Common Hazardous Waste Management Mistakes (Part 1): Hazardous Waste Identification

When it comes to continuous improvement, the primary focus of the majority of industrial facilities is production. This type of industrial management is a sensible approach, as production can have the greatest impact on the facility’s profitability. However, singularly focusing on products generated by a facility while ignoring waste generation can be costly not only from a financial perspective but also from a regulatory compliance perspective as well.

In order to decrease the possible risks associated with improper waste management, it is beneficial to examine some of the more common mistakes made throughout industry. This ensures that a facility has a solid foundation from which to build out a waste management program that covers the proper handling of all of its waste streams.

Mistake #1: Not conducting a complete Hazardous Waste Determination

Waste cannot be properly managed and disposed of without classification. To fully characterize all of the waste streams at a facility, the facility must document all of its streams and then determine which of those streams might be classified as Hazardous Waste. Sometimes this can be a simple task and the type of waste generated is listed under the Resource Conservation and Recovery Act (RCRA) as a hazardous waste or the waste exhibits one of the hazardous waste characteristics: ignitability, corrosivity, reactivity, or toxicity. In these cases, the facility can cite generator knowledge for classification of a particular waste based on knowledge of the material’s composition, characteristics, or SDS.

However, in a lot of cases, the characteristics or composition of a waste is not readily apparent. In these cases, a Toxicity Characteristic Leaching Procedure (TCLP) needs to be completed. The TCLP simulates what pollutants would leach out of a particular waste if it was disposed of directly into a landfill. This is completed alongside measurement of the pH and the flash point of the waste to check for corrosivity and ignitability respectively. After these analyses are conducted, you will have a complete picture of whether or not your waste is hazardous. Any and all records used in this determination, whether these are in the form of analytical reports or SDS’s, should be maintained for a minimum of 5 years.

Mistake #2: Inaccurate determination of Hazardous Waste Generator Status

The Hazardous Waste Generator Status of a facility is extremely important as the requirements that have to be followed significantly change from one status to the next. A facility can either be:

Hazardous Waste Generator Status Qualification
Very Small Quantity Generator (VSQG) ≤ 220 lbs generated in a calendar month
Small Quantity Generator (SQG) > 220 lbs and ≤ 2,200 lbs generated in a calendar month
Large Quantity Generator (LQG) ≥ 2,200 lbs generated in a calendar month

The important word to focus on above is “generated”. Typically, facilities tend to review Hazardous Waste Manifests as the manifests list the amount of waste that was disposed of. The issue with this is that this does not directly tell you how much was generated per calendar month. A facility may dispose of 3,000 lbs of hazardous waste but a facility needs to know how long it took to generate that amount of waste. If the facility generated that amount in a month, then it would be a LQG. If the facility took 10 months to generate the waste, the facility would be a SQG. There is a significant difference in the compliance requirements for these two classifications.The best and most accurate method for determining a Generator Status is to employ waste tracking. Every time a waste is generated during a month, the amount should be recorded so it can be totaled at the end of the month. Realistically, this tracking should continue throughout the year to account for seasonal changes in production and waste generation. The facility should default to selecting a Generator Status that represents the highest amount of generation for one calendar month out of the year. Continuing to track waste after this initial determination is also a good idea, as this can capture any changes in waste generation as a result of the introduction of new processes or process changes at the facility.

Mistake #3: Not submitting or updating a Site Identification (8700-12) Form

After a facility determines if hazardous waste is generated, how much hazardous waste is generated, and their generator status, the facility must then submit a Site Identification (8700-12) Form. This form is used to identify a particular facility, its generator status, the types of hazardous waste generated, and site contact information. The form can be submitted either to the state environmental agency or electronically using the EPA’s RCRA Info Web Portal. Both Small Quantity and Large Quantity Generators are required to submit a Site Identification Form. Very Small Quantity Generators can voluntarily choose to submit a Site Identification Form but are not required to. After submittal of the Site Identification Form, the facility will receive an EPA ID Number, which will stay with the facility in perpetuity. The facility retains this EPA ID Number even through name and ownership changes, although a new Site Identification Form should be submitted to indicate that a change has occurred. This is an important distinction to make as the Site Identification Form should be treated as a living document and one that needs to be updated on a consistent basis as changes can occur with a facility’s generator status and the types of hazardous waste generated over time.

What to do next?

If you find that your facility may need to consider addressing Waste Management issues onsite, Conversion Technology, Inc. (CTI) can provide consulting assistance to ensure that all of your issues and questions are addressed. CTI has had over 30 years of experience working with industrial facilities to assist in proper management of waste. This includes onsite Waste Management Audits, preparation of Hazardous Waste Reports, preparation of Hazardous Waste Contingency and Waste Minimization Plans, preparation of Hazardous Waste Fees, preparation of Site Identification Forms, and provision of Hazardous Waste Training. We will be happy to assist you with whatever consulting services you are in need of.

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