Authored by Angie Martin, PE, CHMM

EPA’s e-Manifest processing facility received over 1.5 million manifests from the launch of the system on June 30, 2018 through April 30, 2019. On an annualized basis, this number falls 880,000 manifests short of the projected number of manifests initially used to calculate EPA’s e-Manifest fees. The regulations require EPA to recalculate fees which are effective October 1, 2019 and every 2 years thereafter. EPA has increased fees for different types of manifest submissions from 60% to 115%. These fees are charged directly to the destination facilities. As such, Heritage is adjusting our e-Manifest fee to $25 per manifest, effective with shipments originating on October 1.

As noted below, EPA’s analysis indicated that a very low percentage of manifests have been submitted using fully electronic options (<0.3%).  This is due to a wide variety of factors (user registration, continuing software changes, technical restrictions, logistical challenges, etc.) and was the primary topic of the recent Advisory Board meeting.  EPA also has a backlog of approximately 100,000 paper manifests to process and about 270,000 data plus image manifests to process. 

At this time, Heritage submits manifests to EPA using the same two most widely used options indicated below (scanned image and data plus image). 

Manifest Submission Type Submitted (6/30/18 – 4/30/19) %
Mailed paper manifest 103,348 6.8%
Scanned image upload 272,627 18%
Data plus image 1,140,003 75%
Fully electronic 4,005 <0.3%

Source: EPA, “Hazardous Waste e-Manifest Advisory Board June 2019 Meeting Background Whitepaper.”


Heritage is committed to safely and compliantly transporting, managing, and disposing of our customers’ waste.  We will continue to follow the EPA’s progress on e-Manifest programming and implementation and to update our customers on the progress.  EPA will recalculate fees in 2021, effective October 2021.

On July 17th, 2019, Angie Martin, our Vice President, attended the Missouri Waste Control Coalition Conference to give a presentation that addressed the health concerns, legislation, and treatment options associated with Per- and polyfluoroalkyl substances (PFAS). PFAS are a persistent group of manufactured chemicals used in water and stain repellents, nonstick coatings, cleaning products, firefighting foams, and more.

Environmental issues and health concerns have been linked to PFAS, calling for Congress to draft legislation pertaining to PFAS waste stream management and disposal. Many amendments regarding PFAS have been added to the National Defense Authorization Act, and the House Energy and Commerce Committee is currently reviewing a plethora of PFAS bills.

There are a variety of treatment options available for PFAS. However, the different chemical and physical properties of the thousands of PFAS species make selecting a treatment option challenging. With talk of the negative implications of PFAS on human health and the environment on the rise, Angie discussed possible treatment options and their effectiveness, including separation, transformation, disposal, and destruction.

SEPARATION technologies such as granular activated carbon, ion resin exchange, membrane filtration, and precipitation concentrate PFAS out of contaminated water. While these methods can be quite effective in removing PFAS from water, the PFAS is still existent. It has just been transferred to a membrane, resin, or PFAS-rich sludge, and must now be treated further.

TRANSFORMATION through oxidation or biodegradation is another treatment option. When oxidized, the carbon-carbon or carbon-oxygen bonds in PFAS are more easily broken than the persistent carbon-fluorine bond. Breaking the carbon-carbon backbone of longer PFAS molecules without breaking the carbon-fluorine bonds simply creates a greater number shorter PFAS molecules. Biodegradation is similar; biodegradation pathways for PFAS precursors lead to PFAS species of regulatory concern. Even though these methods do have their positives, such as a lack of PFAS waste being generated, they are ultimately ineffective.

DISPOSAL in a landfill is another largely ineffective method for PFAS treatment. Many are landfilling PFAS waste from separation processes. However, due to the solubility and mobility of some PFAS molecules, PFAS can easily escape the landfills in leachate and be reintroduced to the environment.

DESTRUCTION using the extreme heat of incineration breaks the carbon-fluorine bonds characteristic of PFAS. Incineration is the only commercially available technology with the capacity to address the PFAS problem, avoid liability, minimize human health concerns, and abate the environmental persistence of PFAS. Destruction is Heritage’s only management method provided to customers with PFAS waste.

If you have any questions regarding PFAS or treatment options offered by Heritage Environmental Services, please reach out to your account representative, or contact Angie Martin at angie.martin@heritage-enviro.com.

