The EPA’s definition of waste treatment can be confusing and potentially costly, so it is important that hazardous waste generators be clear as to what activities might be considered as treatment of hazardous waste, according to Pollution Engineering.
Under the Resource Conservation and Recovery Act, treating a waste means changing the physical, chemical or biological characteristics of it. Examples of these types of change might be:
- Making a waste less corrosive or toxic
- Reducing a waste’s volume through evaporation
- Burning waste to obtain energy from it
- Leaving waste paint in the open to let volatile organic compounds in it vaporize
- Adding an acid or alkaline into a waste stream to reduce its corrosivity
- Doing something to waste to make it easier or less costly to transport or store
It is important to understand point of generation and its role in hazardous waste treatment. The simplest way to view it is like this: once a material is removed from the manufacturing process to be discarded, it becomes waste. Changing the hazardous characteristic of any material after it has left the manufacturing process is considered to be treating that hazardous waste.
A sample scenario would be where chemicals are being brewed in a reactor and the brew is very corrosive. At some point it is decided to add chemicals to the reactor to make the brew less corrosive. Is this an example of treating hazardous waste? The answer is no. This is an important distinction because no waste, hazardous or otherwise, had yet been generated. It was the manufacturing process that was being altered.
There are certain situations under the RCRA where treatment of hazardous wastes is allowed. A common exemption is “Elementary Neutralization Unit.” Neutralizing these waste streams is allowed because they are hazardous solely because they exhibit the corrosivity characteristic. However, this is a federal exemption and some states put severe restrictions on such practices. Always check with your state agency first.
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