Environically Speaking: Heritage Environmental's Blog

What are the Rules for Used Oil Mixtures?

Posted by Kyley Eagleson on Thu, Oct 30, 2014 @ 08:28 AM

What_are_the_Rules_for_Used_Oil_MixturesAs we said in Tuesday’s post on the Rebuttable Presumption, the current used oil management standards can get confusing when it comes to mixing used oil with other things.  We will be breaking used oil mixtures into four categories; used oil mixed with hazardous waste, used oil mixed with solid waste, used oil mixed with products, and other mixtures.

How do you manage used oil mixed with hazardous waste?

As with most any other type of waste, a used oil combined with a listed hazardous waste must be managed as a hazardous waste.  If, however, a used oil is mixed with a characteristic hazardous waste, the rules are not quite as simple.  The EPA sites two separate scenarios to help generators determine if a mixture must be handled as hazardous waste or if it can be handled as a used oil.

“The first scenario involves used oil that is mixed with a waste that is hazardous solely because it exhibits the characteristic of ignitability. If the resultant mixture is no longer ignitable, then the mixture can be managed as used oil, despite the inherent characteristics that the used oil may bring to the mixture… The second scenario involves used oil mixed with a waste that is hazardous because it exhibits one or more characteristic of hazardous waste (other than just ignitability). The resultant mixture must no longer exhibit any characteristics if it is going to be managed as used oil.”

The difference between the two scenarios is so important because used oil often displays a characteristic of hazardous waste from its normal use.  The EPA provides the following example, “used oil that displays the toxicity characteristic for lead (D008) is mixed with an ignitable hazardous waste (D001). Section 279.10(b)(2)(iii) allows this mixture to remain under the umbrella of used oil regulation even if it fails the Toxicity Characteristic Leaching Procedure (TCLP) for lead (D008), as long as the mixture is no longer ignitable. On the other hand, if the D008 used oil had been mixed with a reactive waste (D003), then the resultant mixture would need to be void of both characteristics in order to be managed as used oil. Otherwise, the mixture would need to be managed as hazardous waste.”

How is used oil mixed with solid waste managed?

The regulations for used oil mixed with solid waste aren’t nearly as stringent.  According to the EPA, any material that is contaminated with a used oil or that is contaminating a used oil is regulated as a used oil.  After the contaminating oil has been appropriately removed / drained from the mixture to the best extent possible (no visible signs of free-flowing oil) remaining wastes can be classified as solid waste.  Any oil separated from the solid waste must be disposed of as such.  “The exception to this is that a solid waste from which free-flowing used oil has been removed is still subject to regulation as used oil if it is burned for energy recovery.”

How do you manage used oil mixed with products?

According to the EPA, “the blending of used oil generated in diesel-powered vehicles with diesel fuel is excluded from the processing and re-refining standards when the mixture is used in the generator's own vehicles as a fuel. The mixture itself is also specifically excluded when used in this manner.” 

What do you do with other mixtures?

The EPA states that “used oil that is considered to be a hazardous waste solely because it exhibits one or more characteristic of hazardous waste, because it has been mixed with hazardous waste subject to the special provisions of §261.5 for conditionally exempt small quantity generators (CESQGs), or because it has been mixed with household hazardous waste is subject to regulation as a used oil, not as a hazardous waste.”

 

Quoted and EPA cited information (unless otherwise noted) for this blog post was gathered from the EPA document, RCRA, Superfund & EPCRA Call Center Training Module: Used Oil”  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.   

Topics: used oil, Used Oil Management, Used Oil Mixtures

What is the Rebuttable Presumption?

Posted by Kyley Eagleson on Tue, Oct 28, 2014 @ 05:30 AM

What_is_the_Rebuttable_PresumptionLast week we wrote about the history of used oil regulations.  In that post we discussed the steps that led up to the regulations the EPA has in place for used oils now.  This week we’re going to dig deeper into the subject of used oil regulations and look at how mixtures are handled.  Today we will cover the Rebuttable Presumption and how it applies to used oil management. 

What is used oil?

Before we can look at mixtures containing used oil it is important that we all know what used oil is.  According to the EPA, “used oil is defined as any oil that was refined from crude oil or any synthetic oil, and that is used and as a result of such use is contaminated by physical or chemical impurities.”  The EPA also points out that the terms “used oil” and “waste oil” are not interchangeable since waste oil or oily waste does not always meet the definition of used oil; in particular the distinction that the oil has been “used.”

