environmental controls

THE OPERATIONAL BENEFITS

IN DELISTING HAZARDOUS WASTES

GENERATED BY THE FINISHING INDUSTRY

BY WILLIAM R. MILLER III, PH.D. SENIOR CLIENT PROGRAM MANAGER,

SHAW ENVIRONMENTAL & INFRASTRUCTURE, COROLLA, N.C.

The U.S. Code defines a hazardous waste as:(1) …a solid waste, or combination of solid wastes, which because of its quantity,concentration, or physical, chemical, or infectious characteristics may—a. cause, or significantly contribute to, an increase in mortality or anincrease in serious irreversible, or incapacitating reversible, illness;orb. pose a substantial present or potential hazard to humanhealth orthe environment when improperly treated, stored, transported,or disposed of, or otherwise managed.iFurther, the Resource Conservation and Recovery Act or RCRA defineshazardous wastes as:(1) Wastes that are contained on an EPA List ( e.g., electroplating wastes likeF006, F009, and F019), or(2) Wastes that are characteristically hazardous (e.g., corrosive, ignitable,reactive), or(3) Wastes that are mixtures of hazardous wastes and solid wastes (e.g., a mixtureof F019 wastes and filters), or(4) Wastes that are derived from hazardous wastes (e.g., wastewater treatmentplant sludge from a process that meets the definition of a F006 waste).iiMetal finishing processes frequently generate objectionable by-productsthat might include, for example, air emissions, wastewater treatment plantsludges, characteristically hazardous corrosive wastes, organic halogenatedsolvents, and cyanide. An overview of the wastes typical of the metal finishingindustry is provided in Table 1.It is not unusual for waste disposal to be one of the more costly operatingexpenses at a metal finishing plant. Managing hazardous wastes at a plant isalso a very resource-intensive activity. Tasks such as labeling, storing, manifesting,training, signage, spill response, closure, and long-term liability are allintegral to the proper management of hazardous wastes. The most commonwaste codes applicable to the metal finishing sector are F-Codes F006, F009,and F019. F006 and F009 deal with electroplating while F019 pertains to thechemical conversion coating of aluminum. It is not uncommon for facilities to spend well over $100,000/year dealing with these F-coded wastes. Disposal

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Figure 1. Mass Balance Approach Used for an Engineering Analysis

costs, including all the tasks referenced above—plus transportation and statefees—can run to well over $200/ton.One way around these high disposal costs is to go through the process ofexcluding or delisting the waste from consideration as hazardous. Regulationsat 40 CFR 260.22 outline in general what is required to delist a waste. Majorcomponents of a delisting include: identifying constituents of concern, preparationof a sampling and analysis plan, preparation of a quality assurance projectplan, close coordination with the regulatory authority having jurisdiction(either an EPA Region or a State agency), and publication of proposed andfinal rules in the Federal Register.

Hazardous Waste Delistings. Delistings are primarily handled out of an EPARegion with Regions 4, 5, and 6 performing the most delistings. Some states,however, have jurisdiction to perform delistings (e.g., Georgia, Indiana, andPennsylvania) and in such cases you will want to coordinate your activitieswith the state environmental agency.There are a number of resources you will want to review prior to undertakinga hazardous waste delistings. A few of these are listed in Table 2

Major Steps in a Delisting. There are at least 12 (twelve) major steps in a typicaldelisting. These major steps, along with some information on timing, areincluded in Table 3. It is assumed that close coordination with the controlling regulatory agency will be a part of every step identified in Table 3.

Steps 1 and 2 — IdentifyingConstituents of Concern.

There is perhaps no otherstep in securing a delistingthat is more important thanidentifying the constituentsof concern (COC). The processinvolves reviewing anumber of regulatory lists(e.g., Appendix VIII andAppendix IX)iii to determineif a given constituentis in the subject waste. Forone list of chemicals in particular,Appendix VIII, it isdifficult to identify all of thechemicals on the list becauseeither standard methods donot exist, or the procedureis incredibly expensive, orthe method will not workin the matrix of the wastesample. Either way, it will beimportant to establish withthe regulatory authority thetotal universe of chemicalsto include in your review.One thing the petitioner(the entity conducting thedelisting is termed the petitioner)should keep in mindis that it is your responsibilityto provide a complete andthorough characterizationof your waste. Ultimately,it is not uncommon for thepetitioner and the agency tosettle on analyzing for allconstituents (~ 222 chemicals)on Appendix IX.An important documentthat the petitioner mustprepare is the Sampling andAnalysis Plan (SAP). TheSAP lays out specificallywhat will be analyzed for,the number of samples, theanalytical techniques, and data analysis methods that will be used. The SAP is a livingdocument in thatthe petitioner and the agency will probably go through several iterations beforea final SAP will be produced. You cannot proceed with the overall process untilyou have an agreed upon SAP.There are lists of chemicals that are expected to characterize certain wastes(e.g., petroleum refinery wastes) and those chemicals should be incorporatedinto your SAP.

