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DEP Hazardous Waste Program. Why a need for regulations. Following WWII, manufacturing was booming and large volumes of toxic waste were generated. The waste was disposed on ground or burned without controls Problems started developing Water polluted Air pollution Dying species
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Why a need for regulations Following WWII, manufacturing was booming and large volumes of toxic waste were generated. The waste was disposed on ground or burned without controls • Problems started developing • Water polluted • Air pollution • Dying species • Health problems • Several sites became legendary • They help cause the creation of environmental protection laws
Some sites became legendary • Love Canal • Cuyahoga River • Valley of the drums • Times Beach
Love Canal, Niagara NY • 15 acres along Niagara River • 1890, constructed 3000ft by 60ft canal – went bankrupt • 1920, purchased by Hooker Chemical • 1920 – 1953, used as a landfill by Hooker Chemical and the city. • 1953, sold to the city’s board of education ($1.00) • Deed stated not to dig within the area of the canal • 1954, Board of Ed built schools and housing (1000) • Disregarded warning on deed • Chemicals seeped into basements and storm drains • Drums popping up in ball fields and yards • Residents started complaining • 1978, years of residents complaints forced evacuation of several city blocks • 2010, a few city blocks still restricted
Cuyahoga River, Cleveland OH • 1936 – 1969, used as an industrial sewer • Numerous fires from waste chemicals floating on the river • Referred to as the “dead river”. • No signs of life in the river • 1952, large fire damaging boats and buildings • 1969, last large fire • Earth movement and Clean Water Act of 1970 put an end to industrial dumping
Valley of the Drums, Brooks KY • 13 acre site, gravel pits owned by A. L. Taylor • 1967 – 1977, took in over 38,000 drums of waste from area paint and coating manufacturers • 11,000 drums buried and/or burned • 27,000 drums stored on the soil • 1980, EPA begins cleanup
Times Beach, MI • Small town of 2000 with 21 miles of un-paved roads • 1971 – 1972, Sixty two horse die at area stables. • Russell Bliss was hired to sprayed waste oil for dust control • 1972 – 1976, Times Beach hires Russell Bliss • Spray waste oil on roads for dust control • 1977, EPA begins investigation into horse deaths • Oil came from NE Pharmaceutical and Chemical Corp • Made Agent Orange (2,4,5T and 2,4D) • Contains dioxin • Russell Bliss picked up waste oil • 1983, EPA purchases the town and evacuates residents • 1996 – 1997, incinerate 26,000 tons of dioxin contaminated soil • from Times Beach and local stables • Current – Town park (still polluted)
Hazardous Waste Laws • Title 40 of the Code of Federal Regulations, Parts 260 – 280 Cradle to Grave “you generate a waste, you own it forever”
Enforcement • Civil – • $25,000 per day per violation • Criminal – • $50,000 per day per violation • Up to five years in prison
Civil Cases • Home Depot (9 stores) • $425,000.00 & corporation wide compliance program in CT • Light Sources • $857,000.00 & clean up mercury release • Kaman Aerospace • $420,000.00
Criminal • Phoenix Products • $250,000.00 • Probation • Mike Fretaus and U Haul • $60,000.00 • 1 year prison • Sound Mfg • $100,000.00 and $1,000,000.00 cash bond (clean up) • 3 years prison (suspended on appeal) • 1 year home confinement • Clean up completed in January 2010
Hazardous Waste Management Regulations As a generator of HW, you must: • Determine if each solid waste is HW • Properly manage & store the waste • Inspect waste & emergency response equipment • Plan for Emergency responses • Train employees • Preparing for off-site shipment • Keep records
Determination if Waste is Hazardous Can use knowledge of the chemicals and process that generates the waste, analytical testing, or both • 1st – is the waste a solid waste • i.e. is it discarded • 2nd – is the solid waste excluded • If no, • 3rd – is the solid waste a hazardous waste
What’s a Solid Waste • Discarded material – • Spent material • Sludge • By-product • Commercial chemical product • Scrap metal That’s discarded – • Burned/incinerated • Recycled/reclaimed • Accumulated speculatively • Used in a manner constituting disposal* *placed on land or water