With its ongoing importance, we want to update and inform on this old topic! Local, state and federal environmental agencies use the inspection process to verify that hazardous waste generators are following the rules. Over the last number of years, and with the implementation of the Generator Improvement Rules, we have a better understanding of what rules are consistently looked at, and can result in citations and fines if not followed. Below you will find rule violations and how to avoid them.

 Failure to Make a Waste Determination

Avoid this by:

  • Make a determination on all waste generated on-site.
  • Treat unknown material as a hazardous waste during the determination process (label, close, date, etc.)
  • Keep necessary documentation for both hazardous and non-hazardous waste.

Knowing what you generate and if it is hazardous will help you make the determination as to what size generator you are, and what rules you need to follow…as well as ensuring that you aren’t improperly disposing of hazardous waste as non-hazardous and creating liability issues for your company.

 

 Adequate Aisle Space

Avoid this by:

  • Ensuring that you can get to all of your containers in your 90/180 accumulation area
  • Ensuring that if a container has an issue, emergency responders can get to that container
  • Ensure that incompatibles are separated in some way (dike, berm, wall) to reduce risk of fire, release, explosion

The regulations do not indicate a specific distance for adequate aisle space. Check state regulations for any state guidelines, or even fire marshal guidance.

 

 

Failure to Perform Weekly Inspections of Hazardous Waste Storage Areas

Avoid this by:

  • Perform the inspections on the same day every week
  • Mondays and Fridays are not a good choice
  • Have a back-up inspector
  • Document inspections on an inspection log

Make sure that your employees aren’t just documenting what issues they found, but also how the either mitigated them at that time, or if the issue was mitigated at a late      time, how and when. Under the Generator Improvement Rules, remember that weekly inspections must now be completed “at least weekly” and must specifically look for containers that are leaking AND containers that have deteriorated due to corrosion.

 

 

 Contingency Planning Violations

Avoid this by:

  • Designate an emergency coordinator
  • Keep information up to date and on-site
  • Ensure all required elements are included
  • For LQG’s, document submittals to local authorities

Do you know your capabilities? Do you know your local emergency responder’s capabilities for large release mitigation? Have you considered contracting with Heritage for your emergency response if you or your local responders aren’t able to mitigate large emergencies or decontamination’s?

 

 

Marking and Labeling of Containers

Either with “hazardous waste” OR Words describing the container contents

Avoid this by:

  • Review and understand the definition of a satellite accumulation area
  • Label your container once the first drop of hazardous waste is added to the container.

The GIR requires the words “Hazardous Waste” as well as an indication of the hazard (DOT diamond, GHS pictogram, etc.) in both satellite and central accumulation areas. Proper marking of containers will reduce the mixing of incompatible wastes, and potentially and emergency situation.

 

 

Separate incompatibles

Avoid this by:

  • Appropriately marking and labeling your containers
  • Training your employees about certain incompatibles (acids and caustics in the same container) based on waste determinations
  • Not placing materials in an unwashed container

The more you know about the wastes you have, the better prepared you are for reducing the risk of fires, releases or explosions.

 

 

Training

Avoid this by:

  • Knowing what your training requirements are based on your generator status
  • Documenting when you received your training
  • Documenting what training you are providing your employees based on their job responsibilities

LQGs are required to have training annually, have a written training plan and that employees are training within 6 months of being hired to work in the company’s hazardous waste program. SQG employers need to show that the employees understand the rules based on their performance (i.e., do they know the rules and how they apply to the job).

 

 

Open Container Violations

Avoid this by:

  •  Rule of Thumb- if the contents would spill if the container was overturned, then the container is considered open
  • Close and latch funnels; screw in bungs; use drum rings and tighten bolts
  • Train employees to close containers when not adding or removing waste

Satellite and central accumulations area containers, as well as those for used oil, contaminated wipes, universal wastes, must be kept closed unless adding or removing material from the container. Are you ensuring that your containers are adequately closed?

 

 

Storage Area Accumulation Date Violations

Avoid this by:

  • Once 55 gallons of hazardous waste or 1 quart of acute hazardous waste is exceeded at the satellite accumulation area, storage area dating requirements apply after three days.
  • Make sure all containers of hazardous waste in storage are marked with waste accumulation dates during weekly inspections.

