Many hazardous wastes, when mixed with other waste or materials at a hazardous waste facility, can produce effects which are harmful to human health and the environment, such as (1) heat or pressure, (2) fire or explosion, (3) violent reaction, (4) toxic dusts, mists, fumes, or gases, or (5) flammable fumes or gases.

Below are examples of potentially incompatible wastes, waste components, and materials, along with the harmful consequences which result from mixing materials in one group with materials in another group. The list is intended as a guide to owners or operators of treatment, storage, and disposal facilities, and to enforcement and permit granting officials, to indicate the need for special precautions when managing these potentially incompatible waste materials or components.

This list is not intended to be exhaustive. An owner or operator must, as the regulations require, adequately analyze his wastes so that he can avoid creating uncontrolled substances or reactions of the type listed below, whether they are listed below or not.

It is possible for potentially incompatible wastes to be mixed in a way that precludes a reaction (e.g., adding acid to water rather than water to acid) or that neutralizes them (e.g., a strong acid mixed with a strong base), or that controls substances produced (e.g., by generating flammable gases in a closed tank equipped so that ignition cannot occur, and burning the gases in an incinerator).

In the lists below, the mixing of a Group A material with a Group B material may have the potential consequence as noted.

Potential consequences: Heat generation; violent reaction.

Potential consequences: Fire or explosion; generation of flammable hydrogen gas.

Potential consequences: Fire, explosion, or heat generation; generation of flammable or toxic gases.

Potential consequences: Fire, explosion, or violent reaction.

Potential consequences: Generation of toxic hydrogen cyanide or hydrogen sulfide gas.

Potential consequences: Fire, explosion, or violent reaction.

Source: “Law, Regulations, and Guidelines for Handling of Hazardous Waste.” California Department of Health, February 1975.

[45 FR 33232, May 19, 1980, as amended at 71 FR 40276, July 14, 2006]

09/18/2013

(Seattle—Sept 18, 2013) Joint Base Elmendorf-Richardson in Anchorage failed to comply with federal hazardous waste management laws and has agreed to pay a fine to resolve the violations, according to a settlement with the U.S. Environmental Protection Agency. The base has taken action to correct the violations and will pay a fine of over $21,000.

“Careful hazardous waste management protects human lives and the environment, and it also prevents the public from having to fund costly cleanup operations,” said Scott Downey, Manager of the Hazardous Waste Compliance Unit at the EPA Seattle office. “Facilities have to inspect hazardous waste storage and keep staff up to date on training to prevent incidents.”

The facility generates and stores hazardous waste from vehicles, aircraft and other facility maintenance. This includes acids, contaminated soils, batteries, PCB wastes, solvents, used oil and pesticides.

EPA inspections found a series of violations from 2010-2011, including

1. Failure to conduct weekly inspections of hazardous waste facilities and containers for leakage or deterioration;
2. Failure to ensure staff participated in annual hazardous waste management training; and
3. Failure to submit hazardous waste tracking reports.

The violations occurred under the Resource Conservation and Recovery Act.

Hazardous waste personnel training required for large quantity generators of hazardous waste at 40 CFR 262.34(a)(4) and explained in 40
CFR 265.16 would have prevented these violations from happening.

Contact me to provide you with high-quality hazardous waste personnel training (aka: RCRA Training) before you become the subject of a news release like this one.

Published July 12, 2013 in the Federal Register (FR Vol. 78, No. 134, 41853), the Safety Advisory is issued by the PHMSA of the USDOT in coordination with the Occupational Health and Safety Administration (OSHA) and the US Environmental Protection Agency (USEPA) and in consultation with the Federal Railroad Administration of the USDOT.  Its scope is limited to those persons who heat a rail tank car to prepare its hazardous material contents for unloading or transloading (defined below).  Its purpose is to prevent accidents that occur as a result of the heating of hazardous materials contained in rail tank cars.  To achieve its purpose, this Safety Advisory:

• Provides safety precautions and recommended guidance for persons engaged in heating a hazardous materials in a rail tank car for the purpose of unloading and transloading, and;
• Reminds subject persons of current regulatory requirements for these activities.

(more…)

In 1999 and again in 2002, accidents occurred as a result of the process of heating rail tank cars for unloading hazardous materials.

On February 18, 1999, a rail tank car, which was on the unloading rack at the Essroc Cement Corporation (Essroc) Logansport cement plant near Clymers, Indiana, sustained a sudden and catastrophic rupture that propelled the tank of the rail tank car an estimated 750 feet and over multistory storage tanks.  The 20,000-gallon rail tank car initially contained about 161,700 pounds (14,185 gallons) of a toxic and flammable hazardous waste that was used as a fuel for the plant’s kilns.  There were no injuries or fatalities. Total damages, including property damage and costs from lost production, were estimated at nearly $8.2 million. The National Transportation Safety Board (NTSB) determined that the probable cause of the accident was the failure of Essroc to develop and implement safe procedures for heating rail tank cars for unloading hazardous waste (i.e., toluene diisocyanate matter wastes). This lack of procedures resulted in the over-pressurization of the rail tank car due to chemical self-reaction and expansion of the toluene diisocyanate matter wastes.