Solid Waste Example disposed discarded reused burned
What’s a Hazardous Waste A hazardous waste is a solid waste that is • listed as a hazardous wastes and/or • Exhibits a characteristic of a hazardous waste • Two sub-categories • Used oil • Universal waste
Exclusions • Waste fuel reused as a fuel • gasoline sent off-site for fuel blending • Effective substitute for a commercial chemical product, provided the product is not used in a manner constituting disposal or burned. • Spent plastic bead blast media (removing paint from air craft) • Used in water resistant concrete block (Sealtech block) • Applied above ground – not solid waste • Applied on the ground – is solid waste • Fly ash used to make zinc powder (electric plant emission control) • Used for galvanizing – not solid waste (US Zinc) • Used in plant food – is solid waste (Bay Zinc)
Waste Codes • All hazardous wastes are identified by a “waste code” • (except for used oil and universal waste) • The listed waste codes • F, K, U, P • (Example – F001 spent halogenated solvent) • The characteristic waste codes • D waste codes • (Example – D008 lead)
Reasons for Waste Codes • National statistical information • Observe trends in waste generation • Pollution prevention programs • Eliminate/reduce large volume waste types • Hazard recognition • Waste codes represent specific hazards
Listed Hazardous Waste • Three Lists (developed in 1976) • Non-specific source list • Waste from a process that any business can do • Specific source list • Waste from specifically listed types of businesses • Commercial chemical product list • Waste that is a specifically listed type of chemical product
Facts about Listed HW Reasons for Listing Ignitable (I) Corrosive (C) Reactive (R) Acutely Hazardous (H) Toxic (T) Mixture Rule • mixing a listed waste with any other solid waste makes the entire mixture a listed waste! • not dependent on amount (one drop, one gallon, etc). • not dependent on the source (intentional mixing, accidental mixing). • Can cause an inexpensive waste to become more expensive when shipped off-site
Non-specific source“F” Waste Codes Waste from generic sources: F001 – F039 Solvents (F001 – F005) Metal finishing (F006 – F019) Pesticides/wood preservative [dioxin] (F020 - F035)
F001 (T) Spent halogenated solvent used in degreasing • Carb cleaner • Brake cleaner • Contact cleaner • tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1 trichloroethane, carbon tetrachloride, chlorinated fluorocarbons • still bottoms from recovery of spent solvents
F002 (T) the following spent halogenated solvents • tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1 trichloroethane, carbon tetrachloride, chlorinated fluorocarbons • still bottoms from recovery of spent solvents • Paint stripper • Tire cleaner • Lab analysis
Halogens Chemical with the word chlor or fluorin its name Perchloroethylene (1.6) Trichloroethylene (1.46) methylene chloride (1.33) “HEAVIER THAN WATER” IMPROPER TREATMENT = DIOXINS
F003 (I) The following spent non-halogenated solvents • xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether, methyl isobutyl ketone, butyl alcohol, cyclohexanone, methanol • still bottoms from recovery of spent solvents • Paint stripper • Carb cleaner • Brake cleaner • Electric contact cleaner • Lab analysis
F005 (I)(T) The following spent non-halogenated solvents • Carb cleaner • Brake cleaner • Paint stripper • Gasket remover • Electric contact cleaner • Lab analysis • toluene, methyl ethyl ketone, carbon disulfide, isobutanol, pyridine, benzene, 2-ethoxyethanol, 2-nitropropane • still bottoms from recovery of spent solvents
Specific Source“K” Waste Codes Waste from specifically identified industrial sources: K001 – K160 Refineries (K048, K170) Pharmaceutical (K084, K101) Foundry (K061, K069) Explosives (K044, K45)
Commercial Chemical Product“U” & “P” Waste Codes Solvents Pesticides Pharmaceuticals Chemical ingredients
Commercial Chemical Product Waste • Waste chemical product that is unused • pure or technical grade of chemical • sole active ingredient • no longer needed or wanted • off-specification • old/outdated
