In early June 2021, EPA became aware that some commercial hazardous waste incinerators were informing their customers (hazardous waste generators) that they would no longer accept containerized hazardous waste designated for incineration, due to a backlog at their facilities.

Generators cited a number of contributing factors for the backlog including labor shortages affecting both transportation and the incinerators due to the COVID-19 pandemic; winter storms that caused shutdowns in the southern United States; shutdowns for both scheduled and unscheduled maintenance; and increased manufacturing (and resulting increase in waste generation) as the economy recovers from the pandemic. They also indicated that this backlog at incinerators may not fully resolve until the end of the first quarter of 2022.

Due to this temporary backlog, the EPA has released a memorandum communicating other existing options under the RCRA for managing hazardous waste.  The memorandum can be found at the following link: https://www.enviro-safe.com/news/epa-news-and-rcra-incinerators-backlog

In the generator regulations at 40 CFR 262.16(d) and 40 CFR 262.17(b), SQGs and LQGs can submit a request to the authorized implementing agency for accumulation time limit extensions. These provisions are also applicable to permitted hazardous waste TSDFs for hazardous waste that they generate and accumulate onsite.

Requesting a time limit extension might help temporarily ease the regulatory burden on certain waste streams however, as Environmental Technologists focused on improving sustainability, we can audit these streams designated for incineration to see if they may be good candidates for alternative treatment.

Hazardous liquid waste streams with high BTU value could potentially go to liquid fuel blending.  Non-hazardous debris streams can go the Waste-to-Energy route.  Does the waste profile need an update?  Has something changed in the generating process over the years where listed waste codes are no longer applicable? Independent lab testing can help back up assumptions.

Throughout the course of this exercise, we are bound to identify waste volumes that can be diverted from the incineration backlog, and at the same time improve our company’s sustainability activities.

– Mike Schulte, Enviro-Safe Resource Recovery