On September 13, 2002, a 24,000-gallon-capacity rail tank car containing about 6,500 gallons of hazardous waste catastrophically ruptured at a transfer station at the BASF Corporation chemical facility in Freeport, Texas.  The rail tank car had been steam-heated to permit the transfer of the waste to a cargo tank motor vehicle for subsequent disposal.  The waste was a combination of cyclohexanone oxime, cyclohexanone, and water.  As a result of the accident, 28 people received minor injuries.  Residents living within one mile of the accident site had to shelter in place for five and one-half hours.  The rail tank car, cargo tank, and transfer station were destroyed.  The force of the explosion propelled a 300-pound rail tank car dome housing about 1/3 mile away from the rail tank car.  Two storage tanks near the transfer station were damaged which resulted in the release of about 660 gallons of the hazardous material oleum.

The Federal Railroad Administration has identified involving heating of rail tank cars that did not result in death or injury.  The NTSB investigated the Freeport, Texas accident and determined that the probable cause of the rupture of the rail tank car was over-pressurization resulting from a runaway exothermic decomposition reaction initiated by excessive heating of the hazardous waste material.  The NTSB determined that BASF’s failure to monitor the temperature and pressure inside the rail tank car while the hazardous waste was heated in preparation for unloading contributed to the accident.  As a result of its investigation of the Freeport, Texas accident, the NTSB recommended that PHMSA, in cooperation with the OSHA and the EPA, develop regulations that require safe operating procedures to be established before hazardous materials are heated in a rail tank car for unloading; at a minimum, the NTSB recommended that the procedures should include the monitoring of internal tank pressure and cargo temperature (NTSB Recommendation R-04-10; December 15, 2004).

See http://www.ntsb.gov/doclib/recletters/2004/R04_10.pdf.

In a response to the July 6, 2013 train derailment in Lac-Mégantic, Quebec, Canada, and before the investigation into the crash is complete, on  August 2nd the Federal Railroad Administration (FRA) of the USDOT announced its intent to prevent similar accidents caused by trains operating on mainline tracks or sidings from moving unintentionally. (more…)

News Release: Presidio Trust Awarded Honorable Mention for U.S. EPA Resource Conservation Competition
08/26/2013

FOR IMMEDIATE RELEASE:  August 26, 2013

MEDIA CONTACT:  David Yogi, yogi.david@epa.gov, (415) 972-3350

SAN FRANCISCO – The U.S. Environmental Protection Agency today announces the Presidio Trust as its 2012 WasteWise “Federal Government Partner of the Year” Honorable Mention recipient. The Presidio Trust is recognized for its efforts to reduce and compost food waste, and recycle and reclaim demolition materials for use in new construction projects.

“Presidio Trust’s efforts alone will save the organization over $215,000 and remove the equivalent of 334 households’ annual CO2 emissions from the air,” said Jared Blumenfeld, EPA’s Regional Administrator for the Pacific Southwest.  “EPA is proud to recognize the efforts of the Presidio Trust to ensure their operation’s environmental impact is as small as possible.”

As part of its efforts, the Presidio Trust:

• reused wood from re-foresting and deconstruction projects in the Presidio—part of the federal Golden Gate National Recreation Area—to create park benches and new elements for building renovations;
• reused material onsite (such as gravel, top soil, sand, architectural elements, hardware, lighting, furnishings, etc.) that was collected from construction, renovation and demolition projects.
• diverted 100% of green waste generated from Presidio gardening, landscaping, and forestry projects;
• increased the amount of food waste it diverted from landfills by 47 percent from 2010 to 2011, bringing its total diversion rate to 69 percent;
• reduced its total waste by 24 percent in 2011; and
• recycled a total of 4,447 tons of materials (equivalent to avoiding the annual CO2 output of 1356 automobiles) and made 626 tons of compost in 2012.

The Presidio Trust has been an EPA WasteWise partner since 2000, and has won sustainability awards in 2001 and 2007.

EPA’s WasteWise program was launched in 1994 to help organizations and businesses reduce municipal and industrial wastes. Organizations can join WasteWise as a partner, endorser, or both. Partners demonstrate how they reduce waste, practice environmental stewardship, and incorporate sustainable materials management into their waste-handling processes. Endorsers promote enrollment in WasteWise as part of a comprehensive approach to help their stakeholders realize the economic benefits to reducing waste.

WasteWise is something that I mention at all of my Training Seminars.  It is a good tool to use when reducing the waste (including but not necessarily exclusive to hazardous waste) at your facility.

For more information on EPA’s WasteWise program, please visit:  http://www.epa.gov/epawaste/conserve/smm/wastewise/index.htm

BELLEVUE – The Department of Ecology (Ecology) has fined Burlington Environmental LLC (Burlington Environmental) $180,000 for 13 violations of requirements for dangerous waste management at the company’s facility in Kent. The violations occurred between October 2012 and January 2013.

