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Solid and Hazardous Waste Management

Lecture 3 RCRA Definition and Waste Identifications


Lecture 3 RCRA Definition and Waste Identification

First Step in RCRA


Define a Solid Waste Define a Hazardous Waste
For a waste to be a hazardous waste it must be a solid waste.

Lecture 3 RCRA Definition and Waste Identification

What is a Solid Waste?

Lecture 3 RCRA Definition and Waste Identification

Statutory Definition of Solid Waste


The term ''solid waste'' means any garbage, refuse, sludge from a waste treatment plant, water supply treatment plant, or air pollution control facility and other discarded material, including solid, liquid, semisolid, or contained gaseous material resulting from industrial, commercial, mining, and agricultural operations, and from community activities, but does not include solid or dissolved material in domestic sewage, or solid or dissolved materials in irrigation return flows or industrial discharges which are point sources subject to permits under section 1342 of title 33, or source, special nuclear, or byproduct material as defined by the Atomic Energy Act of 1954.
Lecture 3 RCRA Definition and Waste Identification

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

Lecture 3 RCRA Definition and Waste Identification

Abandoned
The term abandoned simply means thrown away. A material is abandoned if it is disposed of, burned, or incinerated.

Lecture 3 RCRA Definition and Waste Identification

Inherently Waste-Like
Some materials pose such a threat to human health and the environment that they are always considered solid wastes. Examples include certain dioxin containing wastes.

Lecture 3 RCRA Definition and Waste Identification

Military Munition
Unused defective munitions are solid wastes when abandoned or treated prior to disposal; rendered non recyclable or nonuseable through deterioration; or declared a waste by an authorized military official.

Lecture 3 RCRA Definition and Waste Identification

Recycled
A material is recycled if it is used or reused (e.g. as an ingredient in an process) or reclaimed. A material is reclaimed if it is processed to recover a useable product, or if it is regenerated through processing to remove contaminants in a way that restores their useable condition.
Lecture 3 RCRA Definition and Waste Identification

Special rules often apply to wastes that are recycled. This is done to encourage appropriate recycling, while discouraging sham recycling. We will discuss this later in class when discussing recycling.

Lecture 3 RCRA Definition and Waste Identification

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!

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Solid Waste Industrial Wastewater Discharges Excluded from definition if the discharge has a CWA NPDES permit.

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Solid Waste Irrigation Return Flows

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Solid Waste Radioactive Wastes Regulated under the Atomic Energy Act

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Solid Waste In-situ Mining Wastes For mining operations where a solvent is added directly to a mineral deposit in the ground.

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Solid Waste Pulping Liquors Corrosive material used to dissolved wood chips for manufacturing of paper. Excluded if the pulping liquors are reclaimed in a recovery furnace and then reused in the pulping process.

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Solid Waste Spent Sulfuric Acid Excluded if recycled to produce virgin sulfuric acid.

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Solid Waste Closed Loop Recycling Spent materials that are reclaimed and returned to the original process in an enclosed system of pipes and tanks are excluded.

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Solid Waste Spent Wood Preservatives Spent materials collected on drip pads or in sumps that are returned to the process where they are reused in the same manner are excluded.

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Solid Waste Coke By-Product Wastes Applies to certain coke by-product wastes that are recycled into new products.

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Solid Waste 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.

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Solid Waste Recovered Oil from Petroleum Refining Operations Material is excluded when the material is used in the refining process.

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Solid Waste Comparable Fuels If materials have high fuel values and meet appropriate purity requirements, they are exempt.

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Solid Waste Processed Scrap Metal Scrap metal that has been processed to make it easier to handle or transport and is sent for metals recovery is excluded.

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Solid Waste 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.

Lecture 3 RCRA Definition and Waste Identification

RCRA Hazardous Waste Regulations


40 CFR 261 -- Identification 40 CFR 262 -- Generator Requirements 40 CFR 263 -- Transporter Requirements 40 CFR 264 -- Treatment, Storage and Disposal Facilities

Lecture 3 RCRA Definition and Waste Identification

Statutory Definition of Hazardous Waste


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 an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness; or (B) pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed.
Lecture 3 RCRA Definition and Waste Identification

Challenge
How do you create regulations that meet the spirit of the law but that do not result in expensive and time consuming testing requirements.

