How To Recognize a Hazardous Waste Even If Its Wearing Glasses

1. How To Recognize a Hazardous WasteEven If Its Wearing Glasses

2. Classification of Hazardous Wastes • Solid Wastes • Hazardous Waste Definition • Used Oil • Other Waste Characterization Principles • Used, Reused, Reclaimed, Recycled • Delisting

3. Classification of Hazardous Wastes • Solid Wastes: • can be a solid liquid or gas • a material must first be a solid waste before it can be classified a hazardous waste • A material that has been abondoned through disposal, burning, storage, or treatment, or • recycled (including use, reuse, reclamation)

4. Classification of Hazardous Wastes • Hazardous Wastes: • First step. Is it specifically exempted? • Not a solid waste: • untreated sanitary sewage going to POTW • Point Source Discharge Permits (lagoon too) • irrigation return flows • There are other very specific exemptions: • nuclear wastes • pulping liquors • mining wastes

5. Classification of Hazardous Wastes • Solid Wastes that are not hazardous wastes: • Household wastes • Ag waste if used as fertilizer • Mining spoils return to mine • Wastes from exploration, development or production of crude oil, gas, geothermal • Cement Kiln wastes • Leather Industry, Trivalent Chromium Process

6. Classification of Hazardous Wastes • Some Hazardous Solid Wastes are regulated by other laws: • Asbestos - CAA/NESHAP • PCBs above 50ppm - TSCA • Only Two ways a solid waste can be a hazardous waste: • the waste is specifically listed as hazardous • the waste ails a characteristic test

7. Classification of Hazardous Wastes • Listed Hazardous Wastes: • EPA has authority to generally lists wastes it believes are hazardous • The waste may be delisted if you can prove that it meets delisting criteria • Delisting is granted by specific material, process and address. • Delisting will be covered later

8. Classification of Hazardous Wastes • EPA lists wastes based on three categories: • Exhibits a hazardous characteristic • ignitibility, reactivity, corrosivity, toxicity • Acutely hazardous • fatal to humans at low doses • Toxic • If it contains certain hazardous constituents. • Listing is accompanied by a hazard code • I, C, R, E, H, T

9. Classification of Hazardous Wastes • There are three lists of hazardous wastes • Non Specific Source Wastes • Specific Source Wastes • Discarded Commercial Chemical Products • Non Specific Source Wastes • Broad, General Groupings (F series) • Spent Solvents • Electroplating/Metal Finishing • Other Non Specific

10. Classification of Hazardous Wastes • Specific Source Wastes • Wastes from certain industries that EPA has defined as hazardous • K series wastes • wood preservation, organic chemicals, coking • pesticides, explosives, ink formulation, etc • Discarded Comm. Products (U/P series) • Listed in 261.33(e)(f), (very narrow) or • its sole active ingredient is listed here, and • this material is discarded for any reason.

11. Classification of Hazardous Wastes • Hazardous Waste Characteristics • Ignitability • Corrosivity • Reactivity • Toxicity

12. Classification of Hazardous Wastes • Ignitability • Applies to any physical state • Most common is Liquids (fp <140F) • Excludes Aqueous Alcohol if <24% • Other ignitable wastes include: • DOT oxidizers • Spontaneously Combustible • DOT flammable compressed gases • Assigned EPA HW# D0001

13. Classification of Hazardous Wastes • Corrosivity • Applies only to Liquids • If unsure about physical state do a paint filter liquids test • pH is greater than 12.5 or less than 2.0 • or it corrodes steel at 6.35 mm/year • Assigned EP # D0002

14. Classification of Hazardous Wastes • Reactivity (D0003) • The most Nebulous characteristic • No repeatable, sound test method • Meant to identify wastes that have the potential to explode or release toxic gases during the waste management process • The determination is based ultimately on the your knowledge of your waste and a regulatory interpretation.

15. Classification of Hazardous Wastes • The regulatory language • normally unstable, undergoes violent change • reacts violently with water • forms explosive mixtures with water • explosive if heated under confinement • detonates, explosive decomposition, or reaction at standard T and P • is a DOT forbidden, A, or B, explosive • cyanide and sulfide available for release

16. Classification of Hazardous Wastes • Toxicity Characteristic (TC) • The TC is based on the results of the TCLP. • Extraction by DI water and acetic acid • 8 heavy metals, 4 insecticides, 2 herbicides, and 25 other organic compounds • Extraction in analyzed to determine if any of these 39 compounds exceed their MCL • Assigned EPA# D0004-D043

17. Classification of Hazardous Wastes • TC Exemptions • If the waste contains PCB that meets the TSCA • Wastes that meet the MCL for Chromium if • waste not otherwise listed and < other MCLs • waste and process is trivalent chromium • waste is managed in non oxidizing environments • TCLP Shortcut (if waste contains less than 20 times MCL of a contaminant, the dilution extraction CAN NOT exceed the MCL

18. Classification of Hazardous Wastes • Other Classification Rules: • non-listed wastes carry the EPA#’s for each of the characteristics it exhibits • listed wastes that also meet a characteristic code, are classified by all codes, but • a listed waste does not carry the waste number for the characteristics it was listed for • Samples sent for analysis are not classed as Hazardous Wastes if they are packaged to prevent leaks and vaporization

19. Classification of Hazardous Wastes • Used Oil (six questions): • Is it used oil (crude or synthetic used as oil) • Is the used oil mixed with a HazWaste • Does the oil contain >1000ppm halogens • Is it used oil fuel • Is it a hazardous waste fuel • Is the used oil fuel, specification used oil fuel • Ar, Cd, Cr, Pb, FP>100F, Halogen <4000ppm

20. Classification of Hazardous Wastes • Empty Containers • all material commonly possible removed, and • no more than iI” residue on the bottom, or • residue is less than 3% by weight <110G • residue is less than 0.3% by weight >110G • Unless the drum contained an acute hazardous material or H series waste, • then removed lining or triple rinsed.

21. Classification of Hazardous Wastes • Mixture Rule • a characteristic waste mixed with a solid waste is a hazardous waste if it exhibits a characteristic • a listed waste mixed with a solid waste is always a hazardous waste, unless • the listed waste is listed only because of a characteristic and the mixture exhibits a characteristic.