Forms

Material Characterization Forms (MCF) FAQs

Material Characterization Forms (MCF)

Section 4. Process Description

Question:
What if the process is confidential in nature?

Answer:
Covanta Secure Services needs to establish that the waste is nonhazardous and that it meets our acceptance criteria. Our interest is in regulatory and combustion characteristics of the waste. In any case that a trade secret would need to be revealed, a Confidentiality Agreement can be arranged. This may require speaking to someone else in your organization that can address these issues without compromising confidentiality.

References:
40 CFR Process Flow Diagram
State of Generation Regulations

Section 5. Regulatory Waste Classification

Question:
What is a hazardous waste?

Answer:
A hazardous waste is any waste which meets the criteria for a listed hazardous waste per 40 CFR 261.31, 261.32 and 261.33 and/or which meets any of the criteria for a characteristic hazardous waste per 40 CFR 261.21, 261.22, 261.23 and 261.24. A hazardous waste also includes any waste which is deemed to be hazardous in the state of generation and/or state of disposal based upon state or local regulations.

References:
40 CFR Part 261, 279
State of Generation Regulations

Question:
What is a waste exemption?

Answer:
Waste exemptions can, under the specific circumstance, exempt certain materials from regulated status, allowing them to be characterized as nonhazardous. Please Note: Covanta Secure Services does not accept waste that is exempt due to the small quantity generator exemption including conditionally exempt.

References:
40 CFR Part 261, 279
State of Generation Regulations

Section 7. Waste Characterization

Question:
Why do we need to know the physical form?

Answer:
Physical form will determine how we handle the material at the facility. Examples: waxy solids can melt before they burn, this can cause operational problems in the combustor. Powders can create a dusting problem causing health and safety concerns such as: dust inhalation, skin exposure, eye exposure.

References:
Process Line Technicians/Health and Safety/Environmental Specialist (internal)
Material Safety Data Sheets

Question:
Why is color and odor required?

Answer:
For facility QA/QC, personnel receiving the materials need to verify the general description.

References:
Process line Technicians/Health and Safety/Environmental Specialist (internal)
Material Safety Data Sheets

Question:
Why is BTU needed?

Answer:
Because the waste is a fuel and some facilities have permit limitations or tighter operational constraints on Higher Heating Value of waste. The BTU value determines how waste is processed.

References:
Process line Technicians/Health and Safety/Environmental Specialist (internal)
Material Safety data Sheets

Question:
What are the Department of Transportation Standards?

Answer:
The DOT Standards are guidelines set by the United States Department of Transportation to assure safe transport of all materials. (49 CFR).

References:
Search for The Code of Federal Regulations
Transportation Section

Section 8.Waste Composition

Question:
How do I determine if any of these constituents are in the waste?

Answer:
In order to determine whether or not a waste is acceptable for disposal at a Covanta EfW plant, it is necessary to properly categorize the waste. While it may seem that a standard hazardous/non-hazardous determination would be sufficient such is not the case. Determining if a waste is hazardous by testing for flash point or doing TCLP analysis is essential since Covanta facilities are prohibited from accepting hazardous waste. However, due to other permit requirements, this determination alone is not sufficient.

References:
Covanta Secure Services Environmental Health and Safety
Process Technicians/Engineers(Internal)

Question:
Why do you need to know the type & weight percentage of packaging?

Answer:
Each facility has an air permit that specifies emission limits. Included in these limits are the 16 metals Covanta requires analysis for as well as Halogens and Sulfur. Each waste is reviewed to ensure no component of the waste would give rise to an emission that would exceed those stated in the permit. Only a total metals, halogen and sulfur analysis will provide the information necessary for this review.

References:
Covanta Secure Services Environmental Health and Safety
Process Technicians/Engineers(Internal)

Question:
Why do you need to understand weight percent of inert material?

Answer:
In some cases, the facility solid waste permit also establishes maximum contaminant levels of metals in the materials being disposed of. Again, only total metals analysis of the waste will allow Covanta to determine the suitability of the waste as a fuel for our boilers.

References:
Covanta Secure Services Environmental Health and Safety
Process Technicians/Engineers(Internal)

Section 9. Non-Hazardous Certification

Question:
What does it mean to certify something?

Answer:
Certification, according to 40 CFR Part 261, means a professional opinion based upon knowledge and belief.

References:
Covanta Secure Services Environmental Health and Safety
Process Technicians/Engineers(Internal)

Question:
Can a Third Party sign a non-hazardous certification?

Answer:
Yes. If the Generator has signed the Third Party Authorization section of the Broker Information Form.

References:
40 CFR Part 261
Internal Environmental Specialist

Question:
If I have signed this section, why do I need to provide any other backup documentation?

Answer:
In the event that a regulator wants to audit your files, we have established an auditable document. Also, many Covanta Secure Services customers have turned to CSS for copies of documents for internal audits and record keeping.

References:
40 CFR Part 261
Internal Environmental Specialist

Third Party Authorization Form

Question:
As a waste generator, am I required to complete the Third Party Authorization section?

Answer:
This is an optional section for completion by the generator. Complete this section IF you wish to have your service provider assume characterization responsibility.

References:
40 CFR Part 260, 261
State of Generation Regulations

Question:
As a waste generator, why would I choose to authorize my service provider?

Answer:
Authorizing a third party will allow that service provider to make representations for you as it pertains to the Covanta Secure Services waste approval process. This will help to streamline the process for you.

References:
40 CFR Part 260, 261
State of Generation Regulations

Question:
What is the service company authorized to do?

Answer:
By signing the Third Party Authorization, The generator is allowing the service company to answer any and all questions and provide needed information on the generator's behalf and to sign off on any changes made to the MCFs.

References:
40 CFR Part 260, 261
State of Generation Regulations

Question:
What requirements does this authorization place on the third party?

Answer:
The service provider becomes an agent for the generator in addressing all Covanta Secure Services related matters. In some situations, Covanta Secure Services may require the third party to provide information on an expedited basis. This third party will facilitate that exchange of information.

References:
40 CFR Part 260, 261
State of Generation Regulations

Oil Waste Addendum Form

Question:
How do I know when to use the Oily Waste Addendum Form?

Answer:
The Oily Waste Addendum Form is to be used for wastes which are contaminated with or consists of hydrocarbon fuels, oils or filters for fuels or oils. Also please see the glossary for a definition.

References:
40 CFR Part 261, 279
State of Generation Regulations