Back to All
Blog

Any Waste, Any Place: Comprehensive Waste Management Solutions

December 4, 2024

When dealing with RCRA hazardous waste management solutions, we say, “any waste, any place,” and we really mean it.

We could start with the 55 gallons of vintage Viagra that one of our clients needed to dispose of safely and legally. But let’s not go there.

Instead, let’s talk about Rolex watches. In this case, fake Rolex watches.

 

Once upon a time:

We were tasked (at the customs facility in Memphis) to destroy five ersatz Rolex watches in front of witnesses and in the most documentable manner. While we pride ourselves on high-tech solutions to esoteric RCRA hazardous waste management problems, for this particular assignment, our weapon of choice was a deftly employed five-pound sledgehammer.

But wait! There’s more.

After the watches were convincingly pulverized, we learned that there were only four phonies. One of the watches was for real: a genuine $10,000+ Rolex “chronometer” that for some reason was condemned to the same fate as its four impersonators.

Was this some quirk of customs law? Were the agents unable to tell real from fake? Did the Rolex company itself order the real chronometer knocked off because it was hanging around with knockoffs?

Don’t ask. Don’t tell. We never found out.

 

Fashion Faux Pas: A RCRA Waste Challenge

Another case of counterfeit fashion:

In this instance, the matter needing documentable waste disposal involved bogus haute couture. To be exact: two tractor-trailer loads of fake designer dresses.

Of course, you can’t just throw a few thousand fake Diors, Armanis, or Versaces into a dumpster, as they might reemerge in the fashion black market (possibly a bit stained and smelling of fast-food orts).

Alternatively, shredding or incinerating two tractor-trailer loads of fake frocks poses a number of logistic challenges that would be of peculiar interest to the EPA. Neither can you simply start a bonfire and toast marshmallows out back behind the warehouse.

Consider just one ubiquitous component of dresses:

Nylon is a polymer made from coal and water that doesn’t break down easily. So, it’s there to stay when it finds its way into our landfills and waterways.

Compounding the problem, nylon is difficult to recycle, because it can’t tolerate high heat, which makes purging contaminants difficult (e.g., microbes, bacteria, and non-recyclable material). (See source.)

Proper RCRA hazardous waste management solutions were needed, even though our client company had never heard of such a thing, let alone think that they would ever need high-tech shredding, incinerating, and/or recycling expertise.

 

Innovative Solutions for RCRA Waste Compliance

Sometimes, what should be quick & easy turns out not to be:

We were commissioned to drain and dispose of some oil-contaminated water from a 1000-gallon holding tank made for that purpose. Piece of cake. Right?

Well, not really.

We pumped 1,000 gallons, and the level in the tank remained at 1,000 gallons. We continued pumping—up to 2,700 gallons—and the tank still had 1,000 gallons inside it.

What could be going on? Our technicians climbed under the tank—under the basement subfloor—to do some sleuthing. (Claustrophobics need not apply.)

They discovered that the feeder pipe that ran through the five-acre site had two valves that connected and fed municipal water to the waste stream. One of them, which was about 100 feet downline, was stuck open and constantly feeding it water.

The solution was to dig trenches, cap the city water lines, lay temporary pipes, void the tank, and then reassemble everything to the prevailing codes, rules, regulations, etc.

And of course, the oil-contaminated water had to be transported to a licensed treatment, storage, and disposal facility (TSDF) following RCRA hazardous waste regulations.

 

Why Choose Us for RCRA Hazardous Waste Solutions

We help where & when others won’t:

TSDFs used to be willing to work with generators when mistakes were made in the packaging or shipment of waste. Now, many won’t accept waste if anything is wrong.

We’re not like that.

For example, many times we arrive onsite to find that the ten-, thirty-, or fifty-five-gallon drums of hazmat are not RCRA compliant. E.g., they might be dented, corroded, or even leaking.

Even a small pinhole can disqualify a drum.

In such cases, we will “overpack” the hazmat. I.e., we bring the equipment and know-how to place the noncompliant drum into a larger one (e.g., 85 gallons) that does meet RCRA standards.

We just don’t turn on our heel and say “no.”

We’ve also helped clients in cases where hazmat drums are mislabeled. For example, one of our clients had a problematic employee who allowed 80 drums to accumulate onsite containing only what was supposed to be polymer-contaminated water, per the labeling.

But prior to transport, when we opened some drums and mixed samples from each into a composite bucket, the mixture erupted into a pink foam, indicating the undocumented/unlabeled presence of isocyanates; and burning isocyanate-containing materials can produce hydrogen cyanide (HCN).

In sum, we averted a RCRA non-compliance nightmare for our client company by helping them remediate a myriad of storage and labeling errors before they garnered the attention of the EPA, DOT, and/or OSHA.

That’s what we do.

 

But here’s something we won’t do:

We decided not to help one client with a single particular waste.

We took on the job of clearing, cleaning, and remediating to RCRA specs, the site of a defunct hospital scheduled for demolition. And you’d be surprised at the vast amount of hazardous waste a hospital contains—defunct or otherwise.

We’re talking old fluorescent tubes & fixtures, plaster and drywall contaminated with lead paint, decommissioned X-ray equipment, old refrigerators, and televisions, along with—of course—expired meds and chemicals among other hazmat.

We successfully conducted a veritable symphony of hazardous waste removal, sorting, labeling, transporting, and disposal for our client—all accomplished on time and within budget.

Now mind you, only two people had keys to this place for entry: our project manager (PM) and the director of the hospital.

So, one Friday afternoon, our PM commandeers a wheeled cart. He trundles from room to room throughout the hospital in search of abandoned meds and chemicals, placing them on said cart, which he then secures in a staging area before going home for the weekend.

When he returns on Monday morning, the cart is empty. And upon investigation, each med and chemical is meticulously replaced in the exact room in the exact spot from which he took it.

The director was out of town that weekend. He had no explanation. He didn’t do it. Nobody else could have done it—and why would they want to?

The prevailing explanation was ghosts. And alas, spectral waste is perhaps the only kind of detritus that we’re unprepared to remediate. So, who are ya gonna call? We’d refer you here.

Here’s the upshot:

In business and industry, it’s easy enough to suddenly own vast quantities of something that you need to move offsite—safely and legally. And almost anything you need to throw away can be considered a RCRA hazardous waste if you have enough of it.

When such happens, you need a consulting partner that can ensure you meet your cradle-to-grave RCRA responsibilities safely and legally. As an industry leader in RCRA-compliant waste management, Hazardous Waste Experts can help you facilitate the responsible and ethical disposal of any waste—any place.

Don’t go it alone.

Email or call our new number: 425.414.3485

And thank you for reading our blog!

Disposal of hazardous waste doesn’t have to be painful.