Search

RCRA—Waste Treatment/Minimization

Posted on 3/26/2013 by Won Bae

A HazCom rule change has been announced that will affect labeling of all hazardous materials packages.  The new rule makes an important adjustment to new requirements OSHA adopted last year, known as the Globally Harmonized System (GHS) of classifying and labeling chemicals.
 
The rule in question pertains to DOT and HCS labels on the same package. The regulation (29 CFR 1910.1200, C.2.3.3) currently reads:
 
“Where a pictogram required by the Department of Transportation under Title 49 of the Code of Federal Regulations appears on a shipped container, the pictogram specified in C.4 for the same hazard shall not appear.”
 
OSHA now plans to revise this rule to allow both a DOT and HCS pictogram for the same hazard to appear on a package, and will not enforce the current prohibition in the meantime. Because the U.S. DOT does not view Hazard Communication pictograms as conflicting with DOT labeling requirements; and because for some international shipments both pictograms may be needed, OSHA has decided to lift the prohibition at 1910.1200 C.2.3.3.
 
The planned change was announced in an OSHA Brief released last week. You can view the full brief here.
 
 
There are many ways to use RCRA reliefs to cut costs at your facility. You can reuse spent materials, turn your waste into someone else’s product; recycle scrap metals, circuit boards, ethanol, cathode ray tubes, used oil, batteries, and other universal wastes; reclaim value from sludges and by-products; neutralize corrosive wastes; install a closed-loop reclamation system; or decharacterize or solidify wastes in process-units. Of these options, one of the most widely used is elementary neutralization of corrosive waste.
 
The Advantages of Elementary Neutralization
 
One common, and bulky, type of hazardous waste generated in many industries is liquid solutions that exhibit the hazardous characteristic of corrosivity. These corrosives may be by-products of chemical reactions, spent catalysts, sludges from wastewater treatment systems, or simply industrial cleansers.
 
Hazardous Waste Recycling Reliefs Banner
 
Under certain conditions, you can treat this type of hazardous waste yourself, without a permit. This process is called “elementary neutralization.” [40 CFR 260.10] Taking care of your own hazardous waste has many advantages:
 
  • 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.
 
What Kinds of Wastes Qualify?
 
Elementary neutralization can be applied to hazardous wastes that 1) exhibit the hazardous waste characteristic of corrosivity defined at 40 CFR 261.22, 2) do not exhibit any other characteristics, and 3) are not listed as hazardous waste at 40 CFR 261, Subpart D. While this description is very specific, this type of waste is generated by many kinds of facilities, typically in large amounts.
 
How Does the Treatment Work?
 
  • 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.
 
What Else Do I Have to Do?
 
  • 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)]
Operating an elementary neutralization unit (ENU) isn’t easy, and it isn’t the right solution for everyone. But if your facility generates large quantities of corrosive wastewaters, then setting up an ENU can minimize your waste generation, cutting your shipping costs and treatment fees, and possibly reduce your generator status.
 
Learn how to gain efficiencies and streamline your waste management operations at Lion Technology’s Advanced Hazardous Waste Management Workshop
 

Tags: hazardous, RCRA, treatment, waste, waste minimization

Find a Post

Compliance Archives

Lion - Quotes

The workshop covered a lot of information without being too overwhelming. Lion is much better, more comprehensive than other training providers.

George Alva

Manufacturing Manager

The course was very informative and presented in a way that was easily understood and remembered. I would recommend this course.

Jeffrey Tierno

Hazmat Shipping Professional

Excellent. I learned more in two days with Lion than at a 5-day program I took with another provider.

Francisco Gallardo

HES Technician

Best course instructor I've ever had. Funny, relatable, engaging; made it interesting and challenged us as the professionals we are.

Amanda Schwartz

Environmental Coordinator

Very witty instructor, made the long times sitting bearable. One of the few training courses I can say I actually enjoyed.

John Hutchinson

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!

Chelsea Minguela

Hazmat Shipping Professional

The instructor was very patient and engaging - willing to answer and help explain subject matter.

Misty Filipp

Material Control Superintendent

As always, Lion never disappoints

Paul Resley

Environmental Coordinator

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!

Diana Joyner

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.

Donnie James

Quality Manager

Download Our Latest Whitepaper

A guide to developing standard operating procedures, or SOPs, that help you select, manage, and audit your hazmat agents and contractors.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.