Managing Waste Chemicals

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Managing Waste Chemicals
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Emergence of Regulations to Manage Chemical
Wastes

• Growing awareness of the impact and magnitude of
  abandoned waste sites on the environment and
  human health (Love Canal).
• The exponential growth of manufactured chemicals
  entering the environment.

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• The Comprehensive Environmental Response,
  Compensation, and Liability Act (CERCLA),
  commonly known as Superfund was enacted by
  Congress on December 11, 1980. This law created a
  tax on the chemical and petroleum industries and
  provided broad Federal authority to respond
  directly to releases or threatened releases of
  hazardous substances that may endanger public
  health or the environment. CERCLA
• established prohibitions and requirements
  concerning closed and abandoned hazardous waste
  sites
• provided for liability of persons responsible
  for releases of hazardous waste at these sites
  and
• established a trust fund to provide for cleanup
  when no responsible party could be identified.
• The law authorizes two kinds of response actions
• Short-term removals, where actions may be
  taken to address releases or threatened releases
  requiring prompt
• response.
• Long-term remedial response actions, that
  permanently and significantly reduce the dangers
  associated with
• releases or threats of releases of hazardous
  substances that are serious, but not immediately
  life threatening.

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• Resource Conservation and Recovery Act
• The Resource Conservation and Recovery Act (RCRA)
  of 1976 was the first substantial effort by
  Congress to establish a regulatory structure for
  the management of solid and hazardous wastes.
• Subtitle C of RCRA addresses "cradle-to-grave"
  requirements for hazardous waste from the point
  of generation to disposal.
• Subtitle D of RCRA contains less restrictive
  requirements for non-hazardous solid waste.

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Evolution of Waste Management Legislation
Solid Waste Disposal Act of 1965
Hazardous and Solid Waste Amendments Of 1984
Resource Conservation and Recovery Act of 1976
Federal Facilities Compliance Act of 1992
Land Disposal Program Flexibility Act of 1996
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RCRA Cradle to Grave Waste Management
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Resource Conservation and Recovery Act -1976

• A cradle-to-grave system to track and monitor
  hazardous waste
• Established management standards for anyone who
  generates, recycles, transports, treats, stores,
  or disposes of hazardous waste.
• Authorized States to implement RCRA programs
  equal to or more stringent than federal program.
• Goals
• Ensure that wastes are managed in manner that
  protects human health and the environment
• Reduce/eliminate the amount of waste generated,
  including hazardous wastes
• Conserve energy and natural resources through
  waste recycling and recovery.

• Banned open dumping
• Provided a comprehensive national program to
  encourage source reduction, recycling, and safe
  disposal of solid waste.
• Mandated strict requirements for treatment,
  storage, and disposal of hazardous waste to
  minimize present and future risks.
• First hazardous waste facility permit was issued
  in October, 1981.

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Hazardous and Solid Waste Amendments (HSWA) - 1984

• Created the Land Disposal Restriction (LDR)
  program.
• Established treatment requirements to be met
  before waste could be disposed of in land units.
• Hazardous waste must be physically or chemically
  treated to reduce toxicity or mobility prior to
  disposal.
• Between 1986 and 1998, EPA issued treatment
  standards specifying the method or level of
  treatment for hazardous waste.
• Specified permitting deadlines for hazardous
  waste facilities
• Reestablished permitting deadlines for hazardous
  waste landfills, incinerators and storage
  facilities.
• By November 8. 1985, landfills and surface
  impoundments that failed to comply with financial
  assurance and ground-water monitoring
  requirements were forced to close.
• Established RCRA Corrective Action requirements
• Clean up standards established to prevent human
  exposure to, and migration of, contaminated
  groundwater from RCRA permitted facilities.
• Corrective Action are meant to
• Lead to focused, flexible cleanups
• Pilot innovative approaches to cleanups
• Connect communities and capitalize on
  redevelopment potentials.
• Regulated organizations that generated small
  quantities of hazardous waste.

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RCRAs Three Interrelated Programs
Subtitle D
Subtitle C
Subtitle I
Underground Storage Tank Program
Solid Waste Management
Hazardous Waste Management
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RCRA Hazardous Waste Management Scheme

• Hazardous Waste Identification
• Hazardous Waste Recycling and Universal Wastes
• Standards Governing Hazardous Waste Generators
• Standards Governing Transporters
• Standards Governing Treatment, Storage and
  Disposal
• Land Disposal Restrictions

• Hazardous Waste Combustion
• Permitting of TSD Facilities
• Corrective Action to Clean Up Hazardous Waste
• Enforcement of Regulations
• Authorization of State Programs

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• A Hazardous Waste is
• A "solid waste" which because of its quantity,
  concentration, or physical, chemical, or
  infectious characteristics may
• Pose a substantial present or potential hazard to
  human health or the environment when improperly
  treated, stored or disposed of, or otherwise
  mismanaged or
• Cause or contribute to an increase in mortality,
  or an increase in irreversible or incapacitating
  illness.

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Defining Hazardous Waste

• Is the material a solid waste?
• Recycled materials
• Secondary materials
• Excluded wastes
• Some solid wastes
• Exempt hazardous wastes
• Raw or process wastes
• Waste samples
• Is the waste a listed hazardous waste?
• Listed hazardous wastes
• Waste listed due to certain characteristics

• Hazardous Waste Characteristics
• Ignitibility
• Corrosivity
• Reactivity
• Toxicity
• Special Wastes
• Mixtures
• Derived-from rule wastes
• Contained-in rule wastes

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Hazardous Waste Identification Process

• Is the material a
• solid waste?

