7.2 Hazardous waste management

Hazardous waste management is crucial for protecting human health and the environment. This topic covers the identification, handling, and disposal of dangerous materials generated by industries and households. Understanding proper techniques is essential for minimizing risks and complying with regulations.

From defining hazardous waste to exploring treatment methods, this section examines key aspects of managing these materials safely. It also covers important regulations like RCRA and CERCLA, which govern hazardous waste practices in the United States.

Hazardous Waste Characteristics and Classifications

Defining Hazardous Waste

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• Hazardous waste is defined as waste with properties that make it dangerous or capable of having a harmful effect on human health or the environment
• Examples of hazardous waste include discarded chemicals, batteries, pesticides, and electronic waste

Characteristics of Hazardous Waste

• Ignitability: Waste with a flashpoint less than 60°C (140°F), capable of causing fires under certain conditions (e.g., solvents, paint thinners)
• Corrosivity: Waste with a pH less than or equal to 2 or greater than or equal to 12.5, capable of corroding metal containers (e.g., battery acid, cleaning fluids)
• Reactivity: Waste that is unstable under normal conditions, reacts violently with water, or generates toxic gases (e.g., cyanide plating waste, explosives)
• Toxicity: Waste that is harmful or fatal when ingested or absorbed, as determined by the Toxicity Characteristic Leaching Procedure (TCLP) (e.g., lead-based paint, mercury-containing waste)

EPA Classifications of Hazardous Waste

• Listed wastes: Generated from common manufacturing and industrial processes, divided into F-list (non-specific sources), K-list (specific sources), P-list (discarded commercial chemical products), and U-list (toxic wastes)
• Characteristic wastes: Defined by their properties, including ignitability, corrosivity, reactivity, and toxicity
• Examples of listed wastes include spent solvents (F-list), wastewater treatment sludges from electroplating operations (K-list), and discarded pesticides (P-list and U-list)

Hazardous Waste Generator Categories

• Large quantity generators (LQGs): Generate ≥ 1,000 kg of hazardous waste or > 1 kg of acutely hazardous waste per month
• Small quantity generators (SQGs): Generate between 100 and 1,000 kg of hazardous waste per month
• Very small quantity generators (VSQGs): Generate ≤ 100 kg of hazardous waste and ≤ 1 kg of acutely hazardous waste per month
• Generator categories determine the level of regulation and requirements for hazardous waste management (e.g., storage time limits, emergency preparedness)

Hazardous Waste Handling and Disposal

Proper Handling of Hazardous Waste

• Segregation: Separating hazardous waste by type and compatibility to prevent dangerous reactions (e.g., storing acids separately from bases)
• Labeling: Clearly identifying the contents, hazards, and accumulation start date on each container
• Packaging: Using appropriate containers (e.g., DOT-approved drums) and ensuring proper closure to prevent leaks and spills during transport

Storage Requirements for Hazardous Waste

• Secondary containment: Providing a secondary barrier (e.g., spill pallets, berms) to contain leaks and spills from primary containers
• Proper ventilation: Ensuring adequate ventilation to prevent the accumulation of toxic or flammable vapors
• Separation of incompatible wastes: Storing incompatible wastes in separate areas or with physical barriers to prevent mixing
• Storage time limits: LQGs can store waste on-site for up to 90 days, while SQGs can store waste for up to 180 days
• Weekly inspections: Regularly inspecting storage areas for leaks, spills, and deterioration of containers

Treatment Methods for Hazardous Waste

• Physical treatment: Using physical processes to remove or separate contaminants, such as filtration (e.g., removing solids), sedimentation (e.g., settling out suspended particles), and adsorption (e.g., using activated carbon to remove organic compounds)
• Chemical treatment: Altering the chemical composition of the waste to reduce toxicity or reactivity, such as neutralization (e.g., adjusting pH), oxidation (e.g., breaking down organic compounds), and reduction (e.g., converting metals to less toxic forms)
• Biological treatment: Using microorganisms or plants to degrade or absorb contaminants, such as bioremediation (e.g., using bacteria to break down petroleum hydrocarbons) and phytoremediation (e.g., using plants to extract heavy metals from soil)

Disposal Methods for Hazardous Waste

• Landfilling: Burying waste in specially designed and monitored facilities with liners, leachate collection systems, and groundwater monitoring (e.g., hazardous waste landfills)
• Incineration: Combusting waste at high temperatures (typically > 1,000°C) to destroy organic compounds and reduce volume, with air pollution control devices to minimize emissions (e.g., rotary kiln incinerators)
• Deep well injection: Injecting liquid waste into deep underground formations (typically > 1,000 m) that are geologically isolated from drinking water sources (e.g., injecting treated wastewater from oil and gas production)

Regulations for Hazardous Waste Management

Resource Conservation and Recovery Act (RCRA)

• RCRA is the primary federal law governing hazardous waste management in the United States
• Establishes a cradle-to-grave system for tracking hazardous waste from generation to disposal
• Requires generators to obtain an EPA identification number and maintain records of waste generation, treatment, storage, and disposal
• Sets standards for hazardous waste treatment, storage, and disposal facilities (TSDFs)