Regulations can get confusing when it comes to mixtures containing used oil, especially when the oil is mixed with a hazardous waste.  In order to address this issue the EPA developed the Rebuttable Presumption.

What is the Rebuttable Presumption?

The Rebuttable Presumption came to be when the agency realized that determining if a used oil had been mixed with a hazardous waste would not always be possible.  Since mixtures such as that would need to be regulated as a hazardous waste the EPA needed to develop an objective test.  This is where the Rebuttable Presumption comes into play.

According to the EPA, “used oil that contains more than 1,000 parts per million (ppm) of total halogens is presumed to have been mixed with a regulated halogenated hazardous waste (i.e., spent halogenated solvents), and is therefore subject to applicable hazardous waste regulations.”  The “rebuttal” occurs when a generator attempts to demonstrate, through analysis or other documentation, that no halogenated hazardous waste has been mixed with the used oil.  One way to achieve this is by showing that the used oil “does not contain significant concentrations of halogenated hazardous constituents.”  If the generator succeeds in the rebuttal the used oil will no longer be considered to have been mixed with a hazardous waste and will be subject to only used oil management standards.

“The Agency believes, however, that some oils can become contaminated with more than 1,000 ppm halogens just through the normal use of the oil, without actually mixing the used oil with a hazardous waste. In the present program, the Agency amended the former regulations to exempt two specific types of used oil from the rebuttable presumption. Both metalworking oils containing chlorinated paraffins and used refrigeration compressor oils containing chlorinated fluorocarbons (CFCs) are exempt from the rebuttable presumption.”  This means that if a person generates one of these types of used oil, that person does not have to prove that the oil has not been mixed with a hazardous waste, even though it may contain more than 1,000 ppm total halogens.

Be sure to keep checking our blog for the post on used oil mixtures with hazardous waste, solid waste, products, and other mixtures.

 

Quoted and EPA cited information (unless otherwise noted) for this blog post was gathered from the EPA document, RCRA, Superfund & EPCRA Call Center Training Module: Used Oil”  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.   

Topics: used oil, Used Oil Management, Rebuttable Presumption,

Used Oil Regulations: The History

Posted by Kyley Eagleson on Thu, Oct 23, 2014 @ 10:41 AM

Used_Oil_Regulations_The_HistoryThe current used oil regulations were finalized in September of 1992.  Prior to that, they went through a few different iterations.  At the inception of RCRA §3014 required that the EPA make a decision on whether or not to list used oil as a regulated hazardous waste.  Additionally, the EPA needed to establish standards for used oil recycling. 

According to the EPA, “on November 29, 1985, EPA issued a proposed rule to list all used oil as hazardous waste, including petroleum-derived and synthetic oils. On the same day, management standards were proposed for recycled used oil and final regulations were issued prohibiting burning off-specification used oil in nonindustrial boilers and furnaces. By November 19, 1986, EPA decided not to list used oil, primarily because of the possibility that characterizing used oil as a hazardous waste might discourage or hinder recycling practices.”

In 1988, a court decision made the EPA reconsider the decision not to list used oil as a hazardous waste.  The court ruled that a decision needed to be made based on, “the technical criteria for listing waste specified in the statute, rather than the effects listing might have on the competing goal of recycling.”  This court ruling lead to a supplemental proposed rule being published in September of 1991.  This rule proposed three different options for regulating used oil.  These options included:

  • Identifying all used oils as hazardous waste under RCRA,
  • Designating only certain used oils (mainly nonindustrial) as hazardous, or
  • Creating basic management standards for used oil and only categorizing it as hazardous waste when disposed of.

According to the EPA, “prior to making a final selection of one of the three approaches to recycled used oil regulation, the final rule of May 20, 1992, stated that used oil destined for disposal would not be listed as a hazardous waste.”  The EPA justified that since most used oil has the “potential to be recycled, either through re-refining or burning for energy recovery,” and since waste destined for disposal is protected by the existing network of regulations, the listing decision could be deferred.

As we said above, the final rule was published in September of 1992.  This ruling created both a final listing decision for recycled used oil and management standards for used oil.  According to the EPA, “the Agency decided not to list recycled used oils because the management standards issued in this rulemaking would adequately protect human health and the environment.”

