Delisting offers inorganic hazardous waste generators, particularly those with F-listed hazardous waste codes, an attractive, safe and more compliant disposal option. EQ offers delisting at its hazardous waste treatment facilities in Canton, OH, York, PA and Harvey IL.
What is Delisting?
Delisting involves treating a waste below regulatory thresholds so that it no longer carries a hazardous waste listed code under RCRA (see 40 CFR Subpart B-261.11). Listed wastes are considered hazardous as the result of the process by which they are produced. For example, spent cyanide plating solutions from electroplating operations, or wastewater treatment sludges from electroplating operations, are two wastes that are listed by the EPA.
The Advantages of Delisting
EQ’s delisting treatment process converts hazardous inorganic wastes into non-hazardous, delisted residuals. As a result, customers’ RCRA hazardous waste liabilities are eliminated and other long-term risks associated with disposal are minimized. This extra measure of protection is the main benefit of delisting.
The delisting standards are much more aggressive than the standards for normal treatment of these wastes. Treating these wastes to these very tough standards means your waste is more secure. EQ’s insurance and indemnification programs stand behind our delisting ability. We take responsibility for properly treating the waste and go one step further with indemnification to our customers that we have done our jobs. This gives our customers long term security that no one else can offer.
Delisting offers significant economic advantages as well. Waste that has been delisted can be deposited in nonhazardous landfills – a less expensive, more generally available alternative to hazardous waste landfills. Non-hazardous waste landfill tipping fees vary, but a generator can typically save at least half of traditional hazardous waste landfill cost.
When Delisting Can Be Used
Delisting can be used on waste generated from both specific and nonspecific sources. Wastes that may be delisted include those designated under the land ban rules with codes K002, K003, K004, K005, K006, K007, K008, K062, F006, F007, F008, F011, F012, and F019.
Delisting treatment standards can also be used to render characteristic wastes nonhazardous; however, this is not considered delisting, because they are not listed wastes. Characteristic wastes are so designated because they can leach environmentally significant quantities of toxic constituents into the environment (see CFR Subpart 261.20). Characteristic wastes are subject to different treatment standards than listed wastes. Characteristic wastes include D002, D003, D004, D005, D006, D007, D008, D009, D010, and D011.
The Delisting Procedure
EQ is the only commercial treatment company in the U.S. that is USEPA-authorized to delist 15 inorganic hazardous wastes. (Federal Register, Volume 51, November 7, 1986, page 41323) The company also treats 10 other characteristic wastes to nonhazardous standards. Delisting is authorized at its facilities in Canton, OH, York, PA and Harvey IL. These facilities were previously owned by Envirite.
EQ begins its delisting process by first analyzing the waste to determine its treatability, compiling a waste profile and developing a treatment procedure. After treatability is determined, the company samples, tests, and reviews all subsequent shipments to assure continued compatibility with its permits, treatment process, and delisting criteria.
The actual delisting process used by EQ is proprietary; however, the process involves conducting a series of reactions using wastes and reagents to neutralize the waste, precipitate the metals, and create insoluble metal compounds. Throughout the process, data integrity is crucial; elaborate and highly redundant quality control procedures ensure that all material leaving each facility is in strict accordance with the delisting granted to the company by the USEPA.
First, detailed sampling procedures make certain that waste samples chosen for analysis represent the day’s output, accounting for all possible variables in time and physical location. Next, a battery of quality control accuracy tests are done in conjunction with each sample tested. Tests are run on known “blank” materials such as distilled water or Ottowa sand to ensure that samples are not contaminated during analysis. Tests on system check samples, which contain known concentrations of analyte, verify that equipment and analysis are performing well. Verification samples are used to check equipment calibration. Matrix spiking, the most crucial test, identifies unforeseen chemical or physical reactions that take place when a known quantity of the analyte is added to the waste being tested.
As a final check, laboratory analysis run two identical matrix spikes side by side; if the results are identical, the process is verified as accurate, representative and repeatable. Detailed testing procedures like these account for the fact that 70% of EQ’s laboratory work is performed to validate the other 30%.
Once the residue has passed these closely monitored quality control procedures it can be shipped to a non-hazardous landfill for proper disposal. Documentation is then sent to the EPA showing the laboratory test results and the place of disposal. The generator also receives a certificate demonstrating that the waste has been rendered non-hazardous.