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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.

Easy to Use, Complete Technical Waste Disposal Service

Whether you work in a lab, research facility, or are a small generator, you may have small chemical containers needing disposed. Accumulating different chemicals can be overwhelming because there can be uncertainty about how to dispose of each chemical, hazardous or non-hazardous. Using a lab pack service gives you the peace of mind that all your hazardous and non-hazardous chemicals are being handled properly.

What is Lab Packing?
During a lab pack, qualified professionals will begin by assessing the customers needs. An inventory will be taken, and the contents of each container be determined; even unidentified chemicals. When all chemicals are identified, the lab pack team will pack compatible chemicals from small containers into a larger DOT (Department of Transportation) approved container. The lab pack process ensures the safe handling of chemicals to be taken for proper removal.

How Do You Choose the Right Company?
What are some things you should look for when choosing a company to take care of your chemicals? First you need to ensure EPA compliance. Being compliant to all rules and regulations set by the EPA makes sure that you are working with a company that is properly handling or disposing chemicals. Another important aspect is that a lab pack service crew are properly trained. Having appropriately trained professionals is important because you want to make sure each team member knows what each chemical does, and what chemicals are dangerous if they were to come into contact with each other. There are also benefits if you choose a company who does in house disposal. By using a company who does the lab pack and disposal, you are eliminating the middle man. You are trusting one company and don’t have to worry about improper disposal done by a separate company. When you use one trusted company, you can know that every step is handled by the same team with the same goals.

How Heritage Can Help
If you want to make sure you are following all the regulations set by the EPA, Heritage can help. Here’s how it works:

  1. Our highly trained personnel will meet you on-site to handle all your waste materials. They will help you identify any unknown materials to ensure you everything is being handled appropriately.
  2. We supply all materials and labels needed to ensure regulatory compliance.
  3. We haul everything away for you.

We give you better visibility because you will know exactly what you are dealing with and exactly where it is going. We make it easy! We can save time because all you have to do is make the call to us and we do the rest. Contact us today to get started on your lab pack!

Just What Is “Proper Disposal?”

A family watches a TV news story about a traffic accident involving a chemical spill. The reporter closes by explaining that hazmat crews cleaned up the spill and sent the material off for proper disposal.

A homeowner packs the trunk of her car with boxes of old paint cans, pool and yard chemicals, plus cleaners and solvents that she no longer wants. She drives to a household hazardous waste collection event sponsored by her community. She is satisfied that her old household chemical products have been collected for proper disposal.

A high school chemistry teacher gets ready for another school year by cleaning out and organizing the chemicals in the school’s laboratory. He sends an email to the principal that the lab’s inventory is stored safely, and that the old and unwanted chemicals were shipped out for proper disposal.

For many, the story about proper disposal of hazardous waste ends there.

Without question, our modern society has increased living standards and lengthened life spans. It grows and thrives based on a dynamic economy that produces many goods and services. The production and use of many common, everyday products leave chemical residues that may harm health and the environment if they are not managed properly. That description, essentially, is the definition of a hazardous waste. It takes a specialized industry to manage these materials in an environmentally responsible manner.

For decades, chemical wastes were stored haphazardly, buried, dumped, or burned indiscriminately because they were in the way. Well-known examples of mismanaged hazardous waste, led to the abandonment of a suburban neighborhood in Love Canal, New York, and an oil fire on the Cuyahoga River in Cleveland, Ohio.

Things began to change following the passage of landmark federal legislation in 1976. The Resource Conservation and Recovery Act, known as RCRA, committed the nation to identifying hazardous wastes and developing a program to manage them in a responsible manner. RCRA mandates the proper types of treatment for each type of hazardous waste. This treatment might be chemical neutralization, physical separation of the hazardous chemicals, or possibly thermal treatment to destroy the hazardous compounds. EPA dictates the types of treatment by waste type, thus ensuring proper disposal.

Despite the efforts and policy mandates for people and industry to reduce, reuse or recycle waste, there will always be a chemical residue that must be disposed of in a permitted landfill or be treated by high-temperature incineration with strict controls for air emissions.

So the next time you see a news story about an environmental cleanup, participate in a community household hazardous waste collection, or perform an experiment in a school chemistry lab, think about what “proper disposal” means. You can rest assured there are companies like Heritage that have the experience and know-how to protect health and the environment from the hazards of hazardous wastes.

