Hazardous Waste Handling
Written by Steve Hudgik February 2013
The specific procedures for hazardous waste handling vary depending on the waste being managed. However, there are some general principles. To illustrate the principles of hazardous waste handling we'll take a look at how waste containing lead-based paint should be managed. This is a common hazardous waste that results from building renovations.
Most waste involving lead-based paint is likely to be a physically solid waste. Contaminated waste water, such as mop and shower water disposed into in a municipal waste water treatment system, is regulated under the Clean Water Act. This makes it exempt from the federal RCRA. However, local water departments may regulate water discharges from lead hazard control sites.
Hazardous Waste Handling - Materials Coated With Lead-Based Paint
Improper hazardous waste handling can result in serious health problems and damage to the environment. For example, debris containing lead-based paint can contaminate the soil and groundwater. During renovations or demolition, discarded building components that are coated with lead-based paint may inadvertently be recycled and installed in other dwellings. In addition, if their work clothes are not cleaned or disposed of properly, workers may bring leaded dust into their homes.
Even if classified as nonhazardous wastes, the following procedures for handling demolition materials from buildings are recommended:
- Once painted components are removed from the contained work area, cutting, breaking or any other action that is likely to create dust, should be prohibited.
- Separate glass from windows for recycling.
- While still within the work area, waste should be contained by wrapping it in 6-mil polyethylene plastic and sealing all seams with tape. A disposal facility that can accept waste wrapped in plastic should be used. If such a disposal facility is not available, the unwrapped waste should be securely covered with plastic during storage and transport.
- Waste should be stored in a designated secure area that is separate from the work area. If the material is stored or handled outdoors, 6-mil plastic sheeting should be placed underneath and on top of the material to prevent soil contamination. Plywood, or another durable material, should be placed on top of the plastic to help prevent it from being damaged by wind or punctured.
- Waste materials should always be transported in covered vehicles to minimize lead dispersal into the environment.
- Waste should not be disposed of in a solid waste incinerator.
- Waste should not be reused nor recycled as mulch.
- All non-hazardous solid waste should be disposed ofin a state-licensed or permitted solid-waste landfill.
Hazardous Waste Handling - Concentrated Lead Waste
Some waste will have a higher lead concentration of lead. As a result they will fail the Toxicity Characteristic Leaching Procedure (TCLP). This is called Category III lead waste.
The TCLP is an analysis that simulates leaching through a landfill. Any waste material exhibiting hazardous characteristics, and which is likely to leach lead above 5 ppm, fails the TCLP and is designated as a Category III waste. This type of waste frequently includes paint strippings, lead paint chips, dust, and HEPA vacuum and filter debris. Although the EPA also places cleaning rags, sponges, mops, and scrapers into this same category, if they are properly cleaned these materials may not contain significant levels of leachable lead.
Note: if more than 100 gallons of waste water will be produced, the local waste water treatment facility should be contacted to determine if special measures should be taken before the waste water is poured down the toilet. The treatment facility should be informed about any phosphate detergents or other cleaners that will be used during cleaning. The water should not be discharged until the proper authority has granted permission to do so. Waste water should never be poured onto the ground or pavement.
To determine if the waste being produced is hazardous, EPA lists may be used, or the waste may be tested. If the site-specific testing indicates that the waste passes the toxicity test, then the waste is not considered hazardous. For liability purposes, test records should be maintained for at least ten years.
In addition, hazardous waste handling and management standards vary depending upon the quantity of hazardous waste produced. Those sites generating less that 220 pounds per month of hazardous waste qualify as "conditionally exempt," small-quantity generators. They may handle all waste as though it was nonhazardous.
However, even if the waste is exempt from hazardous waste regulations under the small quantity exemption, the following procedures are recommended for handling Category III waste:
- Wrap the waste in plastic and seal the seams with tape
- Cover during transport.
- Prohibit the waste from being burned in a solid waste incinerator.
- Dispose of the waste in a state-permitted or licensed solid waste landfill.
Hazardous Waste Handling - Other Waste
There are other hazardous wastes that may be generated, such as excavated lead-contaminated soil. Unless the generator has specific knowledge that the waste is not hazardous, these wastes should be tested to determine if they have any of the RCRA hazardous characteristics. If the waste is determined to be hazardous, it should be handled as a Category III waste. If it is nonhazardous, it may be handled as a non-hazardous waste. For liability purposes, all test results should be retained for at least ten years.
Hazardous Waste Handling - Quantity of Hazardous Waste
When determining the amount of hazardous waste, generators must account for all hazardous waste generated on the site, including non-abatement waste that may be hazardous.
Under RCRA, if less than 220 pounds/month of hazardous abatement waste is produced, then the generators automatically qualify as "conditionally exempt, small-quantity generators." This is typically the amount of waste that would result from work done on a single-family dwelling. This waste, at a minimum, must be disposed in a state-licensed or state-permitted solid waste management facility or in a hazardous waste disposal facility.
In addition, no more than 2,200 pounds of hazardous waste may be stored at the site at any one time.
The hazardous waste generated from a multifamily housing abatement project will typically exceed the 220 pound/month limit. As a result it will be subject to the RCRA hazardous waste handling and management requirements. These include an accumulation time limit, packaging and shipping requirements, land disposal restrictions, and recordkeeping requirements. In addition, an EPA identification number must be obtained and a hazardous waste manifest must be completed before the waste is shipped off-site.
