Hazardous Waste: The Part of Hazmat Response We Usually Do Not Talk About

In the arena of hazardous materials response, there is one topic that we usually mention in either hushed tones or not even at all  image

—hazardous waste. While hazardous waste does not generally have the allure of, nor receive as much attention as other hazardous materials in our world of response, we need to be familiar with the specifics of hazardous waste storage, management, and transportation as we are apt to encounter such materials at fixed facilities, in transportation, or at treatment storage and disposal facilities (TSDFs).

The overarching regulatory influence in terms of hazardous wastes is the Resource Conservation and Recovery Act (RCRA). RCRA covers the “cradle to the grave” management of solid wastes and hazardous wastes; and was promulgated in 1976. Whereas in hazardous materials response we are usually focused on the Department of Transportation (DOT) definition of hazardous materials — “materials capable of posing an unreasonable risk to health, safety, and property when transported in commerce” — in the hazardous waste discipline we need to look at the definitions of solid and hazardous wastes.

A solid waste is defined as “any garbage or refuse, sludge from a wastewater treatment plant, water supply treatment plant, or air pollution control facility and other discarded material, resulting from industrial, commercial, mining and agricultural operations and from community activities.” A solid waste is also considered to be “any material that is discarded by being abandoned, inherently waste-like, discarded military munitions, or recycled in certain ways” — with some exclusions. It is ironic that solid wastes also do not have to be in solid form, as they can also be in liquid, semi-solid or contained gaseous material states. Hazardous wastes are defined as “RCRA solid wastes that are characteristic wastes (ignitable, corrosive, reactive, or toxic) or listed hazardous wastes on what are termed the F, K, P or U lists.”

There are specific types of characteristic and listed wastes as defined in the Hazardous Waste Regulations promulgated by the Environmental Protection Agency (EPA) in 40 CFR 260 – 279. Hazardous wastes exhibiting the characteristic of ignitability are assigned the hazardous waste code D001 and consist of liquids with a flashpoint of less than 1400F, non-liquids capable at standard temperature and pressure of causing fire, ignitable compressed gases and oxidizers. An example of a D001 waste would be gasoline. Corrosive hazardous wastes are termed D002 wastes and are defined as having an aqueous pH of 2 or less or 12.5 and above; and liquids that corrode SAE 1020 steel at the rate of greater than one quarter inch per year at 1300F. Sulfuric acid is a representative D002 waste. D003 hazardous wastes exhibit the characteristic of reactivity and are defined as those wastes which are normally unstable and readily undergo violent change without detonating; those that form potentially explosive mixtures with water, and those generating toxic vapors or fumes when mixed with water, among others. Wastes such as organic peroxides exemplify the D003 characterization.

The final characteristic hazardous waste category is that of toxicity. Such wastes are given the hazardous waste codes of D004 through D043 and are defined as those wastes with constituents produced by extraction through the toxicity characteristic leaching procedure (TCLP) meeting or exceeding concentrations specified in 40 CFR 261.24. An example of such a waste is one which produces arsenic under extraction at concentrations equal to or greater than 5.0 mg/L (designated D004). Just to muddy the waters the EPA also assigns hazard codes (which are different than the DXXX hazardous waste codes previously mentioned) to both characteristic and listed wastes, as follows:

I – Ignitable Waste

C – Corrosive Waste

R – Reactive Waste

E – Toxic Waste (Based on the TCLP)

H – Acute Hazardous Waste

T – Toxic Waste (Based on the Presence of Toxic or Hazardous Constituents)

Following the coverage above of the characteristic wastes, let us discuss the listed wastes.

F Listed wastes emanate from non-specific sources and consist of wastes such as spent solvents.

K Listed wastes are generated from specific sources and are assigned one of 120 K Codes over the 17 industrial (manufacturing) types of waste on the K List. An example of a K Listed waste is spent potliners from primary aluminum reduction.

P and U Listed wastes consist of unused commercial chemical products and residues, with P Listed wastes (P028 Benzyl chloride for example) being considered acutely hazardous unused commercial chemical products and U Listed wastes (U204 Selenious acid for example) being considered toxic unused commercial chemical products.

In terms of the generators of hazardous wastes, the EPA designates three separate categories.

