees and shrubs against the south and west sides of your home. In summer, the leafy foliage shades against solar heat, while in winter, bare branches let warm sunlight stream into your home. As shade trees grow, so do your energy savings. According to the US Department of Energy, three big shade trees will chop as much as $250 off your annual energy bill.”

If you add some of these seasonal ideas to your regular list of ways to go green without noticing you will be in for a great and energy conscious summer! 

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Tracking and Record Keeping Requirements: LDR Waste Generators


Tracking and Recordkeeping Requirements: LDR Waste GeneratorsWe've been covering LDR topics recently.  Today we are going to keep on that train of thought and go over the tracking and record keeping requirements the EPA dictates for generators of LDR restricted wastes.  The EPA requires both generators and ten day facilities managing LDR restricted wastes to, “meet certain notification, certification, waste analysis, and recordkeeping requirements.”  The LDR notification and certification paperwork is similar to a hazardous waste manifest; it is used to help hazardous waste handlers as well as EPA enforcers to help make sure wastes are handled appropriately. 

According to the EPA, “A notification accompanies the initial shipment of each waste that is subject to LDR and includes such information as the waste code(s), the hazardous constituents present in the waste, and waste analysis data.”  Only if the waste or receiving facility changes does the EPA require further notification.  If a waste does not need further treatment to be eligible for land disposal a certification stating so must accompany the initial notification.  The EPA requires waste handlers to keep this paperwork so they can properly track wastes and ensure they are getting properly treated prior to land disposal.

The EPA requires generators to determine whether or not a waste is subject to LDR at “the point of generation.”  This determination can be made by testing or simply by applying knowledge.  If the waste is subject to LDR and does not meet set treatment standards then generators must let the treatment facility know in writing.  The notice must be included with the manifest and needs to include the following information:

  • “EPA hazardous waste code(s)
  • Identification of the waste as a wastewater or nonwastewater
  • Manifest number associated with the waste shipment
  • Waste analysis data (if available)
  • For characteristic wastes, any additional hazardous constituents present
  • When hazardous debris is to be treated by an alternative technology in §268.45, a statement to that effect and the contaminants subject to treatment
  • For contaminated soil, a list of the constituents subject to treatment and a statement that the soil does or does not meet LDR standards.”

If, however, the waste already meets set treatment standards the generator must submit a signed certification that says the waste meets the aforementioned standards.  That certification will then need to accompany a copy of the notification statement detailed above.

A similar notification must be submitted if the waste qualifies for an exemption from a treatment standard.  This can include national capacity variance, case-by-case extension, or no-migration exemption, among others.  If this is the case, the certification must also include the date on which the waste will become subject to LDR prohibitions.

According to the EPA, “generators may treat hazardous waste in accumulation tanks, containers, or containment buildings provided the units are in compliance with certain standards applicable to TSDFs (§262.34). EPA believes that generators should have the same recordkeeping and documentation responsibilities that apply to TSDFs when treating wastes to meet LDR treatment standards. Therefore, §268.7(a)(5) requires generators to prepare a waste analysis plan when treating wastes to meet LDR. The waste analysis plans must justify the frequency of testing based on a detailed analysis of a representative sample of the waste. The plan must contain all information necessary for proper treatment of the waste in accordance with Part 268, and must be retained in the facility's records (55 FR 22670; June 1, 1990). Generators who are conducting partial treatment, but not treating to meet treatment standards are not required to have a waste analysis plan.”


Quoted and EPA cited information (unless otherwise noted) for this blog post was gathered from the EPA document, “Introduction to Land Disposal Restrictions.”  As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations. 


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2014 Produce – Should You Buy Organic?


2014 ProduceWe’ve written about which produce to buy organic in the past.  In that post we talked about The Environmental Working Group’s “Dirty Dozen,” and “Clean Fifteen.”  These two lists are a great starting point to help you decide which produce you might want to buy organic.  The EWG aims to fill the gap in knowledge that many people have concerning pesticides in their produce.  In order to do so they have published an annual guide to inform consumers of the amount of pesticides found in different kinds of produce for that year.  In April of this year, they published their most recent findings. 