These standards affect generators, transporters, burners, marketers, processors, and re-refiners of used oil.  The program is built upon the idea that most used oil will be recycled as opposed to being disposed of.  Because the former program didn’t assume as much it had variable requirements for used oil management.  The current system means that virtually all used oil will be subject to the same standards.  Additionally, current regulations expanded the requirements that used oil handlers must fulfill.

So, does your company have used oil as a byproduct of your business?  How do you manage and dispose of it properly?

 

Quoted and EPA cited information (unless otherwise noted) for this blog post was gathered from the EPA document, RCRA, Superfund & EPCRA Call Center Training Module: Used Oil”  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.   

Topics: used oil, Used Oil Management

Land Treatment Units: Operations, Inspections, and Closure

Posted by Kyley Eagleson on Tue, Oct 21, 2014 @ 06:30 AM

Land_Treatment_Units_Operations,_Inspections,_and_ClosureLast week we wrote about land treatment units (LTUs) including what they are and how they are designed.  Today we would like to cover operation regulations, inspection and response actions, and closure guidelines. 

How are LTUs designed and operated?

The basic guidelines for design and operation of a land treatment unit can be found in 40 CFR 265.272.  These regulations read as followed:

“(a) Hazardous waste must not be placed in or on a land treatment facility unless the waste can be made less hazardous or nonhazardous by degradation, transformation, or immobilization processes occurring in or on the soil.
(b) The owner or operator must design, construct, operate, and maintain a run-on control system capable of preventing flow onto the active portions of the facility during peak discharge from at least a 25-year storm.
(c) The owner or operator must design, construct, operate, and maintain a run-off management system capable of collecting and controlling a water volume at least equivalent to a 24-hour, 25-year storm.
(d) Collection and holding facilities (e.g., tanks or basins) associated with run-on and run-off control systems must be emptied or otherwise managed expeditiously after storms to maintain design capacity of the system.
(e) If the treatment zone contains particulate matter which may be subject to wind dispersal, the owner or operator must manage the unit to control wind dispersal.”

According to the EPA, “these sections require the Regional Administrator or authorized state to specify certain parameters in the facility permit.”  Parameters to be specified include the rate and method at which waste is applied to an LTU, measures to be taken in order to control pH levels in soil, measures to enhance microbial and chemical reactions, and measures to control the moisture content of the treatment zone.  LTUs are not only subject to these regulations, however.  They also must control stormwater run-on and runoff.  

Do LTUs need to be inspected?

While there are no set inspection requirements for LTUs, the owner operator does have to maintain unsaturated zone monitoring in order to ensure the unit is meeting performance standards.  According to the EPA, “the purpose of unsaturated zone monitoring is to provide feedback on the success of treatment in the treatment zone and to determine if hazardous constituents are migrating out of the treatment zone (i.e., the monitoring program must be designed to determine the presence of hazardous constituents below the treatment zone).”

What this would generally mean is that the owner and operator of the LTU would need to monitor for the most stable hazardous constituents found in the waste placed in the treatment zone.  The EPA clarifies, however, that, ”unsaturated zone monitoring is not a substitute for groundwater monitoring. Both are required for land treatment units.”

How is an LTU closed?

According to the EPA, “When a land treatment unit is being closed, the owner and operator must maintain all operating parameters to continue the treatment processes, as well as maintain run-on and runoff controls and unsaturated zone monitoring. The major element of the closure procedure is placing a vegetative cover over the closing unit that is capable of maintaining growth without extensive maintenance. At the completion of closure, the owner or operator may submit the closure certification by an independent qualified soil scientist in lieu of an independent registered professional engineer. Closure and post-closure requirements are waived when the hazardous constituents in the treatment zone no longer exceed background levels.”

 

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.  

How are Land Treatment Units Designed?

Posted by Kyley Eagleson on Thu, Oct 16, 2014 @ 06:30 AM

How_are_Land_Treatment_Units_DesignedAccording to the EPA, “owners and operators of land treatment units (LTUs) must devise a program and demonstrate its effectiveness given the design of the unit and characteristics of the area. In addition, the regulations require specific operating requirements to be met in the treatment program.  The requirements outlined for the treatment program, including design and operating criteria and unsaturated zone monitoring, stem from a treatment demonstration.”

The purpose of the treatment demonstration is for the owner / operator to adequately display the effectiveness of the land treatment unit at degrading or immobilizing the hazardous constituents in the waste placed there within.  A treatment demonstration can involve laboratory testing and / or field testing on a sample soil plot. 