Watch for future blogs about various waste and treatment types and how the environmental industry helps to assure proper disposal.

For sites that generate potentially hazardous wastes it is imperative that they make a hazardous waste determination for each and every waste generated. The determination process, also called the hazardous waste identification (HWID) process, is one of the first and perhaps the most important step for properly managing waste materials. To make a proper waste identification a generator must ask four questions:

  • Is the material a solid waste?
  • Is the waste specifically excluded from RCRA?
  • Is the waste a listed hazardous waste?
  • Does the waste exhibit a characteristic of hazardous waste?     

After answering each of these questions a generator will be prepared to facilitate compliant storage and disposal of any wastes generated.

Is the material a solid waste?

In order to answer the first question, 40 CFR Part 261.2 defines materials that are solid wastes and those that are not solid wastes. RCRA §1004(27) defines a solid waste as, “any garbage, refuse, sludge from a wastewater treatment plant, water supply treatment plant, or air pollution control facility, and other discarded material, including solid, liquid, semisolid, or contained gaseous material, resulting from industrial, commercial, mining, and agricultural operations and from community activities.”

Additionally, the EPA provides several tools, including a Definition of Solid Waste (DSW) decision tool that can help walk you through this first step.

Is the waste specifically excluded from RCRA?

There are some types of solid wastes that the EPA excludes from the definition of hazardous waste. These materials, regardless of meeting a listing or exhibiting a characteristic of hazardous waste, cannot be considered a hazardous waste. According to §261.4(b), excluded wastes include:

  • Household Hazardous Waste
  • Agricultural Waste
  • Mining Overburden
  • Fossil Fuel Combustion Waste (Bevill)
  • Oil, Gas, and Geothermal Wastes (Bentsen Amendment)
  • Trivalent Chromium Wastes
  • Mining and Mineral Processing Wastes (Bevill)
  • Cement Kiln Dust (Bevill)
  • Arsenically Treated Wood
  • Petroleum Contaminated Media & Debris from Underground Storage Tanks
  • Injected Groundwater
  • Spent Chloroflurocarbon Refrigerants
  • Used Oil Filters
  • Used Oil Distillation Bottoms
  • Landfill Leachate or Gas Condensate Derived from Certain Listed Wastes
  • Project XL Pilot Project Exclusions

Many of these exclusions are conditional and often specific to an industry or type of waste. Careful reading of the conditional exclusions is necessary when making these determinations.

Is the waste a listed hazardous waste?

The EPA has studied hundreds of different waste streams and listed the wastes accordingly. Listed wastes are described or listed on four different lists that can be found at 40 CFR 261, Subpart D. These four lists are:

  • The F list — The F list designates particular solid wastes from certain common industrial or manufacturing processes as hazardous. Because the processes producing these wastes can occur in different sectors of industry, the F list wastes are known as wastes from nonspecific sources. The F list is codified in the regulations at §261.31.
  • The K list — The K list designates particular solid wastes from certain specific industries as hazardous. K list wastes are known as wastes from specific sources. The K list is found at §261.32.
  • The P list and the U list — These two lists are similar in that both list pure or commercial grade formulations of certain specific unused chemicals as hazardous. Both the P list and U list are codified in §261.33.

Does the waste exhibit a characteristic of hazardous waste?    

There are four characteristics of hazardous waste. These characteristics help us understand what the waste is capable of/how it poses a danger. The four characteristics are ignitability, corrosivity, reactivity, and toxicity. Full definitions of these characteristics can be found here.

You may remember from our post and eBook on the Top 10 Hazardous Waste Generator Violations that “Failure to Perform Weekly Inspections of Hazardous Waste Storage Areas,” is among the most common ways generators violate EPA regulations. 

Weekly container inspections are imperative to protect you, your company, and the health and safety of the public. By performing your weekly inspections you can identify any issues that may arise and stop sills before they happen.

The EPA recommends that companies develop and maintain a standard inspection checklist that can be used during each weekly inspection. This checklist should be detailed and include both the labeling and management procedures in place at your facility. 

We have prepared a checklist (with some additional tips) which can be downloaded by clicking the button below. 

This checklist can be modified to fit the needs of your facility but remember that at the very list you need to address the following:

  • Any leaks or staining coming from containers;
  • Condition of your containers including noting any dents, bulging, and/or corrosion; 
  • Proper labeling—this should include a clearly marked start date as well as the words “Hazardous waste.”  Any other relevant information about the waste should also be indicated on the label.
  • Management practices such as aisle space and drum stacking.

