UNIT I STUDY GUIDE

Hazardous Waste

Course Learning Outcomes for Unit I

 

Upon completion of this unit, students should be able to:

 

1. Identify the primary laws that govern hazardous waste operations and discuss how they are applied in workplace situations.

2. Identify hazardous wastes using the EPA-defined characteristics of ignitibility, corrosivity, reactivity, and toxicity.

3. Identify hazardous wastes using the EPA F, K, P, and U lists.

4. Define universal wastes and describe the requirements for handling them.

5. Define the various categories of hazardous waste generators and explain the regulatory requirements that apply to each.

6. Describe the precautions for the safe handling of hazardous waste.

7. Identify and explain strategies for waste minimization.

8. Identify the considerations for selecting hazardous waste transporters and treatment storage and disposal facilities (TSDF).

9. Discuss the process and options available for the remediation of contaminated hazardous waste sites.

 

 

Reading Assignment

 

Forward: pp. iv-vii

 

Chapter 1:

Hazardous Waste

 

EPA Listed Wastes, 40 CFR 261.31-33: http://www.epa.gov/epa waste/hazard/wastetypes/listed.htm

 

 

Unit Lesson

 

 

BOS 3125, Hazardous Materials Management

5

 

 

 

 (NARA, 2011a)

 

Here we are, ready to start a course titled “Hazardous Materials Management,” but the first course unit and first chapter in the book are titled “Hazardous Waste.” What’s that about? Isn’t hazardous waste at the end of the lifecycle and more appropriate for the end of the course? Besides, safety practitioners aren’t responsible for hazardous waste; that’s an environmental thing, right?

 

In order to manage hazardous materials in the workplace effectively, we need to start with the end in mind; that is, what happens to the material when we are done with it. The Resource Conservation and Recovery Act (RCRA) of 1976 introduced us to the cradle to grave” concept of hazardous materials management by focusing efforts on the final disposal of hazardous substances (Haight, 2012). The improper disposal of industrial waste over many decades had created enormous health and environmental issues, as well as a nearly insurmountable cleanup problem.

 

 

The Environmental Protection Agency (EPA) has created regulations for the cleanup of contaminated waste sites, but more importantly, has forced industries to think about the materials they use, how they are stored and handled, and how they are to be discarded when no longer needed. The escalating cost of the disposal of hazardous wastes in accordance with EPA rules has caused many industries to change to materials that are less hazardous or change processes so that hazardous materials are no longer needed. Recycling and reuse of hazardous materials has become more cost-effective than disposal. One of the goals of RCRA is to prevent

 

future problems caused by irresponsible waste management (Haight, 2012). This goal is being achieved by managing the full lifecycle of hazardous materials.

 

Safety practitioners are most often concerned with OSHA regulations and the effects of hazardous materials on the workers, and they might feel that compliance with EPA regulations belongs to someone else. Some organizations do have a separate environmental compliance office, and other organizations choose to combine the “safety” and “environmental” functions. Regardless of how the responsibilities are divided, the safety practitioner must be familiar with EPA rules and regulations, since they are central to the decisions made regarding hazardous materials in the workplace. Over the years, the OSHA/EPA connection has become even closer, with OSHA’s Hazardous Waste Operations and Emergency Response (HAZWOPER) and the Hazard Communication Standard. It is interesting to note that RCRA predates both of these OSHA standards.

 

The core of RCRA is the identification of hazardous wastes. The first determination is whether or not a material is a solid waste. Anything that is discarded is considered a solid waste, but not all solid wastes are hazardous. A solid waste is designated as hazardous if it is listed in one of the four RCRA

Environmental technicians secure the lid of a hazardous material container. (Barstow, 2008)

 

hazardous waste code lists (F, K, P, and U). If the material is not listed, it can still be classified as hazardous

if it exhibits one or more of the criteria of ignitibility, corrosivity, reactivity, and toxicity. There are really very few industrial wastes that will not fall into one of the above categories. (Graphic below is on page 6 of the textbook.)

 

Producers of hazardous waste are called “generators.” Hazardous waste generators must determine what category applies to them: Small quantity generator, large quantity generator, or conditionally exempt small quantity generator. The determination requires a comprehensive inventory of all hazardous materials in use and an understanding of the waste streams produced. The inventory is often the same one used by safety practitioners to comply with OSHA standards; again we see the connection.