Lecture 3 RCRA Definition and Waste Identification

A Number of Solid Wastes are Excluded from Definition as Hazardous Wastes

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Hazardous Waste

Household Hazardous Waste

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Hazardous Waste

Agricultural Waste

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Hazardous Waste

Mining Overburden

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Hazardous Waste

Bevil and Bensten Waste

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Hazardous Waste

Fossil Fuel Combustion Wastes

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Hazardous Waste

Oil, Gas, and Geothermal Wastes

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Hazardous Waste

Mining and Mineral Processing Wastes

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Hazardous Waste

Cement Kiln Dust

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Hazardous Waste

Trivalent Chromium Wastes


1.2 1.0 0.8 0.6 0.4 0.2 0.0 -0.2 -0.4 -0.6

Cr2O7 -

Eh (volts)

Cr

3+

CrO4 2-

Cr2O3

10

12

14

pH Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Hazardous Waste

Arsenical Treated Wood

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Hazardous Waste

Petroleum-Contaminated Media and Debris from Underground Storage Tanks

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Hazardous Waste

Spent Chlorofluorocarbon Refrigerants

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Hazardous Waste

Used Oil Filters

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Hazardous Waste

Used Oil Distillation Bottoms

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Hazardous Waste

Raw Material, Product Storage, and Process Unit Waste

Lecture 3 RCRA Definition and Waste Identification

Exclusions from the Definition of Hazardous Waste

Sample and Treatability Wastes

Lecture 3 RCRA Definition and Waste Identification

Two Primary Mechanisms for being a Hazardous Waste


Listed Characteristic

Lecture 3 RCRA Definition and Waste Identification

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

Lecture 3 RCRA Definition and Waste Identification

Criteria for Listing


1. The waste typically contains harmful chemicals which indicate that it could pose a threat to human health and the environment in the absence of special regulations. Toxic Listed Waste
Lecture 3 RCRA Definition and Waste Identification

Criteria for Listing


2. The waste contains such dangerous chemicals that it could pose a threat to human health and the environment even when properly managed. These wastes are fatal to humans and animals even in low doses. Acutely Hazardous Waste
Lecture 3 RCRA Definition and Waste Identification

Criteria for Listing


3. The waste typically exhibits one of four characteristics of hazardous waste:
Ignitability Corrosivity Reactivity Toxicity

Lecture 3 RCRA Definition and Waste Identification

Criteria for Listing


4. EPA has cause to believe that, for some reason, the waste typically fits within the statutory definition of hazardous waste developed by Congress.

Lecture 3 RCRA Definition and Waste Identification

Listed Wastes are Assigned Hazard Codes Hazard codes indicate why a waste is listed.
T H I C R E Toxic Waste Acute Hazardous Waste Ignitable Waste Corrosive Waste Reactive Waste Toxicity Characteristic Waste
Lecture 3 RCRA Definition and Waste Identification

The F List - Wastes from nonspecific sources Spent solvent wastes Electroplating and other metal finishing wastes Dioxin-bearing wastes Chlorinated aliphatic hydrocarbon production wastes

Lecture 3 RCRA Definition and Waste Identification

The F List - Wastes from nonspecific sources Wood Preserving Wastes Petroleum Refinery wastewater treatment sludges Multisource leachate

Lecture 3 RCRA Definition and Waste Identification

Example F Waste
F009 -- Spent stripping and cleaning bath solutions from electroplating operations where cyanides are used in the process. Hazard Codes: R, T

Lecture 3 RCRA Definition and Waste Identification

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-, and hexachlorobenzenes under alkaline conditions. Hazard Code: H
Lecture 3 RCRA Definition and Waste Identification

The K List - Wastes from Specific Sources Wood Preservation Organic Chemical Manufacturing Pesticides Manufacturing Petroleum Refining Primary Copper Production Primary Zinc Production Ferroalloys Production
Lecture 3 RCRA Definition and Waste Identification

The K List - Wastes from Specific Sources Vetrinary Pharmaceuticals Manufacturing Inorganic Pigment Manufacturing Inorganic Chemicals Manufacturing Explosives Manufacturing Iron and Steel Production Primary Lead Production
Lecture 3 RCRA Definition and Waste Identification

The K List - Wastes from Specific Sources Primary Aluminum Production Secondary Lead Processing Ink Formulation Coking

Lecture 3 RCRA Definition and Waste Identification

Example K Waste
K027 -- Centrifuge and distillation residues from toluene diisocyanate production. Hazard Code: R, T

Lecture 3 RCRA Definition and Waste Identification

Example K Waste
K088 -- Spent potliners from primary aluminum production. Hazard Code: T

Lecture 3 RCRA Definition and Waste Identification

Example K Waste
K111 -- Production wastewaters from the production of dinitrotoluene via nitration of toluene. Hazard Code: C, T

Lecture 3 RCRA Definition and Waste Identification

The P and U Lists


Discarded Chemical Commercial Products P -- Acutely Toxic U -- Toxic and other characteristics

Lecture 3 RCRA Definition and Waste Identification

Important Tables
Appendix VII -- Basis for listing hazardous constituents Appendix VIII -- Hazardous Constituents