Commercial Chemical Product Waste • Spilled virgin chemical products
Commercial Chemical Product “P” Listed Waste “acutely hazardous” P001 - P205(H) • Methyl parathion P071 • Nicotine P075 • Epinephrine P042 • Methyl isocyanate P064 • Empty containers of “P” listed materials not triple rinsed • Rinsate from rinsing empty containers
Commercial Chemical Product“U” Listed Waste U001 – U411(T) • Acetone U002 (I) • Methylene chloride U080 • 2,4-D U240 • Isopropanol U140 (I) • Methyl ethyl ketone U159 (I) • DDT U061 • Warfarin U248 • Acetyl chloride U006 (C, R)
Characteristic Hazardous Waste Four types “D” waste codes • Ignitable (D001) • Corrosive (D002) • Reactive (D003) • Toxicity Characteristic (D004-D043)
Some Facts about Characteristic Waste • Some characteristics are based on physical properties • flash point • pH (acid or alkali) • compressed or pressurized gases • oxidizer
Some Facts about Characteristic Waste • Some characteristics are based on concentration limits • milligrams per liter (mg/L) • test method “Toxicity Characteristic Leaching Procedure” • limits range between 0.008 to 400 mg/L note: one percent (1%) equals 10,000 ppm
Some Facts about Characteristic Waste • Everything discarded, must determine if it exhibits a characteristic of a hazardous waste • Paper (masking materials, sandpaper, coveralls) • Tires • Chemicals (used & un-used) • Light bulbs/tubes • Electronic devices (computers, cell phones, TV) • Scrap metal • Paint (liquid or solid) • Contaminated debris (paint brushes, speedi dry, dust)
Ignitable Characteristic“D001” • Liquid with a flash point less than 140 Deg. F • Oxidizers • Ignitable compressed gases • Not a liquid – fire through friction, moisture, spontaneous chemical change, & burns vigorously and persistently
Ignitable Examples • Liquid – flash point less than 140 • Mineral spirits • Gasoline • Contact cement • Aerosol paint • Oxidizers • Nitric acid • Fiberglass resin hardener (MEKP) • Ignitable compressed gas • Acetylene • Propane • Not a liquid • Aluminum fines • Magnesium
Corrosive Characteristic“D002” • Aqueous liquid, pH less than 2 or greater than 12.5. • A liquid that corrodes steel at greater than 0.025 inches per year at 130 degrees F.
Corrosive Examples • pH less than 2 • Nitric acid (lab) • Sulfuric acid (battery) • Muriatic acid (concrete) • Hydrofluoric (aluminum) • pH greater than 12.5 • Potassium hydroxide (oven) • Sodium hydroxide (drain) • Ammonium hydroxide (cleaner) • Sodium hypochlorite (bleach)
Reactive Characteristic“D003” Normally unstable Reacts violently with water or forms toxic fumes or vapors Capable of detonation or explosion when heated under confinement or initiating force
Reactive Examples • Explosives • Fire works • Ammunition • Air bags • Compressed cylinders • Aerosol cans • Propane cylinders • Metal fines • Aluminum • Lithium • Batteries with a charge
Toxic Characteristic“D004 – D043” • 39 elements and compounds • cause damage to tissue, impair CNS, cause severe illness or death when ingested, inhaled, or absorbed. • based on concentration limits (mg/L). • testing using Toxicity Characteristic Leaching Procedure (TCLP).
Toxic Characteristic Waste Code Contaminant Limit mg/L D004 arsenic 5.0 D005 barium 100.0 D006 cadmium 1.0 D007 chromium 5.0 D008 lead 5.0 D009 mercury 0.2 D010 selenium 1.0 D011 silver 5.0 D012 endrin 0.02 D013 lindan 0.4 D014 methoxychlor 10.0 D015 toxaphene 0.5 D016 2,4-D 10.0
Toxic Characteristic Waste codeContaminantLimit mg/L D017 2,4,5-TP 1.0 D018 benzene 0.5 D019 carbon tetrachloride 0.5 D020 chlordane 0.03 D021 chlorobenzene 100.0 D022 chloroform 6.0 D023 o-cresol 200.0 D024 m-cresol 200.0 D025 p-cresol 200.0 D026 cresol 200.0 D027 1,4-dichlorobenzene 7.5
Toxic Characteristic Waste codeContaminantLimit mg/L D028 1,2-dichloroethane 0.5 mg/L D029 1,1-dichloroethylene 0.7 mg/L D030 2,4-dinitrotoluene 0.13 mg/L D031 heptachlor 0.008 mg/L D032 hexachlorobenzene 0.13 mg/L D033 hexachlorobutadiene 0.5 mg/L D034 hexachloroethane 3 mg/L D035 methyl ethyl ketone 200 mg/L D036 nitrobenzene 2 mg/L D037 pentachlorophenol 100 mg/L D038 pyridine 5 mg/L D039 tetrachloroethylene 0.7 mg/L D040 trichloroethylene 0.7 D041 2,4,5 trichlorophenol 400.0 D042 2,4,6 trichlorophenol 2.0 D043 vinyl chloride 0.2