What is a Treatment Demonstration? 

The EPA states that, “the Regional Administrator or authorized state uses information provided by the treatment demonstration to set permit standards. Interim status units are not required to establish a treatment program because the interim status regulations are self-implementing.”  In order for owners and operators to place waste in an LTU the waste must be rendered nonhazardous or less hazardous from placement.  The EPA has established a list of parameters that owners and operators must establish during the treatment demonstration.  These parameters include the following:  

  • “Specify the wastes that may be handled at the unit. In general, land treatment is confined to wastes that are primarily organic and that can be greatly reduced in volume by physical, chemical, and biological decomposition in surface soils. The owner and operator must be able to account for smaller fractions of heavy metals and persistent organic compounds by immobilizing those constituents…
  • Formulate a set of operating measures. The LTU must be operated in a manner that will maximize degradation, transformation, and immobilization of hazardous waste constituents….
  • Establish unsaturated zone monitoring. The purpose of this program is to make sure that treatment is occurring within the treatment zone and that all hazardous constituents are being adequately treated. The information provided from the monitoring can help the owner and operator "fine tune" the treatment process to maximize the success of the treatment. Unsaturated zone monitoring involves soil monitoring (e.g., obtaining soil samples) immediately below the treatment zone…
  • Define the treatment zone. This zone comprises the horizontal and vertical dimensions of the unsaturated zone in which the owner and operator intend to perform the actual treatment. The zone can be no deeper than 1.5 meters (5 feet) and the bottom of the zone must be at least one meter (3.2 feet) above the seasonal high water table.”

According to 40 CFR §264.273, “the owner or operator must design, construct, operate, and maintain the unit to maximize the degradation, transformation, and immobilization of hazardous constituents in the treatment zone. The owner or operator must design, construct, operate, and maintain the unit in accord with all design and operating conditions that were used in the treatment demonstration…

At a minimum the Regional Administrator will specify the following in the facility permit:

  • The rate and method of waste application to the treatment zone;
  • Measures to control soil pH;
  • Measures to enhance microbial or chemical reactions (e.g., fertilization, tilling); and
  • Measures to control the moisture content of the treatment zone.”

 

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.      

Topics: Land Disposal Units, Land Treatment Units, LTU

What is a Land Treatment Unit?

Posted by Kyley Eagleson on Tue, Oct 14, 2014 @ 06:30 AM

What_is_a_Land_Treatment_UnitWe’ve done several posts in the past about land disposal units (LDUs); covering landfills, waste piles, and surface impoundments in detail.  While landfills, waste piles, and surface impoundments, and land treatment units all serve as the “grave” portion of the cradle-to-grave system set forth by the EPA, landfills, waste piles, and surface impoundments all share several regulatory requirements whereas land treatment units are very different in both purpose and management. 

What makes LTUs different?

According to the EPA, “land treatment involves the application of waste on the soil surface or the incorporation of waste into the upper layers of the soil in order to degrade, transform, or immobilize hazardous constituents present in hazardous waste.”  This differs greatly from landfills, waste piles, and surface impoundments because the primary goal of the aforementioned is to stop waste from migrating to the surface soil. 

In an LTU, the waste is treated “within the matrix of the surface soil.”  That said, the EPA mandates that any waste in an LTU be placed in the unsaturated zone of the soil.  This is the land that lies above the water table (the highest point of groundwater flow).  The success of an LTU is dependent upon the operational management of the unit because of this proximity to the groundwater.

Why use an LTU?

The goal of a land treatment unit is to allow the soil microbes and natural sunlight to degrade the hazardous waste.  Because of this, the design and operation standards are very different than those that landfills, waste piles, and surface impoundments face.  For example, “land treatment units generally do not use impermeable liners to contain wastes. Instead, units rely on the physical, chemical, and biological processes occurring in the topsoil layers. In a sense, these units can be viewed as an open system.”

In LTUs maintaining proper soil PH, carefully managing the rate of waste application, and controlling the surface water runoff are imperative to the unit running smoothly.  “Because placement of hazardous waste in a land treatment unit is considered land disposal, land disposal restrictions (LDR) standards must be considered. If the hazardous waste does not meet the applicable treatment standard prior to placement in the land treatment unit, the unit owner or operator must obtain a no-migration variance before applying any hazardous waste to the unit.”

