rcra def and waste indentifications lecture3.pdf

7/29/2019 RCRA Def and Waste Indentifications Lecture3.pdf

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Lecture 3

RCRA Definition and Waste Identification

Solid and Hazardous WasteManagement

Lecture 3

RCRA Definition and WasteIdentifications


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Lecture 3


First Step in RCRA Define a Solid Waste

Define a Hazardous Waste For a waste to be a hazardous waste itmust be a solid waste.


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Lecture 3


What is a Solid Waste?


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Statutory Definition of Solid WasteThe term ''solid waste'' means any garbage, refuse,

sludge from a waste treatment plant, water supplytreatment plant, or air pollution control facilityand other discarded material, including solid,liquid, semisolid, or contained gaseous material

resulting from industrial, commercial, mining, andagricultural operations, and from communityactivities, but does not include solid or dissolvedmaterial in domestic sewage, or solid or dissolved materials in irrigation return flows or industrial discharges which are point sourcessubject to permits under section 1342 of title 33,or source, special nuclear, or byproduct materialas defined by the Atomic Energy Act of 1954.


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The regulations further define solid waste as any material that is discardedby being either abandoned, inherentlywaste-like, a certain military munition, or recycled.


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Abandoned The term abandoned simply means

thrown away. A material is abandonedif it is disposed of, burned, or incinerated.


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Inherently Waste-Like Some materials pose such a threat to

human health and the environment thatthey are always considered solidwastes.

Examples include certain dioxin

containing wastes.


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Military Munition Unused defective munitions are solid

wastes when abandoned or treatedprior to disposal; rendered nonrecyclable or nonuseable throughdeterioration; or declared a waste by an

authorized military official.


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Recycled A material is recycled if it is used or

reused (e.g. as an ingredient in anprocess) or reclaimed.

A material is reclaimed if it is processedto recover a useable product, or if it is

regenerated through processing toremove contaminants in a way thatrestores their useable condition.


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Special rules often apply to wastes thatare recycled.

This is done to encourage appropriaterecycling, while discouraging sham

recycling. We will discuss this later in class when

discussing recycling.


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Exclusions from the Definition of Solid Waste

Domestic Sewage Regulated under the Clean Water Act Note : Grit, Scum, and Sludge produced

from POTWs are solid wastes!


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Industrial Wastewater Discharges Excluded from definition if the discharge

has a CWA NPDES permit.


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Irrigation Return Flows


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Radioactive Wastes Regulated under the Atomic Energy Act


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In-situ Mining Wastes For mining operations where a solvent

is added directly to a mineral deposit inthe ground.


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Pulping Liquors Corrosive material used to dissolved

wood chips for manufacturing of paper. Excluded if the pulping liquors are

reclaimed in a recovery furnace andthen reused in the pulping process.


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Lecture 3RCRA Definition and Waste Identification


Spent Sulfuric Acid Excluded if recycled to produce virgin

sulfuric acid.


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Closed Loop Recycling Spent materials that are reclaimed and

returned to the original process in anenclosed system of pipes and tanks areexcluded.


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Spent Wood Preservatives Spent materials collected on drip pads

or in sumps that are returned to theprocess where they are reused in thesame manner are excluded.


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Coke By-Product Wastes Applies to certain coke by-product

wastes that are recycled into newproducts.


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Splash Condenser Dross Residue Dross is a zinc laden residue generated

during steel production. Contains 50-60% zinc and is thus

recycled, and when done so safely, the

dross is exempt.


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Recovered Oil from Petroleum RefiningOperations

Material is excluded when the materialis used in the refining process.


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Comparable Fuels If materials have high fuel values and

meet appropriate purity requirements,they are exempt.


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Processed Scrap Metal Scrap metal that has been processed to

make it easier to handle or transportand is sent for metals recovery isexcluded.


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Shredded Circuit Boards Whole circuit boards meet the definition

of scrap metal. Shredded circuit boards are also

excluded as long as they are free of

potentially dangerous components.