Steps 3, 4, and 5 — Engineering Analysis, Generator Knowledge and Identifying

Analytes. There are several additional ways to modify the COCs list. One wayis to conduct an engineering analysis that essentially involves conducting amass balance around major process units at the facility undergoing the delisting.This is typically done by using a plant’s chemical management system toassemble the list of potential inputs to a process. Essentially you take a processunit and treat it as a black box with chemical inputs, and product, and wasteoutputs. Material Safety Data Sheets (MSDSs) are extremely useful in conductingthis phase of the analysis. By lining up the constituents, as displayed onan MSDS, you can approximate a mass balance around a given process unit.An example of this is provided in Figure 1.As with the characterization of any RCRA waste, the petitioner can use generatorknowledge to add to or subtract from the COC list. Frequently, generatorknowledge is the best type of information to use in making a determinationas to what to test for or what not to test for. For example, a person familiarwith a plant’s layout will likely be able to know quite quickly rather or not aparticular waste flows into a sewer pipe that eventually makes it to the WWTP.You are now at a point where the list of COCs should be fairly complete andyou have identified all analytes that may be in the waste.

Steps 6 and 7 — Select Analytical Methods and Prepare QAPP. The standardreference for collecting and analyzing waste samples is the series of some200 methods referred to as SW 846. iv This again is a very important pointof coordination with the agency so that everyone is on the same page when itcomes to not only what is being analyzed for but how it will be determined.What method is selected can frequently determine the sensitivity of the finalanalytical result. For example, you would want to select a method that had areporting limit of 0.001 mg/l over one that had a limit of 0.1 mg/l if the pointfor comparison from the risk assessment model (see later section on the useof the DRAS model) was 0.01 mg/l.In conjunction with selecting the analytical methods it is also very importantto decide upon the quality assurance and quality controls that will accompanyeach piece of data. A Quality Assurance Project Plan (QAPP) describesthe activities of an environmental data operations project involved with theacquisition of environmental information whether generated from direct measurementsactivities, collected from other sources, or compiled from computerizeddatabases and information systems.v The QAPP documents the results ofa project’s technical planning process, providing in one place a clear, concise,and complete plan for the environmental data operation and its quality objectivesand identifying key project personnel.

Steps 8 and 9 — Data Collection and Analysis. The SAP will specify the what,where, and how of collecting representative waste samples. The term representativehere is very important in that above all else the samples collected need to trulyrepresent the waste. Factors such as waste variability over time, productionvariables, waste treatment variability, and potential for system upsets are allimportant to account for in your approach to data collection.Data analysis can be quite complicated or rather straightforward. Typicallyif you have a large dataset, say, greater than 15 samples, you can perform fairlyrobust statistical evaluations using some rigorous data mining efforts. Theagency should beconsulted beforehand regarding what approach they willendorse regarding data analysis. If your budget will only accommodate a smallsample size, say, six (6) samples, the agency will require that for a given analytethe maximum observed value should be used versus, for instance, a mean valueor some other statistically derived exposure endpoint.Once you have analyzed the data and arrived at an exposure point concentrationfor each of the constituents of concern, you are ready to run theDRAS model. The Delisting Risk Assessment Software (DRAS) model wasdeveloped by EPA Region 6 and improved and modified by Region 5. DRASperforms a multi-pathway and multi-chemical risk assessment to assess theacceptability of a petitioned waste to be disposed into a Subtitle D landfill orsurface impoundment. DRAS executes both forward- and back calculations.The forward calculation uses chemical concentrations and waste volumeinputs to determine cumulative carcinogenic risks and hazard results. Theback-calculation applies waste volume and acceptable risk and hazard valuesto calculate upper- limit allowable chemical concentrations in the waste.vi TheDRAS 3.0 model is available on EPA Region 5’s website. The results of runningthe DRAS model ultimately determine whether you will be able to get yourwaste delisted. If you pass the DRAS model then you incorporate your findingsinto your petition. If you fail the DRAS model (i.e., you exceed a DRAScalculated limit for a given chemical) you need to consult with the agency todetermine next steps.

Steps 10, 11, and 12 — Preparing and Submitting the Petition and Publication in

the Federal Register. The culmination of all of the previous steps is the preparationof a delisting petition. The petition is the petitioner’s main product fordelivery to the agency for review and consideration. The major sections of adelisting petition are outlined in Table 4.A typical delisting petition will be well over 500 pages and frequently over1,000 pages long. The petition is aimed at providing all of the informationnecessary for the agency to make an informed decision regarding the requesteddelisting for the waste.

CONCLUSIONS

For metal finishing plants with significant generation rates of hazardouswastes, it may be wise to look at a hazardous waste delisting as a way toavoid high disposal costs. Once a facility is delisted the subject waste canbe disposed in a Subtitle D landfill where the costs are frequently 4-8 timescheaper. Further, many of the headaches that go along with handling hazard-ous wastes (e.g., manifesting, training, spill response, closure, etc.) go away orare substantially reduced.

REFERENCES

i United States Code at 42 USC ¤ 6903 (5).ii See 40 CFR 261.3iii For Appendix VIII see 40 CFR 261 and for Appendix IX see 40 CFR 264.iv Test Methods for Evaluating Solid Wastes – Physical/Chemical Methodsv Guidance for Quality Assurance Project Plans EPA QA/G-5,EPA/240/R-02/009, December 2002vi User’s Guide Delisting Risk Assessment Software (DRAS) Version 3.0October 2008 U.S. viiEPA Region 5 Chicago, Illinoisvii EPA. 1995b. Metal Plating Waste Minimization. Arlington, VA: WasteManagement Office, Office of Solid Waste.

BIO

Bill Miller III, Ph.D., is a senior client program manager with Shaw Environmental andInfrastructure in Corolla, N.C. He has more than 35 years of environmental engineeringexperience, mostly dealing with delistings. You may reach him by phone at (252) 453-0445 or via e-mail: این آدرس ایمیل توسط spambots حفاظت می شود. برای دیدن شما نیاز به جاوا اسکریپت دارید.