Very Small Quantity Generators (VSQGs) were formerly termed Conditionally Exempt Small Quantity Generators and generate less than or equal to 220 pounds of non-acute hazardous wastes, 2.2 pounds of acute hazardous wastes, and 220 pounds of any residue, contaminated soil, etc. per calendar month.

Small Quantity Generators (SQGs) generate greater than 220 pounds but less than 2200 l pounds. of non-acute hazardous waste; and less than or equal to 2.2 pounds of acute hazardous wastes and 220 pounds of any residue, contaminated soil, etc. per calendar month.

Large Quantity Generators (LQGs) generate greater than or equal to 2200 pounds. of non-acute hazardous wastes, greater than 2.2 pounds of acute hazardous wastes, or greater than 220 pounds of any residue, contaminated soil, etc. per calendar month.

Both SQGs and LQGs are required to generate hazardous waste manifests — similar to shipping papers for hazardous materials — for the transport of hazardous wastes. Hazardous waste manifests are signed by the generator, the transporter, and the designated facility and the generator is required to keep the original copy and the copy returned by the designated facility denoting receipt of the hazardous waste for a period of three years. The manifest itself is required to contain information regarding the generator, the name of the transporter or transporters; appropriate EPA Identification Numbers, and the designated facility the waste is being shipped to.

The manifest also contains various columns of information. An “X” is placed in column 9a if the waste is also a hazardous material. Column 9b contains the basic description of the waste — including the UN Number, proper shipping name, DOT Hazard Class, and packing group. The number of containers and their type are listed in column 10, with fiberboard drums coded “DF” and metal drums coded “DM.” The total quantity is listed in column 11 and the unit of weight/volume is listed in column 12, with “P” signifying pounds and “G” signifying gallons. The hazardous waste code or codes is then entered in column 13.

A certification statement specified by the EPA is required to be present on the manifest, as well as the printed or typed names and signatures of the generator, transporter(s), and the designated facility the waste is being shipped to.

Specific requirements also exist for the marking and labeling of hazardous wastes. Hazardous wastes being accumulated by an SQG or LQG are required to be marked with the words “Hazardous Waste” and are required to have the DOT Hazard Label and the start date of accumulation affixed. Prior to the transport of or offering of hazardous waste for transportation off site, the waste is also required to be marked with the address of the generator, the appropriate EPA Identification Number, UN Number, proper shipping name, hazardous waste code or codes, manifest tracking number, and the exact statement “IF FOUND, CONTACT THE NEAREST POLICE OR PUBLIC SAFETY AUTHORITY OR THE U.S. ENVIRONMENTAL PROTECTION AGENCY.” Shipments are also required to be marked, labeled and placarded as per the applicable DOT Hazardous Materials Regulations.

The final discussion on hazardous waste includes the area of preparedness and prevention measures that are required. LQGs are required to develop contingency plans that are designed to minimize the hazards to human health or the environment during emergencies.

In addition, both SQGs and LQGs are required to try to plan with local authorities, emergency response contractors, hospitals, local emergency planning committees, and others as appropriate including making responders familiar with the facility and hazards presented; and designating a primary response authority and supporting agencies.

SQGs and LQGs are also required to designate an Emergency Coordinator who is responsible for the coordination of any emergencies that arise. In terms of storage, LQGs are also required to store ignitable or reactive waste in containers at least 50 feet from the property line. Exemptions are allowed if the local fire department having jurisdiction approves and the approval is recorded.

Although the topic of hazardous waste does not usually rise to the top of our most favorite subjects to discuss in the world of hazardous materials response, we should be thoroughly familiar with the hazardous waste regulations set forth by the EPA as we are likely to encounter hazardous wastes in transportation or at fixed facilities during our career.

As always, stay safe out there and be sure to visit the North Carolina Association of Hazardous Materials Responders website at www.nchazmat.com.

Glenn Clapp is a past president of the North Carolina Association of Hazardous Materials Responders and has over 23 years of fire service and emergency management experience. He is currently an Improvement Specialist with the Industry Expansion Solutions Division of North Carolina State University and is a volunteer firefighter with the Fairview Fire Department. He is also a Technician-Level Hazmat Instructor, an Executive Fire Officer, a Certified Hazardous Materials Manager and a Certified Fire Protection Specialist.

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