Hazardous waste identification process

(Haight, 2012)

 

 

Cost-benefit analysis is often used to determine whether hazardous materials should be replaced with less

 

 

Polluted South Platte River, circa 1972

(NARA, 2011b)

 

hazardous ones, or whether materials can be reused or recycled. Since ultimate disposal of hazardous materials is subject to a myriad of regulatory requirements, it is often the most costly option. At this point, we can see the positive effect on some additional RCRA goals:

 

1. Protect human health and the environment

2. Conserve energy and natural resources

3. Reduce the amount of hazardous waste generated

 

In the 1960s, America found itself awash in hazardous waste. Lakes and rivers were polluted, and numerous uncontrolled hazardous waste dumpsites were leaching hazardous substances into our soil and water supply. The New York Times called waste “The third pollution” (as cited in U.S. Environmental Protection Agency, 2002). Perhaps it is more correct to think of waste, particularly hazardous waste, as the first pollution, since it is one of the major causes of polluted water, air, and soil. RCRA was intended to be a pollution prevention solution (U.S. Environmental Protection Agency, 2002). For the safety practitioner, it has also aided significantly in injury prevention by reducing the quantity and types of hazardous material in the workplace, reducing the risks to all workers.

 

Role of the States

 

Under RCRA, hazardous waste management is intended to be a joint federal/state effort. Using the RCRA framework, each state creates its own waste management plans to meet its specific needs and establishes its own regulatory requirements. This unit will discuss only the Federal RCRA provisions. It is important that safety and environmental practitioners also become familiar with all of their state and local hazardous waste requirements. Most state information can be found on the Internet.

 

CERCLA

 

Safety practitioners also need to be aware of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly known as Superfund. Through a tax levied on the chemical and petroleum industries, CERCLA created a trust fund that is used for cleaning up abandoned or uncontrolled hazardous waste sites (U.S. Environmental Protection Agency, 2011). EPA has established a National Priority List (NPL) for the long-term planning of hazardous waste cleanup and administers the program through its ten regional offices.

 

References

 

Barstow, T. (2008). USMC-02502 [Photograph]. Retrieved from http://commons.wikimedia.org/wiki/File:USMC-02502.jpg

 

Haight, J. M. (Ed.). (2012). Hazardous material management and hazard communication. Des Plaines, IL: American Society of Safety Engineers.

 

U.S. Environmental Protection Agency. (2011) CERCLA overview. Retrieved from http://www.epa.gov/superfund/policy/cercla.htm

 

U.S. Environmental Protection Agency. (2002). 25 years of RCRA: Building on our past to protect our future [Brochure]. Washington, D.C.: Author. Retrieved from http://www.epa.gov/osw/inforesources/pubs/k02027.pdf

 

U.S. National Archives and Records Administration (NARA). (2011a) Special precautions must be taken for disposing of hazardous materials. As in this area near El Centro in the…- NARA [Photograph]. Retrieved from http://commons.wikimedia.org/wiki/File:SPECIAL_ PRECAUTIONS_ MUST_BE_TAKEN_FOR_DISPOSING_OF_ HAZARDOUS_ MATERIALS._AS_IN_THIS_AREA_NEAR_EL_CENTRO_IN_THE…_-_NARA_-_553905.jpg

 

U.S. National Archives and Records Administration (NARA). (2011b) The polluted South Platte River- NARA [Photograph]. Retrieved from http://commons.wikimedia.org/wiki/File:THE_POLLUTED_SOUTH_ PLATTE_RIVER_-_NARA_-_544810.tif

 

 

Suggested Reading

 

Learn more about this unit’s topics by researching in the CSU Online Library. The following are examples of the information you can find in the Academic OneFile database of the CSU Online Library:

 

· “EPA Reports on Progress Made Toward the 2020 RCRA Corrective Action Goal,” an article in the September-October 2012 issue of the Hazardous Waste Consultant, discusses RCRA Subtitle C, which provides a system for managing hazardous waste from cradle to grave, and EPA’s strategy for enforcing this type of waste management. The article provides information on EPA regional office corrective action contacts and facilities, as well as discussion of such topics as enforceable mechanisms and assessing, targeting, and prioritizing facilities for enforcement.

· “RCRA Nonhazardous Solid Waste Identification Rule,” from the March-April 2013 issue of Hazardous Waste Consultant, discusses the final rule issued by the EPA on March 21, 2011, concerning nonhazardous secondary materials that may or may not be RCRA solid wastes when burned in combustion units and the Feb. 27, 2013 revisions that clarify that 2011 ruling. The discussion goes back to the first ruling on the subject in 2000, and carries forward to the current 2013 clarification.

