Waste management off-site

Does the facility evaluate (for example, audit) the off-site waste management facilities used to manage hazardous wastes If yes, do the evaluations ensure that wastes will be handled safely, without causing harm to waste handlers, the public, or the environment Flave the reviews been documented ... 

The impact of California s waste reduction efforts have not yet been measured quantitatively. Measuring the true efforts is complicated because it is difficult to attribute statewide waste reduction results specifically to the Waste Reduction Program. Even then, that impact may not be distinguishable from that of more stringent regulatory requirements, escalating off-site waste management costs, and broad-based industry trends. 

Points 3 and 4 are discussed in section 5.3.6.S concerning off-site waste management. 

A critical consideration is identifying an off-site waste processor who is able and willing to receive the carbon filter material from the VOC treatment step. A waste processor will certainly require that VOCs be stripped from the hydrolysate only after agent destruction has been confirmed by chemical analysis. Consequently, the spent activated carbon used to recover VOCs should be agent free and can be treated like any other commercially produced spent filter material. If the spent activated carbon cannot be certified as agent free, it will have to be managed in the same manner as spent activated carbon that is known or likely to be agent contaminated. 

Improper waste management by another party of off-site waste material from a production facility... 

Wastes from waste management facilities, off-site waste, wastewater treatment plants, and the preparation of water intended for human consumption and water for... 

The Duty of Care applies to all holders of the waste from the producer to the waste manager of the final disposal operation. Duty of Care responsibilities for off-site waste transfer are covered by the following statements in the regulations... 

Radioactive waste may be processed at a nuclear power plant or at an off-site facility. Preference should be given to on-site waste management. In various cases, transport to off-site facilities is advantageous (for example, for incineration) or necessary (to a repository). Radioactive waste should be moved from a nuclear site to another installation or site only if its transport is authorized by the regulatory body. 

Many of these techniques involve source reduction— the preferred option on the EPA s hierarchy of waste management (24). Others deal with on-and off-site recycling. The best way to determine how these general approaches can fit a particular company s needs is to conduct a waste minimization... 

Recychng (or reuse) refers to the use (or reuse) of materials that would otherwise be disposed of or treated as a waste product. A good example is a rechargeable battery. Wastes that cannot be directly reused may often be recovered on-site through methods such as distillation. When on-site recoveiy or reuse is not feasible due to quality specifications or the inability to perform recoveiy on-site, off-site recoveiy at a permitted commerci recoveiy facihty is often a possibility. Such management techniqiies are considered secondaiy to source reduc tion and should only oe used when pollution cannot be prevented. 

For those waste streams that can impact public health or the environment (if mismanaged), provide a summary of the treatment and disposal methods (for example, solvents are incinerated or recycled, lab wastes are incinerated) used to manage them and identify the on-site or off-site facilities used. Is the disposal of the waste adequately documented (for example, retention of manifests, bills of lading or transfer notes) ... 

Disposal involves the use of postprocess activities that can handle waste, such as deep-well injection and off-site shipment of hazardous materials to waste-management facilities. 

For off-site land disposal of wastes resulting from a CERCLA activity, the program contains two additional requirements. First, the unit in which the wastes are to be disposed must not be releasing hazardous wastes or constituents into groundwater, surface water, or soil. Second, any releases from other units of the facility must be under an approved RCRA corrective action program. This policy assures that wastes shipped off-site from CERCLA sites are sent to environmentally sound waste management facilities. 

The technology of deep-well injection has been around for more than 70 years. Most Americans would be surprised to know that there is a waste management system already in operation in the U.S. that has no emissions into the air, no discharges to surface water, and no off-site transfers, and exposes people and the environment to virtually no hazards. 1 The U.S. Environmental Protection Agency (U.S. EPA) has stated that Class 1 wells are safer than virtually all other waste disposal practices for many chemical industry wastes. 

Brines. Brines produced from air pollution control processes at the baseline facility at Tooele, Utah, are currently being shipped off-site for disposal by commercial waste management facilities. 

Recycling of wastes is the preferable waste management method after source reduction opportunities have been exhausted. Recycling can be performed within the process itself, within the plant, or off-site, and can involve reuse of the entire waste stream, or recovery of a part of it. Recovery of the stream s metal content can be achieved through operations such as electrolytic recovery, reverse osmosis, and ion exchange. 

Waste Control Limit Screening Criteria for Off-site Management of Chemical Agent Disposal Facility Secondary Waste, 39... 

Finding 3-8. The waste management practices for demilitarization protective ensemble suits and other plastics are limited by the on-site capacity for treatment and, at some sites, by the regulatory restrictions for off-site disposal. 

Scrubber brine results from the treatment by the PFS of the process gases coming from the incinerators. Scrubber brine contains water, dissolved salts, suspended solids, and trace amounts of heavy metals. After use, scrubber brine is designated as spent brine and is transferred to storage tanks before off-site shipment to a permitted TSDF. A thermal evaporation system for concentrating the spent brine solution to solid brine salts is used at some sites, while other sites manage this waste as a brine solution. The use of a thermal evaporation brine reduction system may be required by individual site permits. 

The RCRA permit requirements and practices for disposal of brine are fairly uniform across the four baseline sites. There are no analytical issues preventing the accurate characterization of brines, and sites have had no problem meeting the waste control limits. Disposal options for brine solution and brine salts at off-site TSDFs are also readily available and utilized. A stricter requirement for on-site brine salt evaporation is enforced at UMCDF but has not impeded the overall waste management program at that site. 

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