Hazardous waste on a paving job can be a headache for everyone. It creates safety risks for your workers who interact with the potentially harmful products on a daily basis. It increases your shipping costs because freight carriers charge special hazardous waste fees. It also puts you at risk for potential fines from the EPA and DOT inspectors because they pose risks to the environment. It’s safe to say that avoiding hazardous waste in products you use daily, asphalt release agents and asphalt removers, are incredibly important. Let’s look at how to identify and avoid hazardous waste products.
In 1976, Congress passed the Resource Conservation and Recovery Act (RCRA), found in 40 CFR parts 261 and 262. It has been amended since, and the EPA has been implementing it with their usual hard-hitting approach. Violations can result in fines of $25,000 per day per violation. Here’s the kicker: each container of hazardous waste is one violation. The resulting fines could easily put a contractor out of business altogether. RCRA deals primarily with hazardous waste.
What is Waste?
The RCRA regulations define waste, hazardous waste, the difference between the two, and what must be done with hazardous waste. For those in the paving industry, the bottom line is that any unused chemicals are waste. This includes products for cleaning, lab use, or anything brought to the plant in drums, pails, cans or bottles. Unused chemicals are waste, and any material that is used and collected to be disposed of later is waste. All of these may be subject to the RCRA regulations.
What is Hazardous Waste?
Not all waste is hazardous waste. RCRA only covers hazardous waste, so you are out of danger of fines from RCRA violations if the waste you generate are not hazardous wastes. The RCRA regulations are fairly specific. There are five ways that a waste can be considered hazardous according to RCRA. If waste is:
Ignitable: CLOSED CUP flash point below 140°F,
Corrosive: Corrodes steel or has pH outside of 2-12.5 range,
Reactive: Due to tendency to react violently when mixed with water or chemical instability; able to generate heat or explode under certain circumstances,
Toxic: Contains concentrations of certain toxic materials above specified limits, or is
Listed: In a special list (40 CFR 261,31-3) then that waste is a hazardous waste and subject to the RCRA regulations.
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How Does This Affect The Paving Industry?
The most likely way a chemical used by the paving industry could be defined as a RCRA hazardous waste is if it is ignitable. For this reason, the flash point of the chemicals you use chemicals becomes important. It is not enough that the material be of natural origin, contain no petroleum distillates or chlorinated hydrocarbons and be biodegradable. That is why NCDOT facilities, for example, have specified that asphalt-removing cleaning solvents “‘shall not be considered a hazardous waste upon disposal” (Specification No. 549, DOT No. 01 02566)
Unfortunately, not all cleaning solvents meet this criterion, For example, citrus materials currently sold into the paving market list an open cup flash point of 163°F, but a closed cup flash point of 110°F, which is characteristic of most terpene blends and is therefore considered hazardous waste.
How Does PavePro Solve Your Problems?
PavePro asphalt release agent and asphalt remover, on the other hand, is a special blend of natural-origin cleaning materials with a special emphasis on slow evaporation rate. This has two affects:
First, PavePro will not evaporate while cleaning paving equipment in the summer or under high heat. Since asphalt solvents are expensive, using them by continuously spraying one spot until it is clean is a waste of money. The most efficient way to clean paving equipment is to spray some solvent on an area, then move on to other areas, leaving the solvent to penetrate for some time. Typical terpene blends will evaporate when this money-saving technique is used. The bottom line here is that using PavePro will result in saving money and increased efficiency because of its slow evaporation rate.
A second beneficial result of this special emphasis on slow evaporation rate is that PavePro has a closed cup flash point over 400°F. This means that PavePro will never be a RCRA hazardous waste, and only PavePro has this characteristic. Therefore using PavePro nullifies the danger of being fined by the EPA for RCRA hazardous waste violations.
For a more complete discussion of RCRA and related issues, contact our PavePro sales team. They will be able to help you themselves, or put you in contact with our knowledgeable regulatory department. Just another way PavePro gives you superior service.
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