Page 452 - Materials Chemistry, Second Edition

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Hazardous Waste Generator Requirements 423

FIGURE A.12.8 Roll-off con-
tainers. Photo by Theresa M.
Pichtel.

2. (a) Regardless of soil type, groundwater contamination is possible from direct disposal
onto the soil. According to the MSDS, the specific gravity for methylene chloride is 1.33;
it will therefore sink once it contacts the groundwater, making any recovery and remedi-
ation operations slow and expensive.
(b) The deliberate disposal of methylene chloride, an F002 listed RCRA hazardous waste,
to the soil constitutes illegal disposal. The company owner should contact his attorney.
Many states encourage voluntary notification and clean-up of spill and disposal sites rather
than waiting for whistle blowers to report the problem or inspectors to discover them.
3. (a) According to 40CFR 261.2, a solid waste is any discarded material. “Discarded”
means abandoned, recycled, or inherently waste-like. Based on the fact that the drums are
rusted and overgrown with weeds, it is concluded that this material is abandoned and is
therefore a solid waste. Based on company use of toluene, it is further concluded that
these mystery liquids are probably also toluene.
(b) Since the drums were obviously on-site for a long time, it is concluded that the facil-
ity has engaged in 90 day storage without a permit.
(c) It is possible that wastes have been released to the surrounding soil and air. The com-
pany is responsible for assessing the degree of soil contamination; they should arrange
with an outside firm to collect soil samples and analyze them for possible hydrocarbon
contamination.
(d) A waste determination should be carried out to determine the specific composition
of the waste drums.
4. (a) The lab gloves and lab coats are technically hazardous waste according to The
Mixture Rule.
(b) By deliberately allowing the solvent vapors to volatilize, this facility is treating a
hazardous waste. A TSDF permit is required for such an activity.
(c) Workers are potentially being exposed to high levels of hazardous vapors, so this
activity is probably a violation of OSHA regulations.
5. True, the process would likely halt if the solvent-paint wastes accumulated and over-
flowed into the paint booth. However, the mixture is a hazardous waste, and the purge
pots and the ancillary equipment (i.e., all associated plumbing) are indeed considered a
tank system. Tank systems are defined in 40 CFR 260.10 as:

a hazardous waste storage or treatment tank and its associated ancillary equipment and con-
tainment system.

Regulations as to management of tank systems appear in Subpart J, Tank Systems (40
CFR 264.190-264.200).