MSECA: Hazardous Waste FAQs PRESENTED BY JOHN CRAWFORD HW ENVIRONMENTAL, LLC

Transcription

1 MSECA: Hazardous Waste FAQs PRESENTED BY JOHN CRAWFORD HW ENVIRONMENTAL, LLC

2 RCRA in Indiana 16 permitted TSDs in Indiana 11 Commercial TSDs 1 Commercial Landfill 500 LQGs 1000 SQGs

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4 Indiana Rankings Indiana is ranked # 10 in the number of LQG s. Indiana is ranked # 8 in total volume of HW generated. Indiana is ranked # 5 in total quantity shipped. Indiana is ranked # 4 in total quantity received. 4

5 How do you manage waste that is pending analysis? -Minimize sampling -Meet basic storage requirements (closed, good condition, weekly inspections) -Minimize storage time -Label

6 Waste Labels

7 DOT Labels

8 Pending Analysis -Document generation date -Document sample date -Update ASAP

9 What is the difference between DOT and EPA waste regulations? Hazardous Waste has a specific regulatory meaning Is a subset of hazardous substances (CERCLA & OSHA) Has different regulatory meaning than hazardous materials (DOT) Haz Material Haz Substance Haz Waste 9

10 DOT/EPA DOT standards apply during transport (public roads) EPA standards apply before and after transport Must comply with both Packaging, labeling, manifesting

11 Who can sign manifests? Generator or offerer Must be DOT and RCRA trained Signature has regulatory implications

12 How long can I store hazardous waste? Type CESQG Satellite container Used Oil SQG LQG TSD Universal Waste Excluded Solvent Contaminated Wipes Length Indefinite; maximum of 2200 lbs. Indefinite Indefinite 180 days 90 days 1 yr. 1 yr. 180 days

13 Tip: DO NOT DATE SATELLITE CONTAINERS

14 What are the options to treat hazardous waste? TSDs with permits Generators can treat in tanks, containers, & containment buildings if in compliance with all applicable requirements, including Subpart AA,BB,CC Recycling units are generally exempt (distillation units), but waste is regulated prior to treatment (still bottoms are also regulated). Other exemptions: elementary neutralization, WWT, TETUs Impermissible treatment: Thermal Intentional Evaporation WAP necessary if treating to meet LDR s

15 Tip: Crushing fluorescent bulbs is considered treatment, and causes the crushed bulbs to be fully regulated (i.e. it is no longer considered Universal Waste)

16 How do you manage hazardous waste contaminated with PCBs? Very carefully with lots of $ Must meet TSCA and RCRA requirements Dielectric fluid/electric equipment that are TCLP only are exempt Medical waste: must comply with RCRA regulations Radioactive Waste:??????????? See above, time to plug and chug

17 What if a generator is bankrupt/insolvent/deceased? Definite enforcement issues Seek legal advice Government perspective/options: Inability to pay Removal actions w/cost recovery Pierce corporate shields RPs CERCLA

18 What is Landban? Land Disposal Restriction Program Prohibits untreated hazardous wastes from land disposal Establishes treatment standards (40 CFR Part 268) Reduce the mobility and toxicity of hazardous constituents Establishes standards that generators and TSD s must meet

19 What is Landban? 3 Prohibitions Disposal requires adequate treatment Dilution ensures proper treatment Storage prevents indefinite storage

20 Two types of treatment standards Technology-based ( Table 1) Must use a specified technology such as CMBST or DEACT Concentration-based Must meet specified concentration limits has two categories: wastewater and nonwastewater Wastewater=Wastes that are 1% or greater by weight of total organic carbon (TOC) or total suspended solids (TSS)

21 Alternative Treatment Standards Alternative Treatment Standards address wastes that don t fit the general LDR framework Soil ( ) Debris ( ) Lab Packs ( ) Waste variances ( ) Determinations of equivalent treatment (DETs) ( (b)) Remediation waste regulations and policies

22 LDRs attach. LDRs attach at the point of waste generation, not at the point of disposal. Example :D001 solid ignitable paint filter may lose its D001 characteristic in a tub of water, but all D001 LDR rules still apply because it was D001 when it was generated Important concept; once attached, LDRs apply until treatment standards are met