No
Yes
2. Is the waste excluded from the definition of
solid or Hazardous waste?
Yes
Material is not subject to RCRA Subtitle
C regulation
No
3. Is the waste a listed or characteristic hazardo
us waste?
No
Yes
Yes
Waste is subject to RCRA Subtitle C regulations
4. Is the waste delisted?
No
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RCRA Hazardous Waste Management Scheme

• Hazardous Waste Identification
• Hazardous Waste Recycling and Universal Wastes
• Standards Governing Hazardous Waste Generators
• Standards Governing Transporters
• Standards Governing Treatment, Storage and
  Disposal
• Land Disposal Restrictions

• Hazardous Waste Combustion
• Permitting of TSD Facilities
• Corrective Action to Clean Up Hazardous Waste
• Enforcement of Regulations
• Authorization of State Programs

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Evaluation of Recycled Wastes

• Is the waste recycled by being
• Used as an ingredient
• Used as a product substitute
• Returned to the production process?

Yes
Yes
Is the waste reclaimed?
No
Waste is a solid waste
Is recycled waste Used in a manner similar to
disposal? Burned for energy recovery, used to
produce fuels or contained in fuels? Accumulated
speculatively? A dioxin-like waste?
Yes

• Facility must determine if waste is
• Spent material
• Sludge
• By-product
• Commercial chemical product
• Scrap metal

No
Waste is not a solid waste
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RCRA Hazardous Waste Management Scheme

• Hazardous Waste Identification
• Hazardous Waste Recycling and Universal Wastes
• Standards Governing Hazardous Waste Generators
• Standards Governing Transporters
• Standards Governing Treatment, Storage and
  Disposal
• Land Disposal Restrictions

• Hazardous Waste Combustion
• Permitting of TSD Facilities
• Corrective Action to Clean Up Hazardous Waste
• Enforcement of Regulations
• Authorization of State Programs

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Requirements for Hazardous Waste Generators

• Regulated generators
• Large Quantity
• Small Quantity
• Conditionally Exempt
• Waste identification
• Registration ID number
• Accumulation times
• Preparation of waste for transport
• Waste manifests
• Recordkeeping and reporting
• Emergency procedures and
• Contingency planning
• Personnel training

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RCRA Hazardous Waste Management Scheme

• Hazardous Waste Identification
• Hazardous Waste Recycling and Universal Wastes
• Standards Governing Hazardous Waste Generators
• Standards Governing Transporters
• Standards Governing Treatment, Storage and
  Disposal
• Land Disposal Restrictions

• Hazardous Waste Combustion
• Permitting of TSD Facilities
• Corrective Action to Clean Up Hazardous Waste
• Enforcement of Regulations
• Authorization of State Programs

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Hazardous Waste Treatment

• Oxidation Strong oxidizing agents breakdown
  hazardous wastes into less toxic or less mobile
  constituents.
• Deactivation A process that removes the
  hazardous nature of waste by neutralizing
  characteristics such as ignitibility,
  corrosivity, or reactivity.
• Incineration High temperature oxidation of
  waste, usually at temperatures ranging from 1600
  to 2500 F.
• Industrial Furnace Uses thermal energy to
  recover energy or materials. Includes cement
  kilns, lime kilns, coke ovens, blast furnaces,
  and smelting furnaces.

• Micro-encapsulation A process that coats the
  surface of the waste material with a thin layer
  of plastic or resin to prevent leaching.
• Neutralization A process used to treat
  corrosive hazardous waste streams.
• Stabilization A process that reduces the
  mobility of hazardous waste constituents.
• Treatment in Tanks Mechanical settling, gravity
  settling, or chemical oxidation to remove
  hazardous constituents.

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Hazardous Waste Treatment Disposal Standards

• Permits to Operate
• Performance Standards
• Recordkeeping Reporting Requirements
• Groundwater Protection
• Corrective Action
• Emergency Preparedness Contingency Planning

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Some Cases -

• Laboratory Waste Management
• Corrective Action
• Healthcare Compliance Initiative

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Management of Waste Chemicals Generated in
Laboratories
Large Quantity Generator Waste Management
Standards Part 262 RCRA
Labs can be subject to Satellite
Accumulation Standards Part 262.34
Best Management Practices HHMI Proposal
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Defining Hazardous Waste

• Project XL New England Laboratory Project
• Evaluated flexible application of generator rules
  to academic research laboratories.
• HHMI Report to Congress October 2001
• Proposed a set of best practices for the
  management of laboratory wastes.
• Natl Assoc. of College and University Business
  Officers March 2002 Environmental Excellence
  in Higher Education
• Addressed the application of waste management
  regulations to the activities of colleges and
  universities.

• US EPA Notice for Information on the
  Effectiveness of RCRA Generator Program and Areas
  for Improvement October 2003.
• Meeting of agencies and stakeholders on rules
  flexibility
• US EPA Memorandum March 2004
• Clarification regarding satellite accumulation
  practices.
• US EPA Notice Concerning hazardous waste
  generator program April, 2004.

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Emerging Issues -

• Healthcare Compliance
• Hazardous Drugs
• Chemotherapeutics
• Electronic Wastes

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Whats Regulated by RCRA?

• Certain chemotherapeutic drugs
• Drugs that are listed hazardous waste
• Drugs that are characteristic waste
• Containers that held regulated drugs

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RCRA Corrective Action
Plating Facility
Waste Treatment
Nickel Cadmium Waste
Drum Storage Pad
Paint Shop
Sedimentation Tanks
Contaminant Plume