Fishbeck, Thompson, Carr & Huber, Inc. Special Wastes Characterization & Documentation Best Practices Michele J Buckler, P.E., LEED ® AP Stephanie C Werner.

Fishbeck, Thompson, Carr & Huber, Inc.

Special Wastes

Characterization & Documentation Best Practices

Michele J Buckler, P.E., LEED® AP

Stephanie C Werner

What are Special Wastes

What are we going to talk about? This is specific to non-hazardous waste Sometimes called “Special Wastes” Can be from:

Industrial, Commercial, Construction, or Agricultural Activities

30 Seconds through RCRA Haz Waste Rules……OK, maybe 60

D Wastes Ignitable

Flash <140o F Corrosive

2 < pH > 12.5 Reactive

reacts with water or other compounds Toxicity

~40 compounds and metals listed

Listed Wastes

F List - Wastes from nonspecific sources - processes or sources within a certain industries (spent halogenated solvents; distillation residues; etc.)

K List - Wastes from specific sources or within a certain industry

P List - “Acute” Wastes - because small amounts may cause severe health effects

U List - Wastes include discarded commercial chemical products, manufacturing chemical intermediates or off-specification commercial chemical products

So….once you have eliminated you or your client’s waste from the hazardous designation, you still have to find a good home for it and ensure and efficient disposal approval process.

Why?

If you have a one time or a repeating waste stream, you need to complete the appropriate analysis and prepare the appropriate documentation to make the approval process easier. This serves multiple purposes: Provides certainty for the client’s compliance program Provides certainty for the ultimate disposal site Provides supporting documentation for regulatory

audits Makes everything smoother!

This is merely a best management practice to make a complete package to tie up all the loose ends.

Don’t argue with the disposal facility – they have internal protocols and standards!!

Documentation

Prepare a memo which details: How waste is generated (process description) - be very, very

specific If it is similar to some of the Listed Wastes – explain why it is

different Physical description of the waste (color, consistency, odor,

size/form) Landfill personnel can easily confirm that it is the correct waste

If you send an analytical report – please provide a tabulated summary along with the entire report. If the report contains analytical for other samples, explain.

If you are an agent signing for the Generator, provide appropriate documentation

Documentation

If the waste is from a remediation project – ensure that you have adequate soil and/or groundwater data to support the non-hazardous claim. Include a simple map of the site. Make sure analytical is current and not 8 years old!

If the facility produces other hazardous wastes, ensure that this is presented and provide a statement that the there is no chance of co-mingling.

Explain why analytical was not conducted or not necessary.

Laboratory Wastes – Audits

Many labs have been under additional scrutiny from EPA Hazardous Waste enforcement divisions More frequent and rigorous audits/inspections

Common violations for R&D laboratories Chemical Hygiene Plans lacking or outdated Satellite Accumulation Areas

Secondary satellite areas Improper grounding Satellite placement improper for “operator control”

Laboratory Wastes – Tips

Chemical hygiene plan up-to-date Annual review by CH officer documented Updates need to be universal to all copies Each lab bench employee needs to know how to

use, especially during an audit Satellite accumulation has a limit

Pursuant to 40 C.F.R. § 262. 34(c)(1), “a generator may accumulate as much as 55 gallons of hazardous waste or one quart of acutely hazardous waste listed in § 261.33(e)”

Thank You

[email protected] [email protected]