Page 505 - Materials Chemistry, Second Edition

CAT3525_C14.qxd 1/27/2005 12:37 PM Page 476
476 Waste Management Practices: Municipal, Hazardous, and Industrial
A.14.1.3 RESPONSES TO SCENARIOS
1. (a) If the chips could be used in exactly the same form as when they were removed from
the original battery casings, they are not necessarily a “waste”. But, once they are
processed they become a waste. In the current situation, the chips must be washed (i.e.,
“processed, treated”) at least twice.
(b) If the chips are indeed contaminated with lead (and, they were subsequently found
to be contaminated), the chips are also hazardous waste (The Mixture Rule). The trans-
porter must therefore possess an EPA identification number; the shipments must also be
manifested (Uniform Hazardous Waste Manifest) and the chips must be sent to an EPA-
approved treatment, storage, and disposal facility.
The chips can be easily tested for the characteristic of toxicity using the TCLP. If the
lead concentration in a representative extract exceeds 5mg/L lead, the chips have failed
the toxicity test.
2. “Treatment” is defined in 40 CFR 270.2 as:
Any method, technique, or process, including neutralization, designed to change the
physical, chemical, or biological character or composition of any hazardous waste so as to
neutralize such wastes, or so as to recover energy or material resources from the waste, or
so as to render such waste as non-hazardous, or less hazardous; safer to transport, store,
or dispose of; or amenable for recovery, amenable for storage, or reduced in volume.
Given that the new baghouse dust measures “just below” the TCLP limit, a number of
samples were required by the inspector for TCLP determination. Chemists within the
agency carefully assessed all data. As of this writing, this argument continues. The U.S.
EPA is also being asked for guidance to settle this matter.
3. Drums are not labeled (they require the yellow “Hazardous Waste” label); several drums
are open. Additionally, drums should be covered or stored indoors to limit the effects of
weather on the containers.
4. Given that the fumigants were stored for long periods, the containers were in very poor
condition and the inspector required immediate removal, these materials are indeed a
solid waste. Furthermore, aluminum phosphide is a P006 hazardous waste (40 CFR Part
268.40).
This waste is covered under the EPA Land Ban (see Chapter 17) so it is not to be land-
disposed.
If the fumigants could be used immediately, for example to fumigate several ware-
houses, the inspectors may have been willing to allow this; however, there was little prac-
tical use for pesticides and fumigants in the middle of winter.
Given that this is a hazardous waste, there are the obvious DOT and RCRA require-
ments for transportation (proper transporters, labeling, packaging, etc.). Furthermore,
taking this material into a field and reacting it is a form of treatment, and Bogus
Pesticides would need a permit to do so. “Treatment” in the farmer’s field would have
o
been impractical; at temperatures below 49 F, it would take at least 14 days for aluminum
o
phosphide to decompose. Given winter temperatures averaging 20 to 25 F, such decom-
position will last much longer. According to 40 CFR 268.50, the appropriate treatment
would be chemical oxidation, chemical reduction, or controlled incineration.
As of this writing, Bogus Pesticides has been cited for illegal disposal and the case is
being sent to the State Office of Enforcement.