Page 453 - Materials Chemistry, Second Edition

CAT3525_C12.qxd 1/27/2005 4:11 PM Page 424
424 Waste Management Practices: Municipal, Hazardous, and Industrial
6. For a 55 gal drum, a date is to be noted on the hazardous waste label once it has been
filled; counting the days (90 for a LQG, 180 for a SQG) begins immediately thereafter.
One cannot change the start date of accumulation. In the current situation (a LQG) it is
probable that the drum was on-site for over the 90-day storage period. According to 40
CFR 262.34(a)(2):

A generator may accumulate hazardous waste on-site for 90 days or less without a permit pro-
vided that:
The date upon which each period of accumulation begins is clearly marked and visible for
inspection on each container;
As a side note, for a container greater than 55 gal, the date is marked on the Hazardous
Waste label at the first addition of waste, not when the container is full.
7. (a) According to 40 CFR 265.31:

Facilities must be maintained and operated to minimize the possibility of a fire, explosion, or
any unplanned sudden or non-sudden release of hazardous waste or hazardous waste con-
stituents to air, soil, or surface water which could threaten human health or the environment.
The building was open to the outside by way of the garage door and spaces in the walls,
so there is no complete secondary containment.
(b) The inspector encouraged simple improvements in housekeeping, i.e., if the shed
floor is kept free of sludge, dispersal is no longer an issue.
(c) Wastes that are tracked outside could easily be dispersed off the plant site by wind.
The argument of a waste drain is therefore inadequate.
8. There is no requirement that spill prevention equipment be situated directly within the
90-day accumulation areas.
9. Although the waste is a solid hazardous waste, an integrity assessment of the tank is still
required. However, the assessment does not have to be as involved as for a tank storing
liquid hazardous wastes.
Incidentally, the issue over secondary containment came up between inspector and plant
manager. When brought to the U.S. EPA, it was decided that secondary containment was
not required.
10. This hazardous waste storage area has its share of problems. Most wastes are unidenti-
fied and unlabeled; a waste characterization is required. Incompatible wastes are stored
side-by-side. Many containers are open. Containers must remain closed with few excep-
tions, for example (40 CFR Sec. 264.173):

(a) A container holding hazardous waste must always be closed during storage, except when it
is necessary to add or remove waste.
(b) A container holding hazardous waste must not be opened, handled, or stored in a manner
which may rupture the container or cause it to leak.

11. Although not the highest quality printing, the labeling of this drum is actually acceptable.
Federal regulations (40 CFR 262.34) state that, in a satellite accumulation area, a waste
drum must simply be labeled, describing the contents; there is no requirement for a
specific label in a satellite area. If, however, the drum were in a 90-day accumulation
area, this “label” is unacceptable. A standard yellow “Hazardous Waste” label must be
affixed to the drum and dated.
This drum is situated in the middle of the aisle and must be moved.
12. The fly ash is indeed a solid waste, as it is “discarded” material. However, fly ash is
exempted from designation as a hazardous waste. According to 40 CFR 261.4(b)(4), fly