8.B.7 Monitoring Waste Services, Transport, and Off-Site Treatment and Disposal
The ultimate destination of waste is usually a treatment, recycling, and/or disposal facility, which is sometimes called a permitted TSDF. Here waste is treated (typically via chemical action or incineration), recycled, reclaimed, or disposed of in a landfill. Although the waste has left the generator’s facility, the generator retains the final responsibility for the long-term fate of the waste. As explained below, it is important that the generator verify that the waste transporter and TSDF operate in a way that is safe, compliant, and environmentally sound, and minimizes long-term liability. The procedures for preparing and transporting the waste to such a facility are similar to those described above. (See section 8.B.3.)
Waste is rarely transported from a generator’s site directly to the ultimate disposal facility. Because of the economics of transportation, only truckload quantities (usually at least 55- to 80-gal drums or a full tanker) are shipped directly. Most laboratory waste is transported to a transfer storage facility where it is consolidated with wastes from other generators and stored until truckload quantities are accumulated. Flammable solvents and other compatible materials are often blended to make them amenable for fuel recovery.
Generators are legally responsible for all aspects of hazardous waste management, including proper disposal, packaging, labeling, shipping, manifest preparation, recordkeeping, accumulation area operations and maintenance, accumulation time limit compliance, and contingency planning associated with hazardous waste management. However, generators may choose to handle some or all of these responsibilities using in-house personnel, or they may contract with professional waste management firms. The generator’s responsibilities are summarized below:
• inspecting waste containers to ensure complete and legal labeling, and container dating when required;
• waste accumulation, and managing accumulation areas for safety, security, aisle width, and separation of incompatibles;
• inspecting waste containers to ensure that they are always closed and in good condition, including repackaging of leaking containers;
• preparation and updating of waste management and contingency plans;
• sampling and characterization of routine wastes;
• sampling and characterization of “unusual” or new wastes;
• preparation of transportation documents;
• identification of disposal sites; and
• performance of periodic waste management audits to ensure compliance with regulations.
Regardless of which activities a generator decides to conduct in-house, it is imperative that well-trained, qualified staff be available to conduct the waste management activities. It is also important that these persons be given the independence, authority, and resources to properly manage the facility’s wastes and maintain regulatory compliance.
The selection of which activities to perform in-house and which services to handle through firms that specialize in waste disposal is dependent on the number, qualifications, and availability of in-house staff, organizational philosophy, and budgetary constraints. This is summarized in Table 8.1. It is very important to recognize that in the long term, it is the generator who bears the major liability to ensure proper handling and disposal of hazardous waste. Thus the choice of any outside waste disposal firm to participate in the process is extremely important.
When a generator designs or evaluates the effectiveness of its waste management program, it is important to know the types of outside services that are available and to determine if the use of such services is necessary or beneficial. Once a decision has been reached to hire a waste disposal firm for such services, it is important to know how to select, monitor, and work with such firms.
Waste disposal firms differ in the types of service they provide. Some firms furnish consulting services or directly provide transportation or disposal services. Other waste disposal firms provide both types of services, but usually specialize in one or the other.
Some waste disposal firms, referred to as brokers, generally provide few, if any, direct services. They coordinate, directly or through other specialty firms, the selection of disposal sites, acquisition of disposal approvals, and subsequent transportation and disposal. Brokers typically provide only limited direct consulting or waste management support services, which are often limited to waste sampling, packaging, preparation for shipment, and some regulatory compliance support.
Transportation services are designed to move the waste from the point of generation to the chosen TSDF. For laboratories, this typically involves transport of drums or other small containers by truck. For transport on public roads, federal regulations require laboratory waste to be contained in approved packages, such as drums approved by DOT. The packages must be marked and labeled according to DOT rules, and accompanied by a manifest, as described below. Preparers and drivers must receive DOT training. Drivers