Remember, these inspections are very important in both protecting your company from committing a violation and ensuring the protection of human health and the environment. Inspections should be detailed and methodical and should always be performed by a fully trained individual.

The EPA provides the following tips for conducting your weekly container inspections:

  • “Follow the inspection checklist – make detailed notes if you find something wrong.
  • Be thorough. Check the tops of drums to look for waste residue or corrosion.
  • Walk all the way around containers – check entire storage area.
  • Check containment area for stains.
  • Note anything unusual in containment area – even if it might not be a problem.
  • If problems are found, get the problem taken care of immediately.
  • Keep a logbook of the facility’s inspection checklist.”

 

Quoted and cited information for this blog post (unless otherwise noted) was gathered from the EPA Handbook for Hazardous Waste Containers. As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

When a waste material contains radioactive as well as hazardous components it is considered a mixed waste. According to the EPA, “mixed-waste can be generated anywhere radioactive materials are used in processes that also involve the use of chemically hazardous materials.” Generally, however, they come from one of two sources. The first is low-level mixed-waste which is created by commercial users. The second is “low-level, high-level, and transuranic mixed-waste generated by the Department of Energy [source],” both are explained in detail below. Because mixed waste includes both radioactive and hazardous material the treatment and regulation are even more complex than when handling either type of waste individually.

According to the EPA, “most commercially-generated (i.e., non-DOE) mixed waste is classified as low-level mixed waste (LLMW). LLMW is waste that contains low-level radioactive waste (LLRW) and hazardous waste. LLRW is defined as any radioactive waste that is not high-level radioactive waste, spent nuclear fuel, or byproduct material. LLMW is generated commercially in all 50 states at industrial, hospital, and nuclear power plant facilities in a number of processes such as medical diagnostic testing and research, pharmaceutical and biotechnology development, pesticide research, and nuclear power plant operations.”

As mentioned above, the United States Department of Energy produces three different types of mixed waste. The EPA details the three categories as:

  • “Low-level mixed waste (LLMW) – [this waste type] results from research, development, and production of nuclear weapons. An estimated 226,000 cubic meters (m3) of DOE LLMW will require management over the next 20 years.
  • High-level mixed waste (HLW) – [this waste type] results from reprocessing spent nuclear fuel and irradiated targets from reactors. These wastes often contain highly-corrosive components, organics, or heavy metals that are regulated under RCRA. DOE has about 399,000 m3 of HLW stored in large tanks at four locations across the U.S.
  • Mixed transuranic waste (MTRU) – [this waste type] contains radioactive elements heavier than uranium and a hazardous waste component. MTRU is primarily generated from nuclear weapons fabrication, plutonium bearing reactor fuel fabrication, and spent fuel reprocessing.”

Mixed waste is regulated by both the Resource Conservation and Recovery Act (RCRA) and the Atomic Energy Act (AEA). Generally the regulatory bodies agree on requirements but if they do not AEA takes precedence. That said, the Department of Energy is self-regulating with orders applying to both DOE sites and contractors. These sites must comply with the Federal Facilities Compliance Act (FFCA) which was made into law in 1992.

In 2001, the EPA finalized the mixed waste rule. This rule, “provides increased flexibility to generators and facilities that manage low-level mixed waste (LLMW) and technologically-enhanced, naturally-occurring, and/or accelerator-produced radioactive material (NARM) containing hazardous waste.” It also addresses the differences in storage, treatment, and transportation rules between hazardous wastes and mixed wastes.

If you would like further information about mixed waste visit the EPA article on the subject, Mixed Wastes.   

In honor of throwback Thursday I decided to rehash one of the first things we ever wrote about on this blog. The ten most common violations incurred by hazardous waste generators. As you can most likely infer, these items are ones you’ll want to make sure are not happening at your company. The ten items are listed and explained below. And if you’d like a little more information about the violations and how to avoid them you can also check out our eBook on the subject.

1. Open Container Violations – An open container includes containers that have tinfoil caps, funnels, or loose caps. Containers must be closed at all times unless they are being filled or emptied.

2. Storage Area Accumulation Date Violations – Remember, containers of hazardous waste in a 90 or 180-day storage area must be marked with an accumulation date.

