Chemical Engineering August 2021 - 45

age, until it is ultimately disposed of.
All waste generators must follow
the framework established by
RCRA. A hazardous waste generator
is defined as any organization
that produces a hazardous waste.
Generators are regulated based on
the amount of hazardous waste they
create in a calendar month, not the
size of their business or facility.
The EPA recognizes three categories
of generators [7]:
1. Very Small Quantity Generators
(VSQGs) generate 100 kg or less per
month of hazardous waste or 1 kg or
less per month of acutely hazardous
waste.
2. Small Quantity Generators (SQGs)
generate more than 100 kg but less
than 1,000 kg of hazardous waste
per month.
3. Large Quantity Generators (LQGs)
generate 1,000 kg per month or
more of hazardous waste, or more
than 1 kg per month of acutely hazardous
waste.
Many substances that are handled,
stored and manufactured
within chemical plants are regulated
as hazardous waste. Therefore, engineers
and other personnel must follow
all requirements outlined within
RCRA, as well as any other relevant
federal, state or local regulations that
dictate how to properly manage and
dispose of hazardous waste.
Common hazardous wastes
Listed wastes are wastes that come
from common manufacturing and
industrial processes. They can also
come from specific industries or can
be discarded commercial products.
A waste is determined to be a hazardous
waste if it is specifically included
on one of four lists - F, K, P
or U - that are found in Part 261 of
Title 40 of the Code of Federal Regulations
(CFR) [8].
F-List. The F-List identifies wastes
from common manufacturing and
industrial processes as hazardous.
Because the processes generating
these wastes can occur in different
sectors of the industry, F-List wastes
are known as wastes from nonspecific
sources. These wastes are divided
into seven groups that depend
on the type of manufacturing or industrial
operation that creates them:
1. Spent solvent wastes
2. Electroplating and other metalfinishing
wastes
3. Dioxin-based wastes
4. Waste from chlorinated
aliphatic hydrocarbons
production
5. Waste from woodpreserving
activities
6. Sludge from petroleum
refinery wastewater
treatment
7. Multisource leachate
K-List. The K-List identifies
hazardous wastes
from specific sectors of
the industry and manufacturing
that are considered to be
source-specific wastes. To qualify
as a K-listed hazardous waste, an
item must fit into one of the 13 categories
on the list, and the waste
must match one of the detailed KList
waste descriptions in the dedicated
CFR section. The processes
that generate K-List wastes are
as follows:
1. Wood preservation
2. Organic chemicals manufacturing
3. Pesticides manufacturing
4. Petroleum refining
5. Veterinary pharmaceuticals manufacturing
6.
Inorganic pigment manufacturing
7. Inorganic chemicals manufacturing
8. Explosives manufacturing
9. Iron and steel production
10. Primary aluminum production
11. Secondary lead processing
12. Ink formulation
13. Coking
P-and U-Lists. The P-and U-Lists
designate hazardous waste as pure,
commercial-grade formulations of
certain unused chemicals that are
being disposed of. For a waste to
be considered a P- or U-List, it must
meet the following criteria: the waste
must contain one of the chemicals
listed on the P- or U-List; the
chemical in the waste must be unused;
and the chemical in the waste
must be in the form of a commercial
chemical product.
The P-List identifies acute hazardous
wastes from discarded commercial
chemical products. The
U-List identifies hazardous wastes
from discarded commercial chemical
products. Both the P- and U-listed
chemicals refer to materials or products
that can no longer be used for
CHEMICAL ENGINEERING WWW.CHEMENGONLINE.COM AUGUST 2021
FIGURE 2. The disaster risks that chemical plants must consider
include potential loss of containment of highly hazardous materials,
leading to contamination of water, air or soil
their intended purpose. However, the
P-listed chemicals are referred to as
acutely hazardous waste because
they are very hazardous even in small
amounts, such as cyanides.
Other hazardous wastes. Other
hazardous wastes are known as
characteristic wastes. These are
wastes that exhibit any one or more
of the following characteristic properties:
ignitability, corrosivity, reactivity
or toxicity.
Engineers at CPI facilities should
consult the EPA's website for an inventory
of listed and characteristic
wastes. State regulatory requirements
for waste generators may be
more stringent than those of the federal
RCRA program, so as previously
said, it is crucial to check state-specific
policies as well [9].
Emergency contingency plans
Once hazardous wastes are classified,
the next step is to not only
keep up with day-to-day operations,
proper waste segregation and yearround
compliance - but also to account
for extreme circumstances.
Being prepared for potential disasters
can help CPI firms to mitigate
some potential damage and safeguard
employees, communities and
the environment. Outlined here and
in the following sections are several
steps to take to protect facilities in
the event of a disaster.
Every large CPI facility should have
a contingency plan in place for extreme
weather events, which includes
an emergency response plan. Some
third-party waste management providers
may create this on a firm's
behalf as part of an existing or new
service agreement.
To begin, it is recommended to
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Chemical Engineering August 2021

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