 

 

90/180-day violations

Avoid this by:

  • Knowing what hazardous waste you generate and how much you generate in a given month
  • Notify your state EPA office that you are a hazardous waste generate
  • Know the rules that apply based on your generator status

This really captures all of the responsibilities you have as a generator in one major category. If you don’t do waste determinations, you don’t know what hazardous waste you generate and what size generator you are. From there, you may not know how long you are allowed to store hazardous waste on site, and when it needs to be transported for disposal. This could lead to storage violations, and a host of other violations based on how the rules apply to you, and if you follow them.

 

All businesses generate waste, and in some cases, it could simply be wastewater or paper waste. In others, it could also be hazardous and toxic wastes. In all aspects, it is going to cost money to properly manage the wastes a facility creates.  So naturally businesses want to minimize their waste to manage costs – and protect the earth from pollution.  Doing so may be as simple as implementing two-sided printing or using email rather than printed paper for those small businesses. However, when you operate a large industrial or manufacturing facility, minimizing waste can be more complicated.

How to Prevent Waste

When waste is thrown away, it needs to be handled, treated and disposed of properly. If facilities throw less waste away, these handling, treating and disposal processes can be reduced. Prevention can include:

  • Implementing in-process recycling
  • Purchasing durable and long-lasting materials
  • Conserving water and energy
  • Efforts to eliminate raw materials that are not included in the final product
  • Reducing packaging materials
  • Using non-toxic materials

Why is Pollution Prevention Important?

Pollution prevention helps with the financial costs of waste cleanup and management, along with environmental regulatory compliance costs. If a facility strives toward pollution prevention, it will help the environment by protecting and conserving natural resources. Through pollution prevention and protecting the environment, a facility will strengthen its economic growth and can make its production more efficient.

How to Get Started

For a facility to start making pollution prevention a priority, there needs to be the reminder to start small. When a facility is determining what materials to reduce, try targeting one or two materials and move from there. In this process, start with ideas that may require minimal capital investment and involve all employees in the planning and implementation of these ideas. When starting this process, there need to be steps to follow. Initially there needs to be a determination of what wastes the facility generates. Once those wastes are determined, waste prevention measures then need to be identified. The next step will be to set the facilities priorities and goals. Lastly, the facility will hit the ground running and get started on achieving these goals. Goals are best achieved by getting all facility employees involved, and teaching them the personal and global benefits from participating. Most importantly, the policies and goals should be described to employees in an easy-to-understand way that gives them the control to change how they handle materials.

Recently we had the opportunity to take a behind the scenes look at exactly what our onsite personnel do at Northwestern University. We got to talk to the Executive Director for the Office for Research Safety, Michael Blayney, and Heritage’s Technical Services Manager, Breanna Zamorski. Michael talked to us about what Northwestern wanted to accomplish by bringing a supplier and their personnel onsite to perform waste services. He specifically talked about what they were searching for and the benefits the Heritage onsite personnel could provide. Breanna talked to us about our Heritage team onsite at Northwestern and all the duties our team helps with each and every day.

What Were They Looking For?
Determining they needed outside help was recognizing challenges and understanding the necessity of resetting the clock. Picking a team to come in, clean up, reorganize, offer improved services and lower the barriers to help people do the right thing was very important for Northwestern. They wanted a team who paid careful attention to the details. In Heritage, Northwestern found a willingness to look at questions, work to understand those questions, and then respond to those questions. This gave them confidence and understanding that Heritage was going to be an excellent partner to work with.

About the Team
Northwestern currently has 6 Heritage employees on site, 4 at their Evanston campus and 2 at their Chicago campus. As a Heritage onsite personnel team member, they deal with many different duties. Our onsite team works with some unusual materials like, radioactive and biohazardous waste. This is not typical for Heritage onsite services and it is a great experience being able to pioneer new knowledge with these unique materials.