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RCRA Hazardous WasteRegulations

40 CFR 261 -- Identification

40 CFR 262 -- Generator Requirements 40 CFR 263 -- Transporter Requirements 40 CFR 264 -- Treatment, Storage and

Disposal Facilities


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The term ''hazardous waste'' means a solid waste,or combination of solid wastes, which because of its quantity, concentration, or physical, chemical,or infectious characteristics may -

(A) cause, or significantly contribute to anincrease in mortality or an increase in seriousirreversible, or incapacitating reversible, illness;

or

(B) pose a substantial present or potential

hazard to human health or the environment whenimproperly treated, stored, transported, or disposed of, or otherwise managed.

Statutory Definition of Hazardous Waste


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Challenge How do you create regulations that

meet the spirit of the law but that do notresult in expensive and time consumingtesting requirements.


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A Number of Solid Wastes areExcluded from Definition asHazardous Wastes


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Exclusions from the Definition of Hazardous Waste

Household Hazardous Waste


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Agricultural Waste


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Mining Overburden


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Bevil and Bensten Waste


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Fossil Fuel Combustion Wastes


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Oil, Gas, and Geothermal Wastes


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Mining and Mineral Processing Wastes


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Cement Kiln Dust


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Trivalent Chromium Wastes

pH

1.21.00.80.6

0.40.20.0-0.2-0.4-0.6

Cr 2O3

CrO 4 2-

Cr 2O 7 -

Cr 3+

E h ( v o

l t s

)

0 2 4 6 8 10 12 14


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Arsenical Treated Wood


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Petroleum-Contaminated Media andDebris from Underground StorageTanks


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Spent Chlorofluorocarbon Refrigerants


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Used Oil Filters


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Used Oil Distillation Bottoms


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Raw Material, Product Storage, andProcess Unit Waste


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Sample and Treatability Wastes


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Two Primary Mechanisms for being a Hazardous Waste

Listed Characteristic


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Listed Wastes The F List The K List The P List The U List


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Criteria for Listing1. The waste typically contains harmful

chemicals which indicate that it couldpose a threat to human health and theenvironment in the absence of specialregulations.

Toxic Listed Waste


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Criteria for Listing2. The waste contains such dangerous

chemicals that it could pose a threat to

human health and the environmenteven when properly managed. Thesewastes are fatal to humans and animalseven in low doses.

Acutely Hazardous Waste


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Criteria for Listing3. The waste typically exhibits one of four

characteristics of hazardous waste:

Ignitability Corrosivity Reactivity Toxicity


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Criteria for Listing4. EPA has cause to believe that, for

some reason, the waste typically fitswithin the statutory definition of hazardous waste developed byCongress.


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Listed Wastes are Assigned Hazard Codes

Hazard codes indicate why a waste islisted.

T Toxic Waste H Acute Hazardous Waste I Ignitable Waste C Corrosive Waste R Reactive Waste E Toxicity Characteristic Waste


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The F List - Wastes from nonspecific sources

Spent solvent wastes Electroplating and other metal finishing

wastes Dioxin-bearing wastes Chlorinated aliphatic hydrocarbon

production wastes


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The F List - Wastes from nonspecific sources

Wood Preserving Wastes Petroleum Refinery wastewater

treatment sludges Multisource leachate


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Example F Waste F009 -- Spent stripping and cleaning

bath solutions from electroplatingoperations where cyanides are used inthe process.

Hazard Codes: R, T


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Example F Waste F022 -- Waste (except wastewater and

spent carbon from hydrogen chloridepurification) from the manufacturing use(as a reactant, chemical intermediate, or component in a formulating process) of tetra-, penta-, and hexachlorobenzenesunder alkaline conditions.

Hazard Code: H


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The K List - Wastes from Specific Sources

Wood Preservation Organic Chemical Manufacturing Pesticides Manufacturing Petroleum Refining Primary Copper Production Primary Zinc Production Ferroalloys Production


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Vetrinary PharmaceuticalsManufacturing

Inorganic Pigment Manufacturing Inorganic Chemicals Manufacturing Explosives Manufacturing Iron and Steel Production Primary Lead Production


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Primary Aluminum Production Secondary Lead Processing Ink Formulation Coking


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Example K Waste K027 -- Centrifuge and distillation

residues from toluene diisocyanateproduction.

