- Reduce your generator status. Wastewaters are measured in gallons, but generator status is measured in pounds. Every gallon of corrosive wastewater you can exclude from regulation as hazardous waste equals about 8 pounds you can subtract from your monthly totals. Since wastewaters are typically generated in large amounts, on-site treatment can leverage great waste minimization gains.
- Reduce your freight costs. If you’re currently shipping large volumes of corrosive wastewater to an off-site treatment facility, you’re paying freight costs to transport the waste AND treatment costs to neutralize it. By treating the waste on site, you can save on shipping costs.
- Neutralization is cheap. After any on-site storage, as well as recordkeeping and other administrative expenses (which you’re already doing for the waste), the only additional expense for an elementary neutralization operation is a small amount of common industrial caustic.
- Accumulate the waste in a tank, tank system, or container.
- Transport vehicles and vessels are also authorized, but their use can create complications.
- As long as you “immediately manage” the waste in an elementary neutralization unit, you don’t have to count it towards your generator status. [40 CFR 261.5(c)(2)]
- Depending on your setup, you may even be able to skip this step (treatment in “process unit”). [40 CFR 261.4(c)]
- Add base/acid to the waste to raise/lower the pH above 2 or below 12.5 to reach a neutral pH.
- Dispose of the decharacterized water.
- Check the laws, regulations, and policies of the hazardous waste management authorities in your state. Not every jurisdiction authorizes this activity, and some that do will impose additional restrictions or requirements.
- If you intend on discharging the neutralized wastewater to a municipal sewer, you must get permission from the waterworks.
- If you intend on discharging the neutralized wastewater to surface or underground waters, you must have an NPDES permit from the U.S. EPA.
- Keep records of the amount and type of waste you generated and treated to rebut any presumptions of speculative accumulation or sham recycling.
- File a One-Time Notice in your facility’s Land Disposal Restrictions records. [40 CFR 268.7(a)(7)]
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The workshop covered a lot of information without being too overwhelming. Lion is much better, more comprehensive than other training providers.
The course was very informative and presented in a way that was easily understood and remembered. I would recommend this course.
Hazmat Shipping Professional
Excellent. I learned more in two days with Lion than at a 5-day program I took with another provider.
Best course instructor I've ever had. Funny, relatable, engaging; made it interesting and challenged us as the professionals we are.
Very witty instructor, made the long times sitting bearable. One of the few training courses I can say I actually enjoyed.
Senior EHS Engineer
The instructor kept the class engaged and made learning fun. There was a lot of information to cover but time flew by. I will definitely use Lion in the future!
Hazmat Shipping Professional
The instructor was very patient and engaging - willing to answer and help explain subject matter.
Material Control Superintendent
As always, Lion never disappoints
I was able to present my scenario to the instructor and worked thru the regulations together. In the past, I attended another training firm's classes. Now, I have no intention of leaving Lion!
Senior Environmental Engineer
The training was impressive. I am not a fan of online training but this was put together very well. I would recommend Lion to others.
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