Does it Apply to Us?

Question:

Steve, thanks for your July column, “New Hazardous Waste Laws,” regarding the new DOT chemical security regulations.

While looking at our own particular situation, we think it does not apply, but want to get your opinion. We generate a wastewater treatment sludge, which has EPA waste codes of F006 and F019, from a filter press. From the filter press, the sludge is placed into one cubic yard sacks. We store the sludge for less than 90 days and, typically, ship off about 24 sacks at a time. In your opinion, does the DOT chemical security regulations apply to us? E.W.

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Answer:

E.W., first, let’s call your waste “wastewater treatment filter press cake”; “sludge” is such a “dirty” image.

Assuming that you do not generate and ship off-site any other hazardous waste or hazardous chemicals, I would concur with you that the DOT chemical security regulations do not apply to your facility for two reasons. First, while your cubic yard “super sack” is considered a bulk container by DOT, each container’s capacity is less than 17.33 cubic yards. Secondly, while a RCRA hazardous waste, the shipment of your “wastewater treatment filter press cake” does not require placarding of the transport vehicle since it is a Class 9 material.

I know that it makes no sense that a facility can ship off-site a smaller amount of waste than you but in an 18 cubic yard roll-off box, and these DOT regulations apply. Once again, our tax dollars not working well.