Hazardous Waste and Nuclear Waste
Class #4
Homework:
Homework #4 is due before next class. Complete and submit to Professor Auberle and me before beginning class #5. Also should be working on Case study and research paper.
As always, welcome current event reports from you. Important part of class.
Overview of RCRA; what is hazardous waste?
1. Announcements
Homework #3 due before proceed with Class #4. Research paper outline also due. If not yet done, should complete and submit to Professors Auberle and Jeffery before proceeding.
2. Current Events
3. Overview of RCRA
Last class discussed Subtitle D of RCRA, portion dealing with non-hazardous solid waste. Today talk about Subtitle C, portion dealing with "Hazardous" Wastes. Before talk about what hazardous waste is, some background.
US most ambitious regulatory program for management hazardous waste any country in world. Pre-RCRA (adopted 1976, regulations operative about 1980), adage "out of sight, out of mind" applied to disposal hazardous waste. In less than decade, had given way to comprehensive national program to encourage waste reduction and advanced treatment and disposal of hazardous wastes.
Congress enacted as national policy mandate that hazardous waste be treated, stored, and disposed of so as to minimize present and future threat to human health and environment.
EPA and states sought to implement mandate through complex regulations issued uncer RCRA of 1976, as amended by Hazardous and Solid Waste Amendments of 1984.
Cradle to Grave
RCRA designed to provide "cradle-to-grave control hazardous waste by imposing management requirements on generators and transporters of hazardous wastes and upon owners/operators of treatment, storage, and disposal (TSD) facilities.
RCRA applies mainly to active facilities and does not address serious problem abandoned and inactive sites. Congress established remedies and allocated responsibilities correcting problems those sites in Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), commonly known as Superfund. Discuss in detail in next class, Class #5.
3 keys to Cradle to grave system:
Identification of waste as hazardous waste
Notification to EPA by persons managing hazardous waste
Requirements imposed on generators, transporters, and TSD facilities.
Have material. Required to manage it in some way. Sell, give away, throw away, store. First question: Is material a hazardous waste? If not, rest of what going to tell you not apply.
Definition hazardous waste 1. Statute 2. Regulation
Hazardous Waste: Starting point is friend from last class, "solid waste". Is material solid waste? Recall broad definition. Potentially any waste, regardless of physical form.
May be questions what point becomes waste. Returned goods. Waste when returned or waste when manufacturer decides can’t use. As see, may make difference how managed.
Is it exempt from being considered hazardous waste?
E.g., Household waste, ag wastes returned to ground as fertilizer, mining overburden returned to mine site, oil and natural gas exploration drilling waste, cement kiln dust wastes. If solid waste not exempted, is hazardous waste if is listed by EPA on lists of hazardous wastes or if exhibits any of 4 hazardous waste characteristics identified in EPA regulations.
Is it a listed waste?
Is it a characteristic waste?
Listed Wastes:
EPA 3 hazardous waste lists. Each listed waste has hazardous waste number which can be used to identify waste.
Wastes from nonspecific sources (Spent nonhalogenated solvents, such as toluene, produced by an industry source)
Wastes from specific sources (Bottom sediment sludge from treatment of wastewaters by wood preserving indsutry)
Commercial chemical products which, when discarded, must be treated as hazardous wastes. Hazardous waste regulations may be triggered when company decides to reduce inventory or otherwise discards listed commercial chemical in pure form. Or by accidental spill.
If is solid waste and is on list, is "hazardous waste", no matter what. If really is innocuous, can go through "delisting petition" process where must show in this particular situation, concentrations below levels of regulatory concern.
Hazardous Waste Characteristics:
If waste not listed as hazardous, is still covered by RCRA if exhibits one of four hazardous waste characteristics:
Ignitability
Corrosivity
Reactivity
Toxicity
EPA regulations define specific tests for each. Case study questions explore some of these characteristics.
Regulatory Definition of Hazardous Waste
Mixture Rule
Must be aware of mixture rule. Mixture of listed hazardous wastes and a solid waste must also be considered hazardous waste, unless mixture qualifies for exemption
Two waste streams: One listed hazardous and one non-hazardous. Combine?
Note also exemptions only apply if hazardous waste mixed with other wastes as part of normal production or waste management process, not when intentionally mixed to achieve dilution. Such mixing constitutes treatment of hazardous waste and, as will see, requires permit.
Regulatory Definition of Hazardous Waste
Derived-From Rule
Must also be aware of derived-from rule. Waste generated from treatment, storage, or disposal of hazardous waste (e.g., ash from hazardous waste incinerator) is also hazardous waste unless exempted.
Again, delisting petition possible.
Cradle to Grave
Any persons who manages a hazardous waste (generators, transporters, and owners/operators TSD facilities) must notify EPA. Required for each site (each plant) at which hazardous waste managed.
Generators of hazardous waste
Crucial role. Failure to properly identify and initiate management hazardous waste may mean never enters cradle to grave hazardous waste program.
Generator is any person whose act or process produces hazardous waste or first causes hazardous waste to become subject to regulation.
Determine whether it is hazardous waste
Records of tests, analyses, etc.
EPA Identification Number
Uniform Hazardous Waste Manifest a control and transport document that accompanies hazardous waste at all times.
Manifest
Must specify name and EPA ID numbers each authorized transporter and TSD facility that will receive, describe waste, certify properly packaged and labeled, and sign manifest certifications.
All parties handling waste get copy, and final copy returned to generator by TSD facility. Generator must keep copy final signed manifest at least 3 years. If not received in timely manner or properly signed, generator files exception report with EPA or state, contact transporter/TSD facility to determine what happened.
On site accumulation: Generator allowed to accumulate own hazardous wastes on site without RCRA permit for storage two circumstances:
Up to 55 gallons in satellite accumulation areas at or near point of generation
Up to 90 days, provided certains standards met.
Labels very important. Identify contents, date began accumulation, etc.
Reports to EPA
Special regulations for small quantity generators, requirements different in some ways.
Transporters of Hazardous Wastes
Any person engaged in off-site transportation of hazardous waste by air, rail, highway, or water. Includes not only shippers and common carriers, but also company that occasionally transports hazardous wastes on own trucks.
Anyone who moves hazardous waste required to be manifested off the site where generated or site where being treated, stored and disposed of, is subject to transporter standards.
EPA standards closely coordinated with US DOT standards under Hazardous Materials Transportation Act for shipment hazardous materials.
EPA Identification Number
Waste must be accompanied by manifest signed by generator.
Keep manifest with waste at all times
Manifest to TSD upon delivery
TSD facilities:
Treatment facility: Facility using any method to change character or composition hazardous waste
Storage facility: Facility holding waste for temporary period
Disposal facility: Facility where intentionally placed into or on land or water, and at which waste will remain after closure.
Permit required. Must meet detailed requirements of regulations to obtain permit. Standards for specific types of TSD facilities.
Subtitle I: UST
Note: Subtitle I of RCRA required EPA to develop comprehensive regulatory program for "underground storage tank" (UST) systems
Standards for design, construction and installation new tanks
Standards for leak detection system
Standards for reporting of releases
Corrective action for confirmed releases
Closure of existing tanks.
ENV 410C - Lectures