3. Universal Waste Violations – This includes management of wastes such as batteries and lamps.

4. Used Oil Labeling Violations – Remember that any container or tank utilized to hold used oil should be labeled “Used Oil.”

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

6. Satellite Accumulation Area Labeling Violations – Always remember that a container must be labeled after the first drop of waste is added.

7. Contingency Planning Violations – Make sure to have you plan in place and that all employees know what to do if needed.

8. Failure to Perform Weekly Inspections of Hazardous Waste Storage Areas – Fairly self-explanatory, make sure you have weekly inspections done.

9. Failure to 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.

10. Failure to Make a Hazardous Waste Determination – It is imparitive to remember that a hazardous waste determination must be made for each and every waste generated on your site.

Good news, blog friends! We have a new eBook to tell you about today! If you are subscribed to our email newsletter you will have gotten early access to this last week; now it is available to everyone though!

You may be wondering what the new eBook is about so let me tell you! We’re calling it a Hazardous Waste Cheat Sheet and it lives up to its name. Within this short eBook you will find information on a few different basics of hazardous waste, including:

  • The Definition of Hazardous Waste
  • The Characteristics of Hazardous Waste
  • The Different Hazardous Waste Classes and
  • Common Hazardous Material/Waste Acronyms and Recognized Abbreviations

This one may come as a shock to you because we don’t tend to think of things we use regularly (like our cell phones, iPods, and computers) as having the possibility to be considered hazardous. These types of wastes, identified by the somewhat new term E-wastes, include a bevy of items falling under the umbrella of out dated and out of use electronics.

What might I have?

So what exactly are e-wastes? According to the California Department of Toxic Substances Control, “’E-waste’ refers to any unwanted electronic device or Cathode Ray Tube (CRT) and is classified as universal waste. E-waste frequently contains hazardous materials, predominantly lead and mercury, and is produced by households, businesses, governments, and industries.” That said, anything from old stereos and boom boxes to outdated cellphones or computers can fall into this category.

What does this mean for me?

Does this mean that the longer you keep your computer the greater the chance is of it spontaneously going up in flames? Not at all. It simply means that when the time comes to dispose of your old computer you need to be sure to do it in the proper manner.

According to the Marion County ToxDrop Committee, “everything from cell phones to computers needs to be recycled rather than thrown away. Electronics contain hazardous materials such as lead and mercury. These materials, if buried in a landfill, can contaminate groundwater and cause serious health issues for humans.”

How can I dispose of my e-wastes?

Electronics can be broken down and separated into plastic and aluminum to be reused. The City of Indianapolis has a program called ToxDrop for all city citizens where you can drop off your electronics and household hazardous waste to be recycled and/or disposed of properly. Most other cities have similar programs. It just takes a quick Google search to find out about one near you!

Because they are a greener alternative to traditional light bulbs, fluorescents have become increasingly popular in homes and businesses. This category includes fluorescent lamp tubes or bulbs. Fluorescent lamp ballasts are also considered a part of this category.

The danger with these bulbs is that they contain small amounts of mercury, a potent, developmental neurotoxin that can damage the brain, liver, kidneys and central nervous system, especially in infants and young children.

The bulbs are perfectly safe as long as the glass is not broken and for that reason it is important to be especially careful when disposing of spent fluorescent bulbs. Since they contain mercury, fluorescent bulbs should be recycled in order to ensure that they stay out of landfills where they could contaminate the air, soil and/or groundwater.

The EPA provides a few reasons why is Recycling CFLs Important as well. Recycling prevents the release of mercury into the environment. CFLs and other fluorescent bulbs often break when thrown into a dumpster, trash can or compactor, or when they end up in a landfill or incinerator.

Other materials in the bulbs get reused. Recycling CFLs and other fluorescent bulbs allows the reuse of the glass, metals, and other materials that make up fluorescent lights. Virtually all components of a fluorescent bulb can be recycled.

Your area may require recycling. Some states and local jurisdictions have more stringent regulations than the U.S. EPA does, and may require that you recycle CFLs and other mercury-containing light bulbs. California, Maine, New Hampshire, Minnesota, Vermont and Massachusetts, for example, all prohibit mercury-containing lamps from being discarded into landfills.

Some examples include:

  • CFLs (Compact Fluorescent Lamp), U-Bends, Circular
  • 4’ and 8’ fluorescent lamp tubes