Crash Course in Hazardous Waste Management Characterization, Requirements, Compliance, and

Exemptions

John M. BakeriSi Environmental

Consulting Services Manager 1

RCRA Hazardous Waste Management

To safely manage hazardous waste, you must know exactly what a waste is, how it will act, and what its properties are.

Is the waste ignitable or flammable? Is the waste corrosive, will it corrode

certain types of containers? Is the waste incompatible with other

wastes -will it react (explode, catch on fire) when mixed with another waste or water?

Is the waste toxic? Do workers need special protection?

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RCRA Hazardous Waste Management

Once a waste is generated, it should be characterized, before you place the waste in a container.

The six questions you should ask yourself are:Is it a solid waste?Is it exempt from the haz wst regulations?Is it a Characteristic Waste?Is it a Listed Waste?Is it a mixture of waste?Is it derived from the treatment storage or disposal of waste?

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RCRA Hazardous Waste Management

Once a waste is generated, it should be characterized, before you place the waste in a container. Waste characterization can be done by either:

1) sampling and analyzing the waste, or,2) identifying the waste based on process knowledge (you know the constituents in the process and therefore you can use that knowledge to determine if the resulting waste has characteristics that could make the waste hazardous)

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Defining Hazardous Waste

To be a hazardous waste, the material must first be a solid waste as defined by 40 CFR 261.2.

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Defining Solid Waste

A solid waste is a material that is discarded. A material is considered discarded if it is:

Abandoned Recycled Considered inherently

waste-like

May be a liquid, solid, gas or any combination.

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Defining Hazardous Waste

Is it a Solid Waste?.Is excluded in the regulations?

Domestic sewage discharged to the sewer or drain under a permit or with written permission.

Point source discharges (regulated by CWA NPDES) Irrigation return Flows Spent Sulfuric Acid Pulping Liquors In situ mining wastes Spent Wood Preservatives Coke By Product Wastes Exploration, Development, and Production (ED&P) of crude oil

and natural gas. Secondary Materials from Petroleum Refinery wastes

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Defining Hazardous Waste

Exhibits characteristics of... Ignitability Corrosivity Reactivity Toxicity

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CHARACTERISTIC Hazardous Waste

FOUR GROUPS EPA HW NumberIgnitable D001 Corrosive D002Reactive D003Toxic D004-D043

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Ignitability Characteristic

EPA HW Number D001 Liquid* with Flashpoint of

<140ºF Solid that catches on fire

through friction or is spontaneously combustible

Examples: Paint, paint thinners, paint filters, solvents, some compressed gasses, aqueous solutions with >24% alcohol

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Corrosivity Characteristic

EPA HW Number D002 Aqueous material with pH

<2 & >12.5 Liquid that corrodes steel

at >¼ inch per year Examples: HCl, HNO3,

H2SO4, H3PO4 (acids), NaOH, KOH (hydroxides), solutions used to clean and degrease metal parts prior to coating

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Reactivity Characteristic

EPA HW Number D003Normally unstable, undergoes violent change without explodingReacts violently with waterProduces toxics when mixed with water

Examples: Waste gunpowder, sodium metal, or wastes containing cyanides or sulfides

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Toxicity Characteristic

A separate EPA HW Number is assigned to each contaminant.

Fails toxicity characteristic leaching procedure (TCLP) test.

Examples: Pesticides, Benzene, Mercury, Tetrachloroethylene

Regulatory levels listed in §261.24 table 1.

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Determining Toxicity

Toxicity characteristic leachate procedure (TCLP) Extract chemicals using a slightly acidic

solution that simulates landfill leachate. Analyze for toxics, and compare to

regulatory limits in Table 1 of the reference.

Reference: 40 CFR §261.24

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LISTEDHazardous Waste

Wastes specifically listed in 40 CFR §§261.30-34.

From non-specific sources (F list). From specific sources (K list).Discarded generic chemicals (P & U lists).