Onsite Duties on Campus
Heritage onsite employees perform varies tasks on a daily basis including:

  • Manage waste program including hazardous, biohazardous and radioactive wastes
  • Perform waste determinations and set up needed waste streams
  • Provide excellent customer service
  • Do waste pickups throughout the University
  • Pack or bulk all chemicals
  • Handle all shipments
    • Scheduling
    • Packaging
    • Paperwork/signing paperwork
    • Loading the truck
  • Perform inspections in our area and throughout campus for compliance
  • Provide RCRA and waste guidance to Northwestern staff and students
  • Provide regulatory training for facilities staff
  • Decontamination and cleaning of various lab spaces and facilities spaces
  • Emergency response
  • Process incoming radioactive material packages

Ultimate Goal
The ultimate goal of our onsite personnel is to be a hands-on help to the customer, and in this case: Northwestern University. Our Heritage team wants to make sure they dispose of the University’s waste safely and properly. They also want to be able to educate students and staff the best ways to handle, manage, and dispose of their wastes.

Take Away
While visiting our onsite team at Northwestern, there were so many things to learn. Being on campus at such a large university, our team plays an important role in program consistency and environmental compliance. Northwestern’s campus stretches across 240 acres with approximately 150 buildings. To learn more about our onsite personnel, check out our first episode of Behind the Swirl. If you are ready to bring in our onsite team, Contact Us today to get started!

Going digital can save you time, improve visibility and help you stay up to date. Heritage has developed a tool to help meet the needs of customers by putting data at their fingertips. The Heritage Environmental Informational System (EIS) offers complete transparency into exactly when and where your waste is in its process. For Heritage customers they have the ability to view everything, down to the smallest detail.

Save Time
Is it important to get your information in a quick and timely manner? With an electronic system, you have the opportunity to view your paperwork via the computer, rather than waiting for documents to be sent through the mail. The Heritage EIS system can expedite many processes, including:

  • Completing, filing and updating documents
  • Finding a manifest copy
  • Downloading a copy of an invoice
  • Placing an order
  • Electronic profiling
  • Viewing your pricing
  • Running a shipping history (Biennial) report

All the features of EIS are faster than requesting the information from your Account Coordinator or Corporate Account Coordinator. The time it takes for you to utilize these features in EIS is much faster and you can access this information immediately, rather than waiting for your Heritage AC/CAC to do the same and respond via email.

Improve Visibility
As a customer, you want to access your information and paperwork whenever you need it. With an electronic system, you have the ability to search for every document the supplier you work with has on file easily. If you need to access a certain document, or print off copies of documents, you are able to do so without having to contact someone. It gives you an easy and in-depth view into all your information. With Heritage’s EIS system, you have the power to view your data wherever and whenever you need it.

Stay Up To Date
When a supplier offers an electronic system, it gives you the power to customize your account preferences. You can go in and adjust account settings to control the email updates you receive, mailing lists or other informational messages. This keeps you included in any important information that may affect new programs, rules, regulations or other things that can change the way you operate. EIS eases the access by message subscriptions, so you can adjust your account settings to opt into automated emails. This would include getting manifest copies, invoice copies, route notification emails, recertification notifications and electronic statements. Subscribing to these messages allows the emails to come to you automatically with attachments or links that take you directly into EIS. Specifically, the manifests and invoice messages save you time from having to go into EIS and search for those documents. They are emailed directly once those items are available.

Ready To Get Started?

If you are interested in the benefits of going digital, contact us today and let our team show you the benefits of EIS.

Heritage is proud to announce the launch of its new blog site. We are transitioning from a third-party blog host, to directly placing our blogs in our public website. The content and other resources that the site offers should help to engage visitors and educate them on the various ways in which Heritage conducts itself as a steward of the environment.

One of the biggest improvements to the blog site is the ease with which a visitor is able to navigate throughout the pages. Any user should be able to get anywhere in the site with only a few clicks. You can find our blogs by category, by date, or search for any topic. You will even see suggested similar articles below an opened blog post you are reading.

We are excited to bring our blog over to the Heritage website, and we hope that visitors enjoy the easy navigation throughout. If you subscribe to the blog, you will be notified by e-mail when a new blog is released. We also want to hear from YOU! Just use our web chat or contact us form to suggest blog topics that interest you. Submit a suggestion and watch for your topic to be featured on our blog site!

We first distributed this blog in November of 2014, but it has continued to be helpful and useful and wanted to share it with you again! Hazardous waste generators are under constant scrutiny to avoid violating regulations set by RCRA as well as national and state government. In order to help you avoid any potential violations we have developed the following list of 10 steps. If you manage your waste with these ten things in mind you should be able to maintain a safe and compliant workplace.