Lecture 3 RCRA Definition and Waste Identification

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

Lecture 3 RCRA Definition and Waste Identification

Example F Waste
F009 -- Spent stripping and cleaning bath solutions from electroplating operations where cyanides are used in the process. Hazard Codes: R, T Appendix VII -- Listed because of cyanide.
Lecture 3 RCRA Definition and Waste Identification

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-, and hexachlorobenzenes under alkaline conditions. Hazard Code: H Appendix VII -- Listed Because of dioxins and furans
Lecture 3 RCRA Definition and Waste Identification

Example K Waste
K027 -- Centrifuge and distillation residues from toluene diisocyanate production. Hazard Code: R, T Appendix VII -- Listed Because of toluene diisocyante, toluene-2, 4diamine
Lecture 3 RCRA Definition and Waste Identification

Example K Waste
K088 -- Spent potliners from primary aluminum production. Hazard Code: T Appendix VII -- Listed Because of cyanide

Lecture 3 RCRA Definition and Waste Identification

Example K Waste
K111 -- Production wastewaters from the production of dinitrotoluene via nitration of toluene. Hazard Code: C, T Appendix VII -- Listed Because of 2,4-dinitrotoluene

Lecture 3 RCRA Definition and Waste Identification

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

Lecture 3 RCRA Definition and Waste Identification

Characteristic Hazardous Wastes


Ignitability Corrosivity Reactivity Toxicity

Lecture 3 RCRA Definition and Waste Identification

Note: Characteristic hazardous wastes are D wastes.

Lecture 3 RCRA Definition and Waste Identification

Ignitability -- D001
The ignitability characteristic identifies wastes that can readily catch fire and sustain combustion.

Lecture 3 RCRA Definition and Waste Identification

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 testing method. The flash point test determines the lowest temperature at which the fumes above a waste will ignite when exposed to a flame.
Lecture 3 RCRA Definition and Waste Identification

Ignitability -- D001
A solid waste is hazardous by the 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 chemical changes and, when ignited, burns so vigorously and persistently that it creates a hazard.
Lecture 3 RCRA Definition and Waste Identification

Ignitability -- D001
A solid waste is hazardous by the ignitability characteristic if:
3. Is an ignitable compressed gas as defined in 49 CFR 173.300.

Lecture 3 RCRA Definition and Waste Identification

Ignitability -- D001
A solid waste is hazardous by the ignitability characteristic if:
4. Is an oxidizer as defined in 49 CFR 173.51.

Lecture 3 RCRA Definition and Waste Identification

Note:
Ignitability is not supposed to include all wastes that burn.

Lecture 3 RCRA Definition and Waste Identification

Corrosivity -- D002
The corrosivity characteristic identifies wastes that are acidic or alkaline and can readily corrode or dissolve flesh, metal, or other materials.

Lecture 3 RCRA Definition and Waste Identification

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.

Lecture 3 RCRA Definition and Waste Identification

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.

Lecture 3 RCRA Definition and Waste Identification

Reactivity -- D003
The reactivity characteristic identifies wastes that readily explode or undergo violent reactions.

Lecture 3 RCRA Definition and Waste Identification

Reactivity -- D003
A solid waste is hazardous by the reactivity characteristic if:
1. It is normally unstable and readily undergoes violent change without detonating.

Lecture 3 RCRA Definition and Waste Identification

Reactivity -- D003
A solid waste is hazardous by the reactivity characteristic if:
2. It reacts violently with water.

Lecture 3 RCRA Definition and Waste Identification

Reactivity -- D003
A solid waste is hazardous by the reactivity characteristic if:
3. If forms potentially explosive mixtures with water.

Lecture 3 RCRA Definition and Waste Identification

Reactivity -- D003
A solid waste is hazardous by the reactivity characteristic if:
4. When mixed with water, it generates toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health and the evironment.

Lecture 3 RCRA Definition and Waste Identification

Reactivity -- D003
A solid waste is hazardous by the reactivity characteristic if:
5. It is a cyanide or sulfide bearing waste which, when exposed to pH conditions between and 12.5, can generate toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health or the environment.
Lecture 3 RCRA Definition and Waste Identification

Reactivity -- D003
A solid waste is hazardous by the reactivity characteristic if:
6. It is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under confinement.

Lecture 3 RCRA Definition and Waste Identification

Reactivity -- D003
A solid waste is hazardous by the reactivity characteristic if:
7. It is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure.

Lecture 3 RCRA Definition and Waste Identification

Reactivity -- D003
A solid waste is hazardous by the reactivity characteristic if:
8. It is a forbidden explosive as defined in 49 CFR 173.51, or a class A explosive as defined in 49 CFR 173.53 or a class B explosive as defined in 49 CFR 173.88.