According to the EWG, “Some 65 percent of thousands of produce samples analyzed by the U.S. Department of Agriculture test positive for pesticide residues.”  That’s a startling number if you are trying to minimize your consumption of pesticides.

The “Dirty Dozen,” includes the twelve produce items that, “contained a number of different pesticide residues and showed high concentrations of pesticides relative to other produce items. [source]”  For 2014 the twelve items are:

1. Apples,
2. Strawberries,
3. Grapes,
4. Celery,
5. Peaches,
6. Spinach,
7. Sweet Bell Peppers,
8. Imported Nectarines,
9. Cucumbers,
10. Cherry Tomatoes,
11. Imported Snap Peas, and
12. Potatoes    

As you can probably guess, the “Clean Fifteen,” serves the opposite purpose.  According to the EWG, these are the items in which, “relatively few pesticides were detected,” or the concentrations of pesticides were very low.  The 2014 “Clean Fifteen,” included:

1. Avocados,
2. Sweet Corn,
3. Pineapples,
4. Cabbage,
5. Frozen Sweet Peas,
6. Onions,
7. Asparagus,
8. Mangoes,
9. Papayas,
10. Kiwis,
11. Eggplant,
12. Grapefruit,
13. Cantaloupe,
14. Cauliflower, and
15. Sweet Potatoes 

So when you are buying your produce this year try to keep these lists in mind.  Additionally, if you would like more information about the Environmental Working Group or their Shopper’s Guide check out their page on the subject HERE.

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LDR – Storage and Dilution Prohibitions


The Land Disposal Restrictions set forth by the EPA not only prohibit land disposal of wastes that have not met treatment standards.  They also prohibit two other activities; the long-term storage of a waste in place of treatment to set standards and the dilution of wastes as opposed to submitting them to proper treatment.  According to the EPA, “like the prohibition on land disposal, these prohibitions no longer apply once a waste meets its waste code-specific treatment standard.”  Read on for more details on these prohibitions, what they prevent, and how they work.

What is the storage prohibition?

The EPA created the storage prohibition as a way to ensure that waste handlers would not simply store hazardous waste in lieu of treating it.  Unless a waste (one which is subject to a treatment standard) is being stored to accumulate a quantity large enough to better facilitate recycling, treatment, or disposal it is prohibited by the EPA. 

The EPA “bears the burden of proving that the waste handler is storing in order to avoid meeting treatment standards rather than to facilitate legitimate recycling, treatment, or disposal,” for the first year of storage.  After this first year, however, “there is no strict time limit on legitimate waste storage.”  Additionally, in years following the first, “the burden of proof for showing that waste is indeed being legally accumulated to facilitate proper future management shifts from EPA to the waste handler.”

There are a couple of exemptions from the storage prohibition.  For example, “Generators accumulating waste on site in accordance with §262.34 and transporters storing waste at a transfer facility for 10 days or less.”  Additionally, wastes which qualify for an exemption from a treatment standard (case-by-case extension, no-migration petition, national capacity variance, etc.) or which were placed in storage before the “effective date of a prohibition on land disposal,” are exempt.

What is the dilution prohibition?

Generally, the EPA does not allow for the dilution of wastes in place of appropriate treatment.  What this means is that a waste handler could not usually achieve compliance with a numeric treatment standard by mixing a hazardous material with any other material simply to lessen the overall concentration.  Any material that hazardous waste is mixed with must reduce the mobility or toxicity of the hazardous constituents.

In a related vein, the “EPA may consider waste to be impermissibly diluted when a waste handler treats with an inappropriate technology.  For example, it is often impermissible to incinerate metal-bearing, inorganic wastes because incineration fails to destroy or immobilize the hazardous metal constituents.”