Hazard Code: R, T


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Example K Waste K088 -- Spent potliners from primary

aluminum production. Hazard Code: T


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Example K Waste K111 -- Production wastewaters from

the production of dinitrotoluene vianitration of toluene.

Hazard Code: C, T


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The P and U Lists Discarded Chemical Commercial

Products P -- Acutely Toxic U -- Toxic and other characteristics


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Important Tables Appendix VII -- Basis for listing

hazardous constituents Appendix VIII -- Hazardous

Constituents


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CAS Number Chemical Abstracts Number

e.g. Aldrin, CAS# = 309-00-2


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Example F Waste F009 -- Spent stripping and cleaning

bath solutions from electroplatingoperations where cyanides are used inthe process.

Hazard Codes: R, T

Appendix VII -- Listed because of cyanide .


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Example F Waste F022 -- Waste (except wastewater and spent

carbon from hydrogen chloride purification)from the manufacturing use (as a reactant,chemical intermediate, or component in a

formulating process) of tetra-, penta-, andhexachlorobenzenes under alkalineconditions.

Hazard Code: H

Appendix VII -- Listed Because of dioxinsand furans


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Example K Waste K027 -- Centrifuge and distillation

residues from toluene diisocyanateproduction.

Hazard Code: R, T Appendix VII -- Listed Because of

toluene diisocyante, toluene-2, 4-diamine


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Example K Waste K088 -- Spent potliners from primary

aluminum production. Hazard Code: T Appendix VII -- Listed Because of

cyanide


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Example K Waste K111 -- Production wastewaters from

the production of dinitrotoluene vianitration of toluene.

Hazard Code: C, T Appendix VII -- Listed Because of

2,4-dinitrotoluene


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Wastes May Be Delisted Petition must be filed with EPA Must prove that waste does not:

Meet the criteria for which it was listed Exhibit any characteristic Pose at threat to human health of the

environment


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Characteristic HazardousWastes

Ignitability

Corrosivity Reactivity Toxicity


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Note: Characteristic hazardouswastes are D wastes.


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Ignitability -- D001 The ignitability characteristic identifies

wastes that can readily catch fire and

sustain combustion.


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Ignitability -- D001 A solid waste is hazardous by the

ignitability characteristic if:1. It is a liquid and has a flash point less that

60 C ( 140 F) via a specified testingmethod.

The flash point test determines the lowesttemperature at which the fumes above awaste will ignite when exposed to a flame.


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ignitability characteristic if:

2. It is not a liquid and is capable, under standard temperature and pressure, of causing fire through friction absorption of moisture or spontaneous chemicalchanges and, when ignited, burns sovigorously and persistently that it creates ahazard.


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ignitability characteristic if:3. Is an ignitable compressed gas as defined

in 49 CFR 173.300.


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ignitability characteristic if:4. Is an oxidizer as defined in 49 CFR

173.51.


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Note: Ignitability is not supposed to include all

wastes that burn.


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Corrosivity -- D002 The corrosivity characteristic identifies

wastes that are acidic or alkaline and

can readily corrode or dissolve flesh,metal, or other materials.


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Corrosivity -- D002 A solid waste is hazardous by the

corrosivity characteristic if:1. Is aqueous and has a pH less than or

equal to 2 or greater or equal to 12.5.


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Corrosivity -- D002 A solid waste is hazardous by the

corrosivity characteristic if:2. Is a liquid and corrodes steel at a rate

greater than 6.35 mm (0.25 inch) per year at 55 C.


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Reactivity -- D003 The reactivity characteristic identifies

wastes that readily explode or undergo

violent reactions.


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Reactivity -- D003 A solid waste is hazardous by the

reactivity characteristic if:1. It is normally unstable and readily

undergoes violent change withoutdetonating.


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reactivity characteristic if:2. It reacts violently with water.


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reactivity characteristic if:3. If forms potentially explosive mixtures with

water.