· “Delhi’s Dumps Are ‘Public Health Time Bombs’,” by Wendy Glauser, is a May 2013 article that talks about the landfills in India and how advances in waste management have negatively impacted those who depend on scavenging in order to earn money, such as 11-year-old Ambiya.

· “Canadian Zinc Producer Liable for Hazardous Discharges into the United States,” an article in the March-April 2013 issue of Hazardous Waste Consultant, details a December 14, 2012 decision against a Canadian zinc producer that addressed illegal discharges of slag and effluent that had been occurring for more than 60 years, and the resultant costs for the company. This is only the first phase of the case.

· Health care wastes are hazardous, and they occur all over the world. “Assessment of the Health Care Waste Generation Rates And its Management System in Hospitals of Addis Ababa, Ethiopia, 2011” is a January 12, 2013, article in BMC Public Health that discusses health care waste generation rates, waste classification, unsanitary landfill sites, and the disposal mechanisms used for the health care waste, using information collected from six hospitals in Addis Ababa, Ethiopia.

 

The following are examples of articles you can find in the GreenFILE database of the CSU Online Library:

 

· “EPA Memos Provide Agency Interpretations of RCRA Requirements,” is a 2012 article from the Hazardous Waste Consultant. The article discusses the EPA position on a variety of RCRA topics that were addressed in regulatory interpretation memos. The memos are presenting in Q&A format.

· “Developing Best Management Practices,” by Norman Wei, discusses best management practices (BMPs) required under EPA regulations. Topics discussed include properly written and documented BMPs. This article appeared in the April 2013 issue of Pollution Engineering.

· “Power Player,” by Allan Gerlat, discusses breakthrough projects undertaken by Pennsylvania’s Lancaster County Solid Waste Management Authority to derive resources from waste, such as a wind power generation project and another in which LCSWMA will provide steam for processing needs for a soybean crushing facility. The article appeared in the March 2013 issue of Waste Age.

 

Learning Online

 

You can also find a wealth of information concerning hazardous waste by searching online. Be wary when looking online, however, as all of the information available via the Web is not accurate and reliable. The following are examples of trustworthy web sites that pertain to this unit and its topics:

 

· EPA Non-Hazardous Waste Regulations http://www.epa.gov/osw/laws-regs/regs-non-haz.htm

· EPA Hazardous Waste Regulations http://www.epa.gov/osw/laws-regs/regs-haz.htm

· Use of Risk-Based Decision-Making in UST Corrective Action http://www.epa.gov/swerust1/directiv/od961017.htm

· U.S. Environmental Protection Agency. (2002). 25 years of RCRA: Building on our past to protect our future [Brochure]. Washington, D.C.: Author. Retrieved from http://www.epa.gov/osw/inforesources/pubs/k02027.pdf

· RCRA History

http://www.epa.gov/osw/laws-regs/rcrahistory.htm

· RCRA Guidance, Policy, and Resources http://www.epa.gov/osw/laws-regs/rcraguidance.htm

 

 

Learning Activities (Non-Graded)

 

State and Local Regulations vs. EPA: Who’s Tougher?

 

Research the hazardous waste regulations established by your state and local area. Are they more restrictive than the EPA requirements? Create a table that highlights the major differences.

 

Workplace Waste Generation

 

Find out what hazardous waste is generated by the organization for which you currently work. Determine the classification of hazardous waste generator you think would apply and compare your decision to how the organization classifies itself. If there is a difference, what caused it?

 

What’s In The House?

 

Create an inventory of cleaning products on hand in your home. Based on the major ingredients listed on the label, determine if each product would be a hazardous waste (if you were a regulated generator). Use the EPA definitions of characteristic wastes and the listed wastes (F, K, P, & U) in 40 CFR 261 to make your determinations.

 

Non-graded Learning Activities are provided to aid students in their course of study. You do not have to submit them. If you have questions, contact your instructor for further guidance and information.

 

Key Terms

 

1. Characteristic waste

2. Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)

3. Conditionally exempt small quantity generator

4. Corrosivity

5. Emergency Planning and Right to Know Act (EPCRA)

6. Ignitibility

7. Large quantity generator

8. Listed waste

9. Reactivity

10. Resource Conservation and Recovery Act (RCRA)

11. Small quantity generator

12. Superfund Amendment and Reauthorization (SARA)

13. Toxicity

14. Treatment, storage and disposal facility (TSDF)