Keep checking our blog for more posts on land treatment units including design and operating procedures, inspection and response, and closure practices. 

 

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.      

Topics: Land Disposal Units, Land Treatment Units, LTU

How are Hazardous Waste Landfills Designed and Managed?

Posted by Kyley Eagleson on Thu, Oct 09, 2014 @ 10:17 AM

How_are_Hazardous_Waste_Landfills_Designed_and_ManagedWhile we’ve covered certain aspects of Land Disposal Restrictions (LDR) in the past, we’ve not yet talked about how landfill cells are designed and managed.  For those who may not know, hazardous waste landfills are large areas of land divided into individual cells.  Perhaps the most important thing to note is that because hazardous waste landfills are final disposal sites for much of out hazardous wastes, they must continue to be monitored during their whole active life.  This includes closure and post-closure monitoring. 

How are landfill cells designed?

Much like the minimum technological requirements (MTRs) for waste piles and surface impoundments, hazardous waste landfills must have a double-liner, a leachate collection and removal system (LCRS), a leak detection system, and actual leakage reporting (ALR).  Additionally, landfills, like waste piles, must have a second LCRS above the top liner of the cell.  Finally, “landfills have to have stormwater run-on and runoff controls to prevent migration of hazardous constituents for at least a 25-year storm and a cover to prevent wind dispersal.”

How are landfills inspected?

Again, the inspection and response plans for hazardous waste landfills are nearly the same as those for surface impoundments.  This includes a response action plan in the event of the ALR being exceeded as well as a construction quality assurance (CQA) program.  In addition to having these items in place, a generator or owner / operator must perform monitoring and inspections.  “As with surface impoundments and waste piles, these requirements ensure that the unit is maintained in good working condition and that any problems are promptly detected.

How are landfill cells closed?

When a landfill cell is full it must be closed.  Since landfill disposal is typically a permanent situation the closure and post-closure regulations are somewhat different than those for other land-based units.  The EPA provides the example of the “requirement for a final cover over the landfill that can provide long-term minimization of liquid migration through the closed landfill, promote drainage, accommodate settling, and function with a minimum amount of maintenance.”

Owner / operators must also comply with the post closure requirements in Parts 264/265.117 through 264/265.120 relating to actions like monitoring and maintenance.  

Lastly, owner / operators have to “maintain the final cover, leak detection system, and groundwater monitoring system, as well as prevent run-on and runoff from damaging the final cover and protect the surveyed benchmarks (i.e., location and characteristics) of the landfill.”

Do any wastes require special treatment?

Like waste piles and surface impoundments, landfills must oblige with certain restrictions when dealing with ignitable, reactive, incompatible, or dioxin-containing wastes.  Unlike other units, however, landfills are prohibited from placing bulk or noncontainerized liquid hazardous waste or hazardous waste containing free liquids anywhere in the landfill.  Even placement of nonhazardous liquids is basically prohibited. According to the EPA, “there are only certain situations when containers holding free liquids can be placed in a landfill (e.g., small containers such as ampules, containers that are products such as batteries, or labpacks).  If sorbents are used to treat hazardous wastes so that the waste no longer contains free liquids, the owner and operator must use nonbiodegradable sorbents.”

Are there any requirements for containers in landfills?

“To prevent significant voids that could cause collapse of final covers when containers erode, and to maintain and extend available capacity in hazardous waste landfills, containers placed in a landfill must be either at least 90 percent full or crushed, shredded, or in some other way reduced in volume, unless the containers are very small, such as ampules (§264/265.315). 

Finally, there are special standards for lab packs or overpacked drums being placed in a landfill(§264/265.316). Lab packs generally contain small containers of a wide variety of hazardous wastes in relatively small volumes that are packed in sorbent material to prevent leaking. This sorbent material must be nonbiodegradable.”

 

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. 

Topics: Land Disposal Units, LDR, Hazardous Waste Landfill

What is a Waste Pile?

Posted by Kyley Eagleson on Tue, Oct 07, 2014 @ 07:53 AM

What_is_a_Waste_PileIn the past we have covered the subject of surface impoundments in some detail.  From design and operation to inspection and response actions, we have taken a close look at what that type of land disposal unit is used for and how one must be managed.  Today we are going to take a similar look into hazardous waste piles. 