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reactivity characteristic if:4. When mixed with water, it generates toxic

gases, vapors, or fumes in a quantitysufficient to present a danger to humanhealth and the evironment.


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reactivity characteristic if:

5. It is a cyanide or sulfide bearing wastewhich, when exposed to pH conditionsbetween and 12.5, can generate toxicgases, vapors or fumes in a quantity

sufficient to present a danger to humanhealth or the environment.


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reactivity characteristic if:

6. It is capable of detonation or explosivereaction if it is subjected to a stronginitiating source or if heated under confinement.


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Reactivity -- D003

A solid waste is hazardous by thereactivity characteristic if:

7. It is readily capable of detonation or explosive decomposition or reaction atstandard temperature and pressure.


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Reactivity -- D003

A solid waste is hazardous by thereactivity characteristic if:

8. It is a forbidden explosive as defined in 49CFR 173.51, or a class A explosive asdefined in 49 CFR 173.53 or a class Bexplosive as defined in 49 CFR 173.88.


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Toxicity -- D004-D043

The toxicity characteristic is determinedusing the Toxicity Characteristic

Leaching Procedure (TCLP).


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TCLP (Toxicity Characteristic

Leaching Procedure)

Determines Toxicity Characteristic (TC)

Developed under the Resource Conservationand Recovery Act (RCRA)

Representative of landfill conditions


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TCLP Test ProcedureSelect Extraction Fluid

Particle Size Reduction

Rotation

Filtration

Preserve for Analysis

Acid Digestion

Analyze on Appropriate Instrument


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Extraction Fluid Selection

Fluid determination based on bufferingability of the waste

Fluid #1 Acetic Acid + NaOH pH = 4.93

0.05

Fluid #2 Acetic Acid pH = 2.88 0.05


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Previous Test

The Extraction Procedure Toxicity TestEP Tox Test


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Rotation 18 hours

( 2 hours)


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Prepare Leachate Samples for

Digestion


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Analyze for the Chemical of

Concern in the Leachate Compare the chemical of concern to the

appropriate limit. If the leachate concentration is greater than the limit, it is a hazardous waste bythe toxicity characteristic.


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RCRA TC MetalsConstituent Regulatory Level (mg/L)

Arsenic 5.0

Barium 100.0

Cadmium 1.0

Chromium 5.0

Lead 5.0

Mercury 0.2

Selenium 1.0

Silver 5.0


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Where Did EPA Get TCLP

Concentration Limits?

EPA defined what concentration wouldhave to be placed in a landfill for it toexceed drinking water standards at agroundwater well.


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The EPA applied a dilution factor of 100to the SDWA primary drinking water

standards. Although some SDWA standards have

changed, the TCLP limits have not yetchanged accordingly.


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Where do you find descriptions

(recipes) for laboratory methods? SW 846

Test Methods for Evaluating SolidWaste Available on line at the EPA web site Example: TCLP is EPA Method 1311


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What Impacts Leaching?

pH Particle Size Liquid-to-Solid Ratio


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Mixtures

A mixture of a listed hazardous wasteand a nonhazardous waste is always a

hazardous waste with the samehazardous waste code.


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Exception

For a mixture of a listed waste and anonhazardous solid waste where the

listed waste was only listed because of a characteristic, and the mixture doesnot exhibit the characteristic, themixture is not hazardous.


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Derived-From Rule

Any residue from the treatment, storageor disposal of a listed is still a listed

hazardous waste.


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Derived-From Rule

.unless the waste is recycled to makenew products or processed to recover

useable materials with economic value(provided that product is not used in amanner constituting disposal or burnedfor energy recovery).


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Contained-In Policy

Sometimes listed and characteristicwastes are spilled onto soil or

contaminate equipment, buildings, or other structures. The mixture andderived-from rules do not apply becausethese materials are not actually wastes.


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Contained-In Policy

Soil is considered an environmentalmedia.


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Contained-In Policy

If media and debris contain (arecontaminated by) a RCRA listed

hazardous waste or exhibit acharacteristic, they must be managedas if they were hazardous waste.


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rcra def and waste indentifications lecture3.pdf

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