As a hazardous waste generator, do you truly understand what is happening to your waste streams when they leave your facility?
If your company is one of the many United States corporations that are concerned with sustainability, then it is crucial to understand how your hazardous waste will be treated.
This is where understanding how the Environmental Protection Agency (EPA) classifies different waste management recycling and disposal methods through the use of hazardous waste disposal codes, can give you a clue as to what is happening to your waste.
Why should I care?
For companies that have spent solvents as a waste byproduct of their manufacturing or operational processes, options are very limited for the disposal of these waste streams.
Particularly if you are working with any of a number of a handful of national waste management companies you may be presented with HO61 fuel blending as your primary and only disposal option.
However, for a growing list of corporations, there is a mandate to reduce the carbon footprint and reduce the amount of raw materials consumed in order to sustain the availability of natural resources. Natural resources have a finite quantity.
When they are gone, they’re gone!
By recycling whenever practical, resources are sustained. By conserving our natural resources we as a people all benefit. This is one of the stated objectives of the circular economy that is growing in popularity in Europe and has been introduced in North America in recent years.
For this reason, recycling to the natural state of the resource should always be looked at prior to seeking alternative uses for the materials.
So why and how does understanding management method or handling codes benefit you?
Management Method Codes
Management method codes describe the type of hazardous waste management system used to treat or dispose of a hazardous waste stream. Also known as EPA Handling Codes they reflect the disposal method for the Hazardous Waste Management Method Code provided in Box 19 of the Hazardous Waste Manifest Form.
The handling code is recorded on the manifest by the TSDF after they receive and inspect the waste. When the generator receives the facility copy in the mail from the TSDF they can make sure the code that was applied is what they expected.
Let’s look at how this works..
How Codes Are Assigned
Handling Codes are assigned by the TSDF that Block 8 on the manifest directs the waste to. If the TSDF listed on the generators manifest is not the ultimate recycle/disposal facility the TSDF uses the appropriate Handling Code to reflect what they did to the waste.
For example, a TSDF receives 100 drums of solvent waste from 10 different generators and they mix those 100 drums in a bulk tank destined to be burned as fuel at a cement kiln. Commingling of waste from various generators is a form of treatment.
Those drums would have a Handling Code of H061. When that waste is shipped to a cement kiln to be burned as fuel, a new outbound manifest is generated by the first TSDF with the facility listed as the generator.
If the original TSDF on the generator manifest doesn't do anything except store waste for more than 10 days they manifest it out to a second TSDF with an H141 Handling Code. The original generator maintains Cradle to Grave liability until the waste is processed at the final recycle/disposal facility.
The generator only receives a copy of the manifest from the original TSDF where they manifested their waste to on Block 8 of the Uniform Hazardous Waste Manifest.
Let’s take a look at the four main categories of handling codes as follows:
- Reclamation and Recovery
- Destruction or Treatment Prior to Disposal at Another Site
- Storage & Transfer Off-Site
You can view a complete list of the EPA Management Method Codes on the EPA website.
Why is it important to understand these codes?
You will use these codes when you are preparing your hazardous waste report as required by the EPA. They can also be used to make sure your waste is being managed as requested and according to the highest degree of sustainability.
For instance, if you requested Solvents Recovery “HO20” (distillation, extraction) from your hazardous waste service company and see on the return copy of the manifest “H061” then you will know the waste has been redirected to fuel blending.
It’s important to note that not all management methods are alike, and some are more beneficial to the environment and promote sustainability.
Let’s look at a real world example.
At Temarry, we recycle or recover everything that we receive. We accept flammable and halogenated solvents for distillation through our solvent distillation process. Spent solvents are first filtered and blended and then go into the recovery stills. Sufficient heat is applied to boil the solvent.
Only the pure solvent is vaporized and goes up into the column. The vapor is condensed back into liquid where it becomes a pure solvent that is sold back into industry to be used for its intended purpose.
Because of our distillation process, spent solvents and other flammable liquids sent to Temarry will be classified using Reclamation and Recovery handling code HO20 for solvents recovery.
The list of Reclamation and Recovery codes is as follows:
H010 – Metals recovery including retorting, smelting, chemical, etc.
H020 – Solvents recovery (distillation, extraction)
H039 – Other recovery or reclamation for reuse including acid regeneration, organics recovery, etc.
(specify in comments)
H050 – Energy recovery at this site – use as fuel ( indicates that the energy derived from waste conversion is used at the receiving facility)
H061 – Fuel blending prior to energy recovery at another site
Vs. Fuel Blending
The alternative to solvent recovery is HO61 fuel blending. Fuel blending is also an environmentally friendly recycling option for solvent-based liquids, solids and sludge. The process blends organic waste streams into an alternative fuel for kilns used in manufacturing cement.
Fuel blending also conserves natural resources by replacing coal, oil and other fossil fuels in cement production, and is often a less costly alternative to incineration.
BUT, here's the rub for companies located in the Western United States…….the closest cement kilns are almost always very close to limestone quarries, which most if not all are in the Midwest or East Coast of the United States. This means that the final disposal of your hazardous waste stream will have to travel thousands of miles before being used as an alternative fuel.
This is a huge increase in carbon footprint, when there is a closer, more economical and environmentally friendly option just south of the border in Tecate.
Additionally, solvent recovery through solvent distillation is in alignment with the circular economy since the solvents are maintained at their highest value….fresh solvent that is sold back into industry, and not used as an alternative fuel source.
As we indicated earlier, once these resources are gone…..they are gone.
In this case HO20 handling codes are far superior to HO61.
Aren’t The Resources Required For Distillation Just As Valuable?
This sometimes is a natural counter to the recycling vs fuel blending argument…...the resources required to recycle are just as wasteful as the shipping costs. In most cases, that’s correct!
Heat is a natural resource that is expensive and can often mitigate the financial advantage of distillation. To counterbalance this cost, at Temarry, we receive hazardous and non-hazardous organic solids, such as rags, debris, wipes and PPE with sufficient fuel value to convert to energy in our waste-to-energy process.
Solids are fed by conveyer into the primary chamber that operates at 1500°F.
Heat and gases then go into a second chamber that operates at the same temperature to insure that all organics are eliminated. Heat then goes to a 200hp steam boiler. Effluent is then directed to a 2 stage venturi scrubber to insure that particulate does not enter the atmosphere. Steam is then directed to the recovery stills and used as an inexpensive heat source that does not expend natural resources.
All “solid” hazardous waste received by Temarry is classified with an HO50 handling code (Energy recovery at this site – use as fuel) which also reduces carbon footprint, and is preferable to landfill or long distance fuel blending and energy recovery.
These innovations allow Temarry to operate the only “Closed Loop True Recycling” facility serving the western United States.
The benefits to our clients are innumerable, including preferable handling codes, a smooth manifesting process, cost savings and a reduction in carbon footprint that leads to higher levels of sustainability.
This is why it is important to check your manifest handling codes. There could be a more sustainable solution for your hazardous waste streams available to you.