Lecture 3 RCRA Definition and Waste Identification

Toxicity -- D004-D043
The toxicity characteristic is determined using the Toxicity Characteristic Leaching Procedure (TCLP).

Lecture 3 RCRA Definition and Waste Identification

Toxicity Characteristic 40 CFR 261

Lecture 3 RCRA Definition and Waste Identification

Lecture 3 RCRA Definition and Waste Identification

TCLP (Toxicity Characteristic Leaching Procedure)


Determines Toxicity Characteristic (TC) Developed under the Resource Conservation and Recovery Act (RCRA) Representative of landfill conditions

Lecture 3 RCRA Definition and Waste Identification

TCLP Test Procedure


Select Extraction Fluid Particle Size Reduction Rotation Filtration Preserve for Analysis Acid Digestion Analyze on Appropriate Instrument Lecture 3
RCRA Definition and Waste Identification

Extraction Fluid Selection


Fluid determination based on buffering ability of the waste Fluid #1
Acetic Acid + NaOH 0.05 pH = 4.93

Fluid #2
Acetic Acid 0.05 pH = 2.88

Lecture 3 RCRA Definition and Waste Identification

Previous Test
The Extraction Procedure Toxicity Test EP Tox Test

Lecture 3 RCRA Definition and Waste Identification

Rotation 18 hours ( 2 hours)

Lecture 3 RCRA Definition and Waste Identification

Prepare Leachate Samples for Digestion

Lecture 3 RCRA Definition and Waste Identification

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 by the toxicity characteristic.

Lecture 3 RCRA Definition and Waste Identification

RCRA TC Metals
Constituent Arsenic Barium Cadmium Chromium Lead Mercury Selenium Silver
Lecture 3 RCRA Definition and Waste Identification

Regulatory Level (mg/L) 5.0 100.0 1.0 5.0 5.0 0.2 1.0 5.0

Where Did EPA Get TCLP Concentration Limits?


EPA defined what concentration would have to be placed in a landfill for it to exceed drinking water standards at a groundwater well.

Lecture 3 RCRA Definition and Waste Identification

Landfill

Lecture 3 RCRA Definition and Waste Identification

The EPA applied a dilution factor of 100 to the SDWA primary drinking water standards. Although some SDWA standards have changed, the TCLP limits have not yet changed accordingly.

Lecture 3 RCRA Definition and Waste Identification

Where do you find descriptions (recipes) for laboratory methods?


SW 846 Test Methods for Evaluating Solid Waste Available on line at the EPA web site Example: TCLP is EPA Method 1311

Lecture 3 RCRA Definition and Waste Identification

What Impacts Leaching?

pH Particle Size Liquid-to-Solid Ratio

Lecture 3 RCRA Definition and Waste Identification

Lecture 3 RCRA Definition and Waste Identification

Mixtures
A mixture of a listed hazardous waste and a nonhazardous waste is always a hazardous waste with the same hazardous waste code.

Lecture 3 RCRA Definition and Waste Identification

Exception
For a mixture of a listed waste and a nonhazardous solid waste where the listed waste was only listed because of a characteristic, and the mixture does not exhibit the characteristic, the mixture is not hazardous.

Lecture 3 RCRA Definition and Waste Identification

Derived-From Rule
Any residue from the treatment, storage or disposal of a listed is still a listed hazardous waste.

Lecture 3 RCRA Definition and Waste Identification

Derived-From Rule
.unless the waste is recycled to make new products or processed to recover useable materials with economic value (provided that product is not used in a manner constituting disposal or burned for energy recovery).

Lecture 3 RCRA Definition and Waste Identification

Contained-In Policy
Sometimes listed and characteristic wastes are spilled onto soil or contaminate equipment, buildings, or other structures. The mixture and derived-from rules do not apply because these materials are not actually wastes.

Lecture 3 RCRA Definition and Waste Identification

Contained-In Policy
Soil is considered an environmental media.

Lecture 3 RCRA Definition and Waste Identification

Contained-In Policy
Debris includes: Dismantled construction materials, such as used brick, wood beams, and chunks of concrete Decommissioned industrial equipment, such as pipes, pumps, and dismantled tanks Other discarded manufactured objects, such a personal protective equipment Large, naturally occurring objects, such as tree trunks and boulders.
Lecture 3 RCRA Definition and Waste Identification

Contained-In Policy
If media and debris contain (are contaminated by) a RCRA listed hazardous waste or exhibit a characteristic, they must be managed as if they were hazardous waste.

Lecture 3 RCRA Definition and Waste Identification

HWIR
Hazardous Waste Identification Rules HWIR -Waste HWIR-Media

Lecture 3 RCRA Definition and Waste Identification

Lecture 3 RCRA Definition and Waste Identification

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