The facility, located at 20245 77th Ave. S., processes dangerous wastes from hundreds of commercial and industrial clients for proper shipment and disposal.

The company came into compliance quickly after the violations were identified.

“This facility has now incurred penalties of just over $1 million over the past 12 years for violating hazardous waste requirements. Those requirements protect the public, the environment and on-site worker safety,” said K Seiler, who manages Ecology’s hazardous waste and toxics reduction program. “Local processing for business and industrial wastes benefits our state’s economy and environment. We want the company to succeed at this, but properly and without violations.”

The violations fell into three general categories:

• Storage of dangerous waste in excess of required time limits.
• Inadequate training and management of supervisors and employees to follow conditions and standards of the facility’s dangerous waste permit.
• Failure to follow procedures required to ensure safe separation of incompatible materials.

The violations included a fire at the facility, which started because incompatible wastes came into contact and ignited.

“Our company has worked cooperatively with Ecology and the community to ensure our waste handling practices are safe and protective,” said Barbara Smith, Burlington Environmental spokesperson. “It is important to note that none of these incidents caused immediate threat to human or environmental health. No workers were injured. We corrected these issues quickly and diligently work to improve our compliance with the rules and regulations that govern our business.”

The company has the right to appeal the penalty to the Washington State Pollution Control Hearings Board within 30 days.

Burlington Environmental has paid $868,000 in penalties or through penalty settlements from 2001 to 2012.

Ensuring proper safety and environmental practices at hazardous waste processing facilities supports Ecology’s priority of preventing and reducing toxic threats to human health and the environment.

NOTE:  In Washington (a state with an authorized hazardous waste program) what is defined by the USEPA as a Hazardous Waste is identified as a Dangerous Waste.  In addition, Washington’s Department of Ecology (Ecology) has identified “state-only” dangerous wastes which also fit under its definition of Dangerous Waste.  Learn more about how to identify and designate Dangerous Waste on Ecology’s website.

####

Media Contact:

Larry Altose, Ecology media relations, 425-649-7009, larry.altose@ecy.wa.gov
Dave Misko, Ecology compliance supervisor, 425-649-7014
Barbara Smith, Burlington Environmental spokesperson, 206-605-3392

More information:

Hazardous Waste Facilities: (www.ecy.wa.gov/programs/hwtr/hwfacilities/index.html)
Dec. 19, 2012 news release: Kent dangerous waste facility fined $282,000 (www.ecy.wa.gov/news/2012/406.html)
Ecology’s social media (www.ecy.wa.gov/about/newmedia.html)

BOSTON – VHS Acquisition Subsidiary Number 7, Inc., the parent corporation that operates St. Vincent Hospital in Worcester has been assessed a $2,860 penalty by the Massachusetts Department of Environmental Protection (MassDEP) for violating Hazardous Waste Management and Air Pollution Control requirements.  (Link to the news release on the MADEP website).

Release Date: 08/27/2013

Contact Information: Dawn Harris Young, (404) 562-8421 (Direct), (404) 562-8400 (Main), harris-young.dawn@epa.gov

ATLANTA – Family Dollar, Inc., headquartered in Matthews, NC, has paid a $602,438 civil penalty to the United States to resolve alleged violations of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) for misbranded pesticides.

The penalty stems from the sale or distribution of two misbranded or mislabeled antimicrobial bleach products on numerous occasions. The labels for the bleach products were not identical to the EPA approved label. Labels must be identical to the EPA approved label and may not have any additions or omit any label language as required by FIFRA. 

Misbranded pesticides can pose serious risks to human health and the environment. Without proper labeling or safety instructions on packaging, users can unintentionally misapply pesticides and may not have adequate information to address needs for first aid in the event of emergency.

As a result of EPA’s enforcement action, Family Dollar, Inc., alerted its suppliers about the labeling issues and took steps to bring these products into compliance with FIFRA.

Unmentioned in this news release is whether or not the misbranded pesticides were subject to a recall.  If they were, Family Dollar would have to face the additional burden of disposing of the recalled pesticides as a hazardous waste under the regulations of the Resource Conservation & Recovery Act (RCRA); enforced by USEPA and authorized states.  However, if certain conditions are met – read:  What is a Universal Waste Pesticide? – the recalled pesticides may be managed as a universal waste per 40 CFR 273 and therefore not subject to the much heavier regulatory burden of the hazardous waste regulations.  Contact me with any questions you may have about universal waste, used oil, or hazardous waste.

(1) Five or more tank car loads of any one or any combination of materials poisonous by inhalation as defined in 49 CFR 171.8, and including anhydrous ammonia (UN 1005) and ammonia solutions (UN 3318); or

(2) 20 rail car loads or intermodal portable tank loads of any one or any combination of materials listed in (1) above, or, any Division 2.1 flammable gas, Class 3 flammable liquid or combustible liquid, Class 1.1 or 1.2 explosive, or hazardous substance listed in 49 CFR 173.31(f)(2).

See 49 CFR 173.115 for the definition of Division 2.1 flammable gas, 173.120 for definition of Class 3 flammable liquid; and 173.50 for the definition of the various classes of explosives.