1. Remember to mark storage containers with an accumulation date.

Containers of hazardous waste in a 90 or 180-day storage area must be marked with an accumulation date. Check that yours are each week during your inspection of the storage area. You could also consider using a log or spreadsheet to track wastes in addition to review of dates during your area inspections.

2.  Make sure used oil containers are properly labeled.

Remember, “Used oil is defined as any oil that was refined from crude oil or any synthetic oil, and that is used and as a result of such use is contaminated by physical or chemical impurities.” Any container holding used oil must be marked “Used Oil.” Additionally, pipes used to transfer used oil to a UST must be marked “Used Oil.”

3.  Ensure that your containers are kept closed.

Except in the instances of adding or removing waste containers should always remain closed. This means closing and latching funnels, screwing in bungs, using drum rings, and tightening bolts. Remember, if the contents would spill if the container was overturned, then the container is considered open.

4. Keep tabs on your universal wastes.

Make sure you understand the regulations for universal wastes (things like batteries and used lamps). Properly label the wastes as “Universal Waste Batteries” and “Universal Waste Lamps.” Check your local state regulations as well.

5. Label all containers in your storage areas.

Containers in a 90 or 180-day storage area must be marked with the words “Hazardous Waste” as well as listing: generator name and address, accumulation start date, contents, physical state, and hazardous properties.

6. Have a contingency plan in place.

Whether you’re a small quantity or large quantity generator, you must have a contingency plan in place. You can help make sure you avoid violations by designating an emergency coordinator, keeping information up to date and on-site, ensuring all required elements are included in your plan, and for LQG’s, document submittals to local authorities.

7. Have a hazardous waste reduction plan on-site.

A hazardous waste reduction plan (often referred to as a waste minimization plan) is required for all hazardous waste generators. To keep yourself compliant make sure you keep a copy on-site, update that copy annually to ensure accuracy, make sure it’s signed by management, and ensure all applicable elements are included.

8. Properly label waste in satellite accumulation areas.

Utilizing satellite accumulation areas can be very beneficial to hazardous waste generators but it is imperative that all requirements listed in 40CFR are followed. Keep yourself violation free by reviewing and understanding the definition of a satellite accumulation area and by labeling your container once the first drop of hazardous waste is added.

9. Perform weekly inspections of hazardous waste storage areas.

Ensure consistency in your inspections by designating one day a week to perform them. Remember that Monday’s and Friday’s are not typically the best choices since they are often spent catching up from the weekend or readying for the weekend respectively. Have a back-up inspector and make sure that all inspections are documented in an inspection log.

10. Always make a hazardous waste determination.

You must make a hazardous waste determination for all wastes generated on your site. You should also make a list of each kind of hazardous waste generated. Determine if any exemptions apply to your wastes and figure out if your wastes are listed or characteristic hazardous wastes. Treat any unknown waste as hazardous until a determination has been made. Document everything and hold on to the documentation.  

What Is Industrial Maintenance?

Industrial Maintenance is a combination of regular housekeeping, preventative, episodic, and emergency cleaning of equipment and work areas in a manufacturing or other industrial setting. Maintenance personnel are typically responsible for making sure your equipment is functioning properly and efficiently at all times. By keeping equipment properly running, you improve the safe work environment for all personnel. Even though you have Maintenance personnel onsite, at times you may need outside help. For example, once waste will be generated by a maintenance project, it may be time to bring in an Industrial Maintenance Contractor.

 

What Do Industrial Maintenance Teams Do?
Depending on the company you use, many different tasks can be done. Usually, specialty industrial maintenance includes performing duties in hazardous or unsafe conditions. It may make sense to look for a contractor with specialty safety equipment and even specialized machinery. One thing that an industrial maintenance contractor may be trained to take care of is emergency spill response. In a situation where there may have been an accident, causing waste or other materials to spill, having a safety plan and contractor arrangements in advance are key. A cleanup team will first assess the situation and make sure to stop any further damage from occurring. Another very important job you can have completed is tank cleaning. When a tank has waste or materials in them, they will need to be cleaned periodically in order to comply with OSHA standards. An Industrial cleaner will wash, scrub and sanitize your tanks to ensure they can be used safely moving forward. The cleaning team may also do hydro-blasting, which is a technique that allows them to use high-pressure water to clean hazardous and non-hazardous material from machinery.