23 Characteristic and Listed wastes Listed: Must meet the treatment standards (UTS, ) for regulated hazardous constituents specific to the waste (or use a specified technology) Soil must also meet underlying hazardous constituents (UHCs) Characteristic: Must remove the characteristic (or meet the specified technology for a treatment subcategory in ), and remove any underlying hazardous constituents (UHCs) (unless specifically does not require it). Listed and Characteristic- must meet the constituent standards and be treated to address that characteristic and any UHCs that are not already covered by the listing

24 Underlying Hazardous Constituents (UHCs) Must determine if UHCs present in characteristic waste chemicals on the Universal Treatment Standards Table ( ) Reasonably expected to be present at the point of generation

25 Universal Treatment Standards (UTS) Historically, EPA set treatment standards based on BDAT (best demonstrated available technology) for each waste. Unintended consequence: numeric treatment standards from BDAT could vary for different hazardous wastes (e.g. F-listed vs. U-listed) To simplify the LDR program, EPA set a single numeric value for each hazardous constituent. This is the UTS table in

26 UHC Regulated hazardous constituent UTS 250+ chemicals

27 D011 9 D002 Waste code Waste description and treatment/regulatory subcategory 1 Wastes that exhibit, or are expected to exhibit, the characteristic of toxicity for silver based on the toxicity characteristic leaching procedure (TCLP) in SW846. Corrosive Characteristic Wastes. Regulated hazardous constituent Wastewaters Nonwastewaters Common name CAS 2 number Concentration 3 in mg/l; or Technology Code 4 Silver and meet standards 8 NA NA DEACT and meet standards8 Concentration 5 in mg/kg unless noted as mg/l TCLP ; or Technology Code mg/l TCLP and meet standards 8 DEACT and meet standards U002 Acetone Acetone U003 Acetonitrile Acetonitrile CMBST

28 Generator LDR Requirements LDR Waste Determination Notification WAP Recordkeeping

29 How do you manage remediation waste? Types of Remediation Wastes Disposed wastes Media/debris contaminated by hazardous waste

30 Sources of Remediation Waste Assessment drilling waste, pumped groundwater Clean-up excavated wastes and soils, dredged sediments, abandoned drums, debris, and recovered groundwater Long-term operation and monitoring (O&M) treatment residues, spent filters

31 Options for Managing Hazardous Remediation Wastes Area of Contamination (AOC) Policy Special units created for management of remediation wastes Corrective Action Management Units (CAMUs) Staging Piles Temporary Units (TUs) SQG/LQG generator standards

32 Area of Contamination Policy Discrete area of generally dispersed contamination (e.g. large contiguous area of soil contamination) May include old waste disposal units If contamination is in non-contiguous areas, multiple areas of contamination may be used Movement or in situ treatment within area of contamination does not trigger LDRs and other Subtitle C requirements as long as waste is not placed in containers, tanks or other units. Permit not required, but boundaries of AOC must be established, and it is highly recommended to coordinate with IDEM

33 CAMU Provides flexibility for eligible waste Permit/authorization required Disposal CAMU: Minimum design requirements - cap, liner, leachate collection Treatment of Principle Hazardous Constituents Treatment and storage CAMU: Flexible design requirements; same as staging piles May be limited to 2.5 years of operation

34 Differences Between Areas of Contamination and CAMUs Area of Contamination Permit/authorization not required Located only in area with contiguous contamination Consolidation only allowed within area of contamination In situ treatment allowed CAMU Permit/authorization required Located in contaminated areas, uncontaminated areas, and off-site Consolidation allowed from areas inside or outside CAMU In situ or ex situ treatment allowed

35 Staging Piles Temporary storage of solid, non-flowing remediation waste Mixing, sizing, blending, or other physical operations allowed, but not treatment Site-specific design/performance standards Limited to 2 years of operation Permit/authorization required

36 Temporary Units (TUs) Non-land-based unit Temporary tank Temporary container storage area Design standards may be Part 264 or 265 requirements for tanks and containers or alternative site-specific standards. Limited to 1 year of operation Permit/authorization required

37 Alternative LDR Treatment Standards Contaminated soil 90% reduction in hazardous constituents, capped at 10 times Universal Treatment Standards (UTS) Example: F005 toluene Standard LDR, UTS = 10 ppm Contamination at 200 ppm 90% reduction = 20 ppm Cap= 10 x UTS= 100 ppm Final LDR level= 100 ppm

38 Hazardous debris Hazardous debris Specified technologies (extraction, destruction, immobilization) Debris treated by extraction or destruction technologies is generally not subject to further RCRA

39 Thanks! John Crawford Founder, Senior Project Manager HW Environmental LLC Hwenviro.com