Treatment Standards for Hazardous Waste Debris

Posted on 4/28/2015 by Anthony Cardno

Treating RCRA Waste Before Disposal

In the RCRA "cradle-to-grave" management system for hazardous waste, the "grave" refers to one of three options: useful recycling, diversion to wastewater treatment discharge, or permanent disposal in a landfill or via incinerator. To dispose of hazardous waste in a landfill, generators must first ensure the waste is treated to reduce the concentration and mobility of hazardous constituents. The rules for treating hazardous waste to acceptable levels before disposal are known as land disposal restrictions (LDRs) and can be found at 40 CFR Part 268.

Treatment to LDR standards can be expensive, and treatment storage and disposal facilities (TSDFs) charge by weight: The heavier the waste that needs treatment, the higher the price tag. This raises potential problems for generators, especially when the waste stream being disposed of is not just hazardous waste, but debris contaminated with hazardous waste. Contaminated debris like scrap metal or plant matter can be much, much heavier than traditional wastes, and thus is more expensive to treat and dispose of. To help generators with this challenge, EPA sets certain alternative LDR treatment standards for debris.

What Is Debris Under RCRA?
At 40 CFR 268.2(g), EPA defines debris as any solid material that: What is contaminated debris under RCRA?
  1. Has a particle size exceeding 60 mm;
  2. Is intended for disposal; and
  3. Is either:
    1. A manufactured object (scrap metal, concrete, glass, lumber, etc.);
    2. Plant or animal matter (tree stumps, animal carcasses); or
    3. Natural geologic material (boulders, rocks).
It does not include:
  • Materials with a particle size 60 mm (2.4 inch) or less; or
  • Materials with specific treatment standards at 40 CFR 268, Subpart D (lead-acid batteries, cadmium batteries, radioactive lead solids); or
  • Process residuals such as smelter slag; or
  • Residues from the treatment of waste, wastewater, sludges, or air emission residues; or
  • Intact containers of hazardous waste that are not ruptured and retain at least 75% of their original volume.
How Does Debris Become Subject to the LDRs?

Debris that is not contaminated with hazardous waste is not subject to the LDRs. Under EPA's mixture rule [40 CFR 261.3(a)(2)(iv)], however, any mixture of a listed solid waste (any solid, semi-solid, liquid, or contained gaseous material intended for disposal) with any hazardous waste must be managed as a hazardous waste. Therefore, any item meeting the definition of "debris" described above must be regulated as hazardous waste if it becomes contaminated with hazardous waste. All hazardous waste must be treated to meet the LDR standards before disposal.

Alternative LDRs for Contaminated Debris

RCRA regulations lay out three options for treatment of hazardous debris.

First, the debris can be treated to the specific LDR standard that applies to the waste the debris is contaminated with. This is not always practical due to the way the standards are written and the fact that physically solid debris is often heavier and more expensive to dispose of.

Second, generators can manage debris in accordance with the EPA's "contained-in" policy. The "contained-in" policy basically says the debris must be managed as hazardous waste until you get the hazardous waste cleaned off or out of it. Because generators must prove to the EPA's (or the authorized State agency's) satisfaction that the debris no longer contains hazardous waste, this option is also often not practical or cost-effective.

Third, EPA allows debris to be treated and disposed of under alternative LDR standards described at 40 CFR 268.45. These alternate standards allow for various methods of:
  • Immobilizing the contaminated debris (macroencapsulation, microencapsulation, sealing);
  • Destroying the contaminated debris (biodegradation, chemical oxidation, thermal destruction); or
  • Extracting the hazardous waste from the debris (abrasive blasting, vibratory finishing, liquid phase solvent extraction, high-temperature metals recovery, and others).
The full list of extraction, destruction, and immobilization options can be found at 40 CFR 268.45, Table 1 and may be limited, depending on the combination of debris types and hazardous waste contaminants. For example, chemical oxidation is not an acceptable method of treatment if the debris is contaminated with metal constituents.


Generator's Responsibility

Ultimately, it is the responsibility of the initial generator of the hazardous waste to determine the appropriate LDR treatment standards for the waste. This is true even when the waste stream in question is debris contaminated with hazardous waste.

Gain More Clarity on LDR Standards

Managing compliance with the RCRA land disposal restrictions is a complex, expensive part of generating hazardous waste. Knowing how to navigate these rules will help you simplify this process and be confident that you're not overpaying for needless or redundant treatment of your waste. Sign up for the Land Disposal Restrictions online course and build a plan for disposing of your site's waste that protects both the environment and your company's bottom line.


Tags: hazardous, LDR, RCRA, waste

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