 

Why Is Industrial Cleaning Important?
When your equipment and machinery is clean, it is safer and more efficient. Chemical storage tanks hold all types of materials from acids, caustic, petroleum, food, pharmaceuticals, and even paint. They require cleaning for various reasons including housekeeping, mechanical problems, mixer failure, new chemistry, as well as for inspection. Typically, whenever this time comes around, sludge has accumulated inside the tank and must be removed, by regularly cleaning and inspecting, you can cut down on time spent for unscheduled maintenance and repairs. It will also keep your equipment properly working by reducing wear and tear. Not only does industrial cleaning help your machines, but it helps your personnel. By keeping equipment clean and performing at its best, it will create a safer work environment for your employees who are working with that equipment.

 

How Can Heritage Help?
When it comes to industrial maintenance, cleaning, and waste removal, trust is not just valued. It is required. You can trust the world class reliability that Heritage always offers to show up every time you need. You can trust our safety records, with employees that are rigorously trained and retrained several times per year. Heritage industrial maintenance field crews perform this work daily across the country. Our crews have the right knowledge and training to safely enter, remove any remaining material, and clean your tanks and equipment to whatever level is required. In case you are wondering what kind of services our industrial team can handle, here are some examples!

  • -Vacuum services-DOT spec high velocity vacuum trucks
  • -Hydro-excavation
  • -Confined space entry/rescue
  • -Hazardous/non-hazardous chemical removal
  • -Pressure washing
  • -Hydro-blasting
  • -CO2 ice blasting
  • -Soda blasting
  • -Pit, pond & lagoon clean out
  • -Tank cleaning
  • -Paint booth cleaning
  • -Building decontamination & decommissioning
  • -Onsite dewatering
  • -Emergency spill response, (USCG OPA/OSRO contractor)
  • -Container rental

If there are other services you may be looking for, don’t worry! Heritage is able to handle anything you throw at us! Contact us today and we will work towards a plan that can take care of your cleaning needs, large or small.

The Clean Air Regulation for Hazardous Waste Incinerators:

While it makes good sense for people and industry to reduce, reuse or recycle waste, there will always be residuals, byproducts and spent materials that must be disposed of in compliance with the nation’s hazardous waste disposal rules and requirements. Whether landfill or incineration, disposal facilities must follow a demanding array of regulations to ensure that the waste is managed properly. The regulation for managing air emissions from an incinerator is our focus here.

Various industries producing everything from acrylics to wool fiberglass products are subject to industry-specific regulations of the federal Clean Air Act. These are called the Maximum Achievable Control Technology standards, known simply as MACT. Hazardous waste incineration is one of the industries subject to MACT because the process, like others under the MACT rules, emits substances identified by the U.S. EPA as hazardous air pollutants, or HAPs. Among the 187 HAPs, some of the more familiar ones are: benzene, dioxin, toluene and metals such as cadmium, mercury and lead compounds.

MACT standards for controlling HAP emissions from an industry group, such as hazardous waste incineration, are based on performance of the top 12 percent of that industry group’s facilities that are operating currently. In other words, the minimum standard for hazardous waste incinerators is based on the results of the top performers in the industry. That is how the “Maximum Achievable” part of the rule came about.

“Control Technology” refers to the technology, processes, techniques and work practices that are employed to reduce and control emissions of HAPs. Examples include limits on feed rates, pressures, temperatures and the flow rate of a material as it passes from combustion through the emissions-control system.

The U.S. EPA began work on the rule in the late 1990’s. It was made final in 2005 following input from the public, the various industry sectors, academia and government.

Once set, facilities began conducting required Compliance Performance Tests, or CPTs, to demonstrate compliance. These restrictive tests stress how the facility performs while incinerating larger-than-usual amounts of waste.

For example, MACT requires incinerators to demonstrate 99.99″ destruction of hazardous compounds contained in the waste. An incinerator would not be permitted to operate if it could not demonstrate this level of destruction removal efficiency during the rigors of the CPT.

To demonstrate ongoing compliance, incinerators must conduct these comprehensive tests, which take up to a week to complete, every five years. They must also conduct a specific test every 2.5 years to demonstrate compliance with the MACT limit for emissions of dioxin. A facility’s permit limits will be adjusted accordingly following analysis of the test results.

Visit Hazardous Waste Combustor MACT for more information about this important rule.