TCLP tests can be performed on debris from pilot projects or on debris generated by identical abatement procedures in identical structures to indicate whether the waste will be considered hazardous.
Before the work begins, it is important to contract with a hazardous waste management company that has an EPA identification number for the transportation and management of hazardous waste, and to secure cost estimates for waste transportation, treatment to meet land disposal restrictions, storage, and disposal.
Hazardous Waste Handling - Lead-Based Paint Waste From Public Buildings
For nonresidential public buildings such as schools and libraries, all waste from lead hazard control efforts must be handled using the procedures for abatement waste. This waste may be similar to residential waste, however, these buildings are not "households." That means the household waste exemption does not apply.
Hazardous Waste Handling - More Than 220 Pounds Per Month
The requirements that apply when more than 220 pounds/month of hazardous waste is produced are given in 40 CFR Part 262.
Sites producing quantities between 220 and 2,200 pounds/ month are referred to as "small-quantity generators," and are considered conditionally exempt.
Sites producing amounts greater than 2,200 pounds/month are called "large-quantity generators."
Some requirements may differ for small and large-quantity generators. However, the following apply to both:
- An EPA identification number must be obtained.
- The are limits on on-site accumulation of hazardous wastes
- There must be a waste minimization plan
- Hazardous waste manifest forms must be completed before transport of waste.
- Must comply with land disposal restriction notification and certification requirements.
- Records must be retained.
Hazardous Waste Handling - EPA Identification Number (40 CFR 262.12)
An EPA generator ID number must be obtained for each site. This number is used to maintain a nationwide tracking system for hazardous waste. All hazardous waste generators, transporters and treatment, storage, and disposal facilities must have EPA ID numbers.
An ID number is obtained by contacting your state hazardous waste management agency or the nearest EPA regional office.
Hazardous Waste Handling - Onsite Accumulation of Waste
Under certain conditions, small-quantity generators may accumulate up to 13,200 pounds of hazardous waste for 180 days. This may be extended to 270 days, if the treatment, storage, or disposal site is more than 200 miles away.
Large-quantity generators may not store hazardous waste on-site for more than 90 days. Under temporary, unforeseen, and uncontrollable circumstances, an extension of up to 30 days may be granted. Storing hazardous waste longer than the allowable time periods can result in fines, and the sites will be considered storage facilities requiring RCRA regulation.
When storing hazardous waste on-site the following requirements must be met:
- Labeling Of Hazardous Waste: Both small and large quantity generators must label stored hazardous waste properly and indicate the accumulation start date on the label.
- Emergency Plan: Small quantity generators must have in their possession the basic safety information to be used during an emergency. Large-quantity generators must have a written emergency plan.
- Personnel Training: Small quantity generators must ensure that their employees are familiar with emergency spill and accident procedures. Large quantity generators must have an established training program.
Hazardous Waste Handling - Waste Minimization Plans
Both small and large quantity hazardous waste generators must have written waste minimization plans. However, there are no specific requirements for these plans. The following are some recommendations for activities that should be included in a waste minimization plan:
- Recycle, or otherwise separate and dispose of, window glass and unpainted solid waste.
- Clean plastic sheeting used for containment by removing lead paint and dust.
- Avoid mixing hazardous and nonhazardous waste.
- Recycle lead-based hazardous waste at a permitted lead smelter when appropriate.
- Seek a waste management contractor with experience in waste minimization.
- Consolidate paint chips.
Hazardous Waste Handling - Packaging For Transportation
The Department of Transportation's (DOT's) has established hazardous materials transport packing methods that prevent leakage of waste or the release of dust during transport. The DOT regulations also mandate placarding of the packaged waste to identify its characteristics and dangers. Hazardous waste transporters or disposal facilities can provide advice on appropriate packaging methods.
Hazardous Waste Handling - Selecting a Transporter
Since generators are liable for improper hazardous waste handling, it is critical to select a hazardous waste transporter and a management facility that has the proper ID numbers and necessary permits.
Hazardous waste generators should get the answers to the following questions about waste transportation companies as well as disposal facilities, before signing a contract:
- Do they have an EPA ID number?
- Have they successfully completed similar hazardous waste handling or disposal jobs?
- Can they supply references? How do the references describe their service?
- How long have they been in business?
- Has the firm been cited by EPA or state agencies for any environmental violations?
- How much waste are they capable of handling over a given period of time?
- Can they handle both solid and hazardous wastes?
- Are they willing and able to perform special hazardous waste handling, such as covering vehicles during transport?
- Do they have experience dealing with RCRA land disposal restrictions?
- Do they have insurance?
Generators should also check with other generators, trade associations, the Better Business Bureau, and the Chamber of Commerce regarding the firm's qualifications.
Written contracts with transporters and management facilities, at a minimum, should provide for the following items:
- Scope of work and the schedule, including the waste-segregation procedures to be used
- Testing and analysis of waste.
- Emergency procedures.
- Cost estimates and the handling of overruns.
- Payment procedures.
- Liability and responsibility for claims.
- Quality assurance plan.
