Non-Conforming Hazardous Waste

Non-Conforming Hazardous Waste

What exactly is a non-conforming hazardous waste (HW) stream at a permitted TSDF? Let’s take a look at the process of how a HW stream is managed at a TSDF.

All hazardous wastes need to be profiled into a treatment facility. The profile is much like an SDS document, but it is geared more to the specific treatment facility where the waste will be treated. Each EPA permitted hazardous waste Treatment, Storage and Disposal Facility (TSDF) has a Waste Analysis Plan (WAP). Based upon the treatment technology(s) conducted at the facility, the WAP may require different types and amounts of information needed on the HW profile.

The HW profile provides the physical description, chemical composition and properties, and specific constituents of the waste. This profile of the waste stream is what is expected to be received in the container that is shipped from the HW generator. When the waste is received at the TSDF, the WAP will define what inspection of the waste is required – per the TSDF permit. All WAPs will mandate a certain percentage of waste streams opened and inspected per shipment – per profile – a minimum of 10% of the drums per waste stream. Typically, there is both a physical inspection and also a chemical constituent review, through instrumental analysis, like gas chromatography, pH testing, and flash point testing (as needed). If the inspection yields results outside of an expected range for the waste – the waste stream is found to be non-conforming to the HW profile that was submitted.

When a waste stream becomes non-conforming, the TSDF must set the waste aside in the receiving area, and work with the customer to see if the non-conformance can be remedied. There is typically a cost associated with this process – and these costs are passed back to the HW generator. Based on what is making the waste non-conforming, the profile may be amended to address the issue and allow the waste to be acceptable. The generator may have several HW streams, and perhaps accidently mislabeled this stream (such as sending a corrosive waste on a flammable waste profile). Perhaps something not allowed by the TSDF HW permit (like a red biohazardous waste bag or biohazardous label) is in the waste stream.

The TSDF personnel will reach out to the generator to try and correct the issue with the waste that has been determined to be non-conforming. In the worst case, the waste non-conformance cannot be rectified, and the waste cannot be received at the TSDF. The waste stream is REJECTED.

Joe Jordan

Author: Joe Jordan

Joe Jordan has a Bachelors of Arts degree in Chemistry from Washington and Jefferson College. He is certified in RCRA and DOT as well as 40 Hour HAZWOPER certified. Joe has been in the hazardous waste industry since 1990 and has managed industrial, healthcare, retail, and governmental clients, both large and small.