All this said; there are some cases where the EPA will allow dilution.  Because dilution is essential in some legitimate waste treatment methods, like “the aggregation of similar wastes to facilitate subsequent treatment,” the EPA will make some exceptions. 

“As a general rule, if aggregated wastes are all legitimately amenable to the same treatment, the aggregation step does not constitute impermissible dilution. In addition, waste handlers may dilute certain characteristic wastes that are managed in Clean Water Act regulated treatment systems (§268.3(b)). As well, certain characteristic wastes may be diluted to render them nonhazardous before disposal in a deep injection well regulated under the Safe Drinking Water Act (§268.1(c)(3)).”  The table below can help you to determine whether or not a specific waste handled in a specific way is subject to the dilution prohibition.


Quoted and EPA cited information (unless otherwise noted) for this blog post was gathered from the EPA document, “Introduction to Land Disposal Restrictions.”  As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations. 



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10 Ways to Reuse Newspaper


Reuse NewspaperThe first Sunday after I moved into my new apartment last year I went outside to find a newspaper in front of my door.  I knew I didn’t subscribe to the newspaper so I assumed the previous tenant must have.  A year later and I’m still getting papers every Thursday and Sunday morning.  At this point I’ve decided maybe my apartment complex has subscriptions for everyone living there.  Regardless, I’ve accumulated a lot of newspaper within the past year.  Luckily, newspaper is recyclable!  But it is also reusable.  Since the order of conservation goes reduce, reuse, recycle, I’ve compiled a few different ways that we can all reuse our excess newspaper.

1. Use it as kindling to start a fire.  This is a great idea especially as we move into bonfire season.  Instead of using a starter log or some other fire starter tightly ball or twist up old newspaper and light the pieces.  They will help to catch your logs and you’ll have a roaring fire before you know it.

2. Make some seed starters.  Bloggin' Billy's provides instructions on how to make newspaper seed starters.  These are great because once you plant them the newspaper will deteriorate and allow the roots to grow deep into the ground.  Newspaper also helps to cut down on weeds if you place it between plants or line the bottom of a raised bed with it.  

3. Use it for packing.  Save yourself some money on bubble wrap or packing peanuts and wrap items for storage or shipping in newspaper instead.  This will help protect your items just as well and you won’t be making more waste with excess packing items.

4. Wrap gifts in it.  I like to save the Sunday comics for this.  If you have a small gift to wrap the comic section makes for a whimsical and eco-friendly wrapping paper alternative. You can even wrap large items; you’ll just need more than one sheet of newspaper.

5. Line the bottoms of your fridge produce drawers.  Putting newspaper in the bottom of these drawers will help to absorb excess moisture and help cut down on odors.

6. Use it for your pets.  Whether you’re training a cat or dog to do their business where they should or lining the underside of a rabbit or hamster cage, newspaper can help you out.  You can line dog or cat cage floors with newspaper for easy cleanup of accidents.  By lining the cage bottoms of rabbits, hamsters, and other small pets with newspaper you can make cleaning much easier.  When the time comes all you’ll have to do is fold up the old newspaper and toss it in the garbage.

7. Clean your windows.  I mentioned in our Green Cleaning Supplies post that the Amish women in my hometown often use vinegar to clean windows.  What I didn’t say then was that they also tend to use newspaper in place of paper towels.  It may take a little practice but soon you’ll be able to get a streak free shine easily. 

8. Compost it.  Tear your newspaper up into strips and add it to your compost pile.  Red worms love newspaper so it makes a great addition to worm bins as well.

9. Use it for crafts.  Whether you’re into origami or paper mâché, newspaper can help you out.  Cut it into squares for origami projects (newspaper folds very well) or into strips for paper mâché.  You could also let your kids paint on it since paint would cover some of the text. 

10. Donate them.  Local animal shelters will almost always take newspaper to help line cages.  Goodwill as well will often take newspaper to help wrap up fragile items that are sold. 

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