The regulations concerning waste piles can be found in Part 264/265, Subpart L of 40CFR.  Basically, a waste pile is a pile of noncontainerized solid, non-flowing hazardous waste.  Waste piles are not a disposal method but merely serve as a storage and/or treatment option for generators.  Because they are not an end-of-life stage for waste, Subpart L does not contain post-closure care regulations.  However, waste piles do sometimes need to close with waste still in place.  If this happens, the waste pile is closed as a landfill and is susceptible to all applicable regulations.  This is discussed in more detail below.

According to the EPA, “owners and operators of permitted waste piles that meet special requirements are subject to reduced regulation.  Specifically, the waste pile must be located inside or under a structure and not receive free liquid, protected from surface water run-on, designed and operated to control dispersal of waste, and managed to prevent the generation of leachate.  If these standards are met, the owner and operator of the permitted waste pile are exempt from groundwater monitoring requirements, as well as the design and operation requirements for waste piles.”

How are waste piles designed?

The minimum technological requirements (MTRs) for waste piles are just about the same as those of surface impoundments.  These requirements include the need for new units, lateral expansions, and replacement units to be equipped with a double liner and leachate collection and removal system (LCRS).  Additionally, waste piles, with some exceptions, require a second leachate collection and removal system above the top liner. 

A permitted waste pile that is not subject to MTR (things like units, lateral expansions, or replacements that were commenced before July 29, 1992) only needs to have one liner and meet basic LCRS requirements.  The EPA states, “interim status waste piles that are not subject to MTR are subject only to liner, run-on, and run-off controls if leachate or runoff is found to be a hazardous waste.”

How do you close a waste pile?

As mentioned earlier, a waste pile is a storage or treatment area as opposed to an end stage disposal option for hazardous waste.  Because of this, prior to closure all waste residues and contaminated subsoils and equipment must be removed or decontaminated at closure.  According to the EPA, “if an owner or operator removes or decontaminates all waste residues and makes all reasonable efforts to remove or decontaminate all structures and soils and finds that some contamination remains, the waste pile will then be subject to the closure requirements for landfills, including post closure care.”

Are there special requirements for different kinds of wastes?

As with many storage options, RCRA puts special requirements on storing ignitable or reactive wastes in waste piles because these types of materials “require continuous protection from conditions that could cause them to ignite or react.”  Similarly, there are regulations prohibiting the placement of incompatible wastes or materials in the same waste pile unless certain precautions are taken to avoid incident.  Lastly, if an owner / operator plans to manage dioxin-containing waste he or she must have a special management plan approved by the Regional Administrator or authorized state.

What’s the difference between a waste pile and a containment building?

According to the EPA, “containment buildings, sometimes characterized as ‘indoor waste piles,’ are units used to hold noncontainerized piles of hazardous waste.  The difference between waste piles and containment buildings, from a regulatory standpoint, is that containment buildings are not land disposal units.  For this reason, containment buildings are designed with a container system rather than a liner and leak detection system.”

 

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. 

Topics: hazardous waste storage, Waste Piles,

Tips for Hazardous Waste Container Inspections

Posted by Kyley Eagleson on Thu, Oct 02, 2014 @ 08:30 AM

Tips_for_Hazardous_Waste_Container_InspectionsYou may remember from our post and eBook on the Top 10 Hazardous Waste Generator Violations that “Failure to Perform Weekly Inspections of Hazardous Waste Storage Areas,” is among the most common ways generators violate EPA regulations. 

Weekly container inspections are imperative to protect you, your company, and the health and safety of the public.  By performing your weekly inspections you can identify any issues that may arise and stop sills before they happen.

The EPA recommends that companies develop and maintain a standard inspection checklist that can be used during each weekly inspection.  This checklist should be detailed and include both the labeling and management procedures in place at your facility. 

We have prepared a checklist (with some additional tips) which can be downloaded by clicking the button below. 

This checklist can be modified to fit the needs of your facility but remember that at the very list you need to address the following:

  • Any leaks or staining coming from containers;
  • Condition of your containers including noting any dents, bulging, and / or corrosion; 
  • Proper labeling—this should include a clearly marked start date as well as the words “Hazardous waste.”  Any other relevant information about the waste should also be indicated on the label.
  • Management practices such as aisle space and drum stacking.

Remember, these inspections are very important in both protecting your company from committing a violation and ensuring the protection of human health and the environment.  Inspections should be detailed and methodical and should always be performed by a fully trained individual.