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

• CERCLA, also known as Superfund, provides funding and authority for the cleanup of hazardous waste sites
• Establishes liability for parties responsible for the release of hazardous substances into the environment
• Requires the reporting of releases of hazardous substances above certain thresholds
• Enables the EPA to conduct emergency response actions and long-term remedial actions at contaminated sites

Occupational Safety and Health Administration (OSHA) Standards

• OSHA sets standards for worker protection during hazardous waste operations and emergency response (HAZWOPER)
• Requires employers to develop and implement a written safety and health program for hazardous waste operations
• Mandates training for workers involved in hazardous waste operations, including initial training and annual refresher training
• Specifies requirements for personal protective equipment (PPE), medical surveillance, and decontamination procedures

Department of Transportation (DOT) Regulations

• DOT regulates the transportation of hazardous waste, including labeling, packaging, and placarding requirements
• Requires the use of shipping papers and manifests to document the movement of hazardous waste
• Sets standards for the design, construction, and testing of hazardous waste containers and vehicles
• Mandates training for hazardous waste transporters, including function-specific training and security awareness training

International Guidelines for Hazardous Waste Management

• The Basel Convention regulates the transboundary movement of hazardous waste, aiming to minimize waste generation and ensure environmentally sound management
• The Stockholm Convention on Persistent Organic Pollutants (POPs) aims to eliminate or restrict the production and use of POPs, which are toxic, persistent, and bioaccumulative substances
• The Rotterdam Convention promotes shared responsibility in the international trade of certain hazardous chemicals, requiring prior informed consent from importing countries
• The Minamata Convention on Mercury aims to protect human health and the environment from the adverse effects of mercury, including the phase-out of certain mercury-containing products and processes

Hazardous Waste Management Plan Design

Waste Characterization Study

• Identify the types and quantities of hazardous waste generated through a comprehensive waste characterization study
• Determine the physical, chemical, and biological properties of each waste stream
• Evaluate the regulatory status of each waste stream (e.g., listed vs. characteristic waste)
• Estimate the annual generation rates and storage requirements for each waste stream

Waste Minimization Strategies

• Implement source reduction techniques to minimize the generation of hazardous waste, such as process optimization, material substitution, and inventory control
• Evaluate opportunities for recycling and reuse of hazardous waste, such as solvent recovery and metals reclamation
• Consider product substitution to replace hazardous materials with less toxic alternatives
• Set waste minimization goals and track progress through regular audits and reporting

Waste Segregation and Labeling Procedures

• Develop a waste segregation plan based on the compatibility and regulatory status of each waste stream
• Provide clear instructions for proper waste segregation at the point of generation
• Implement a standardized labeling system for hazardous waste containers, including the waste name, hazard class, accumulation start date, and generator information
• Train employees on proper waste segregation and labeling procedures

Storage Area Design and Management

• Identify appropriate storage areas for each type of hazardous waste, considering compatibility, security, and environmental protection
• Select suitable containers for each waste stream, such as DOT-approved drums, cubic yard boxes, and portable tanks
• Establish inspection and maintenance schedules for storage areas and containers, including weekly inspections and annual integrity tests
• Implement secondary containment measures, such as spill pallets and berms, to prevent releases to the environment

Treatment and Disposal Options

• Evaluate on-site treatment options based on the characteristics of each waste stream, such as neutralization, precipitation, and solidification/stabilization
• Identify appropriate off-site treatment and disposal facilities based on the waste type, regulatory requirements, and transportation costs
• Develop procedures for the proper packaging, labeling, and manifesting of hazardous waste shipments
• Conduct due diligence on third-party treatment and disposal facilities to ensure compliance and environmental performance

Emergency Response Procedures

• Develop a comprehensive emergency response plan for hazardous waste incidents, including spills, leaks, fires, and explosions
• Identify potential hazards and release scenarios associated with each waste stream and storage area
• Establish procedures for incident reporting, containment, and cleanup, including the use of spill kits and personal protective equipment (PPE)
• Train employees on emergency response procedures and conduct periodic drills to test the effectiveness of the plan

Employee Training Programs

• Implement a comprehensive training program for employees involved in hazardous waste management, including waste generators, handlers, and supervisors
• Provide initial training on hazardous waste regulations, company policies, and job-specific procedures
• Conduct annual refresher training to reinforce key concepts and update employees on regulatory changes
• Maintain training records, including the date, content, and attendance of each training session

Record-Keeping and Reporting

• Establish a system for maintaining accurate and complete records of hazardous waste generation, treatment, storage, and disposal
• Develop procedures for preparing and submitting required reports, such as biennial reports, exception reports, and annual progress reports
• Maintain copies of manifests, land disposal restriction (LDR) forms, and other shipping documents
• Implement an electronic record-keeping system to facilitate data management and regulatory compliance

Audits and Continuous Improvement

• Conduct regular internal audits of the hazardous waste management program to assess compliance and identify areas for improvement
• Develop corrective action plans to address any deficiencies or non-conformances identified during audits
• Establish a process for continuous improvement, including the setting of performance goals, tracking of key performance indicators (KPIs), and implementation of best management practices (BMPs)
• Engage employees in the continuous improvement process through suggestion programs, problem-solving teams, and recognition of outstanding performance