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F-Listed Wastes

Wastes from non-specific processes. Solvent Cleaning, Degreasing Electroplating Wood Preservation Petroleum Refining

Waste codes:F001 through F039

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K-Listed WastesWastes from 13 specific industry processes. Inorganic pigment industry

• Wastewater treatment sludge from the production of iron blue pigments.

Organic Chemicals Industry• Distillation bottoms from the production of 1,1,1-TCA• Heavy ends or distillation bottoms from the purification column in the

production of epichlorohydrin

Pesticides Industry• Heavy ends or distillation bottoms from the production of 2,4,5-T

Explosives• Spent carbon from the treatment of wastewater containing explosives

Iron and Steel• Spent pickle liquor generated by steel finishing operations

Primary Aluminum Veterinary Pharmaceuticals Ink Formulation Coking

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P and U Listed WastesPertains to unused commercial product or manufacturing chemical intermediate. P = Acutely toxic materials. U = Toxic.

There are specific terms that apply to P and U listed hazardous wastes Technical grade– Refers to all commercial grades of a chemical, which in some cases may be marketed in various stages of purity Sole active ingredient– Means the active ingredient is the only chemically active component for the function of the product

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P and U Listed Waste

The P and U lists designate as hazardous waste pure and commercial grade formulations of certain unused chemicals that are discarded or intended to be discarded

Unused chemicals may become wastes for a number of reasons. Some are spilled by accident, others are intentionally discarded because they are off- specification and cannot serve the purpose for which they were originally produced, and some are discarded simply because they aren’t of any use anymore

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P and U Listed Wastes

The presence of a P or U listed chemical alone does not trigger the listing. The P and U lists have a narrow applicability to unused commercial chemical products (and off-specification ccps) and manufacturing chemical intermediates.

Any chemical which has been used for its intended purpose, does not meet a P or U listing.

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P & U Lists

If P and U listed hazardous wastes have not been used for their intended purposeThe P and U listings apply to:– Commercial chemical product (CCP) or manufacturing chemical intermediate– Off-specification CCPs– Residue, soil, or debris contaminated by P or U listed chemicals– Container or inner liners removed from a container that heldP or U listed chemicals

The P and U listings apply only to the four items on this slide that are found in 261.33(a), (b), (c), & (d) 21

Mixtures of Hazardous Waste

THE “MIXTURE RULE”The entire mixture of solid waste and any amount of a listed hazardous waste (F,K,P, or U) is regulated as hazardous waste.Mixtures that contain a characteristic HW that no longer exhibits that characteristic are not regulated as hazardous waste.

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Wastes Derived From Hazardous Waste

THE “DERIVED FROM” RULEResidues derived from the treatment, storage or disposal of listed hazardous waste are always HW. Residues from characteristic hazardous waste are HW only if they continue to exhibit the characteristic(s).

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Contained In Policy

RCRA can regulate environmental media via the contained-in policy:

Environmental media that contains hazardous waste must be managed as hazardous waste until the media no longer contains the waste

Media does not contain a characteristic waste when the media no longer exhibits a characteristic

Media does not contain a waste listed for a characteristic when the media no longer exhibits a characteristic

Determination that media no longer contains listed waste is made by each individual state or EPA regional offices 24

Compliance with Empty Containers (40 CFR 261.7)

Container ResiduesA container or liner is empty when:

All waste is removed by normal procedures and <1 inch or <3% remains in a non-

bulk container <0.3% remains in a bulk container.

Does not apply to compressed gasses and acutely toxic wastes (P-list).

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Final Thoughts on Compliance Requirements

Develop and document a waste determination for each solid and hazardous waste stream,

Keep hazardous waste containers closed at all times, unless adding waste to or removing waste from,

Keep hazardous waste containers labeled, stenciled, or marked with the words “Hazardous Waste”,

Stage hazardous waste correctly with adequate aisle space and segregate incompatible hazardous waste containers,

Make sure that all hazardous waste containers are dated when in storage,

Inspect and document weekly (or monthly) hazardous waste storage containers (depending on the size of generator you are and in what state you reside),

Make sure empty chemical containers are “RCRA Empty” when disposed of

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