The EPA provides the following tips for conducting your weekly container inspections:

  • “Follow the inspection checklist – make detailed notes if you find something wrong.
  • Be thorough. Check the tops of drums to look for waste residue or corrosion.
  • Walk all the way around containers – check entire storage area.
  • Check containment area for stains.
  • Note anything unusual in containment area – even if it might not be a problem.
  • If problems are found, get the problem taken care of immediately.
  • Keep a logbook of the facility’s inspection checklist.”

 

Quoted and cited information for this blog post (unless otherwise noted) was gathered from the EPA Handbook for Hazardous Waste Containers.  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.

Topics: container management, Hazardous Waste, Container Inspections,

Tips For Managing Incompatible, Ignitable, and / or Reactive Wastes

Posted by Kyley Eagleson on Tue, Sep 30, 2014 @ 07:11 AM

Tips_For_Managing_Incompatible,_Ignitable,_and_Reactive_WastesWhen managing containerized wastes that are incompatible, ignitable, or reactive there are even stricter regulations that must be adhered to.  According to §265.177, “a storage container holding a hazardous waste that is incompatible with any waste or other materials stored nearby in other containers, piles, open tanks, or surface impoundments must be separated from the other materials or protected from them by means of a dike, berm, wall, or other device.”  So in layman’s terms, if a generator has containers that are holding wastes which are incompatible he or she must physically separate the two waste types in order to keep them from contacting and potentially reacting with other wastes or materials. 

In addition to this, there are special requirements for ignitable or reactive wastes.  Firstly, these types of wastes must be stored at least 50 feet from a facility’s property line.  You may have seen that many facilities stack their drums along the fence line in order to maximize storage space; this, however, is not an option for storing ignitable or reactive wastes.  The reasoning behind keeping these types of waste well within the boundary lines of a facility are twofold.  Firstly, they reduce the risk of the general public being able to reach or come in contact with the waste (additionally protecting them from any harm in the chance of an explosion), and secondly, if a release of the hazardous waste occurs the distance will help to prevent waste from migrating offsite.  Besides the distance issue, there are a few more key regulations to follow.

According to 40CFR §265.17(a), “the owner or operator must take precautions to prevent accidental ignition or reaction of ignitable or reactive waste. This waste must be separated and protected from sources of ignition or reaction including but not limited to: Open flames, smoking, cutting and welding, hot surfaces, frictional heat, sparks (static, electrical, or mechanical), spontaneous ignition (e.g., from heat producing chemical reactions), and radiant heat. While ignitable or reactive waste is being handled, the owner or operator must confine smoking and open flame to specially designated locations. “No Smoking” signs must be conspicuously placed wherever there is a hazard from ignitable or reactive waste.”

To break that down, wastes that are ignitable or reactive must be managed to prevent fire or explosions. At a minimum this means a generator needs to keep these types of waste away from:

  • Fire;
  • Hot surfaces such as machinery engines;
  • Sunlight or radient heat;
  • Frictional heat (keep drums stationary to help with this, never drag or pull drums along the ground);
  • Cutting and welding operations;
  • Sparks from static electricity or electrical operations;
  • And in the case of some reactive wastes, water.

And finally, smoking must be banned and signs stating “No Smoking,” must be posted in all areas where reactive or ignitable wastes are managed. 

As far as best management practices go, the EPA provides the following advice:

  1. “Use a funnel or hose to add or transfer wastes to drums. This will prevent spills. Remember to rinse the funnel and characterize the rinse water (a dedicated funnel would not have to be rinsed).
  2. If you notice a leak, or a container is in poor condition, transfer the waste to a new container immediately.
  3. Keep containers cool and dry.
  4. Make sure all container storage areas are clearly marked -- keep ignitable/reactive wastes in their own area.
  5. Don’t stack ignitable/ reactive wastes.
  6. Make sure to open and close steel drums with a spark proof bung wrench.
  7. Don’t push, roll, or drag containers. Use the right equipment to move the drums.
  8. Make sure the drums are easy to reach – keep an open aisle space so that people and equipment can move freely.
  9. Don’t drive equipment (trucks, forklifts) into container storage areas unless you are moving containers.
  10. Keep the containers in a ‘containment area’ to hold spills. Containment can be provided by dikes, berms, or walls.”

  

Quoted and cited information for this blog post (unless otherwise noted) was gathered from the EPA Handbook for Hazardous Waste Containers.  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.

Topics: container management, Containerized Waste, containerized hazardous wastes

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