Professional Documents
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I hate facts. I always say the chief end of man is to form general propositions — adding that no general
proposition is worth a damn.
11.1 INTRODUCTION
As discussed in Chapter 3, the Resource Conservation and Recovery Act (RCRA) was the first truly
significant step in the comprehensive management of hazardous as well as municipal wastes in the
U.S. The ultimate goal of RCRA is to promote the protection of public health and the environment
and to conserve material and energy resources. RCRA requires the U.S. EPA to promulgate and
enforce regulations regarding the management of hazardous waste. These regulations established
mandatory procedures and requirements for compliance with RCRA. RCRA has remained current
with waste management issues and problems by being amended several times. The most sweeping
set of amendments was included in 1984 as the Hazardous and Solid Waste Amendments (HSWA).
RCRA has nine subtitles, each of which addresses some aspects of resource conservation and
waste management. Subtitle C is the primary component that deals with management of hazardous
waste. Its goal is to identify a hazardous waste and set standards for the accumulation, storage,
transportation, treatment, and disposal of hazardous waste. The provisions of Subtitle C apply to a
waste from the moment it becomes hazardous until it is no longer a hazardous waste. This embraces
the so-called “cradle-to-grave” approach to the regulation of hazardous waste.
Hazardous waste management regulations are published in the Federal Register, which is pub-
lished daily. The Federal Register provides a system for making regulations and legal notices issued
by federal agencies available to the public.
Subtitle Topic
A General Provisions
B Office of Solid Waste, Authorities of the EPA administrator
C Hazardous Waste Management
D State or Regional Solid Waste Plans
E Duties of the Secretary of Commerce in Resource Recovery
F Federal Responsibilities
G Miscellaneous Provisions
H Research, Development, Demonstration, and Information
I Underground Storage Tanks
373
Subtitle A declares that the production of hazardous waste is to be reduced; furthermore, land
disposal is to become the least favored method of hazardous waste disposal. Wastes are to be han-
dled in order to minimize the threat to human health and the environment. Subtitle A includes a set
of objectives to achieve these goals, including:
TABLE 11.1
Summary of Federal Regulations Implementing the
Hazardous Waste Management Requirements of RCRA
40 CFR Part Coverage of the Regulations
124 Public participation
260 General requirements, definitions, petitions
261 Identification and listing of hazardous waste
262 Generators of hazardous waste
263 Transporters of hazardous waste
264 Permitted hazardous waste facilities
265 Interim status hazardous waste facilities
266 Certain specific hazardous wastes and facilities
268 Land disposal restrictions
270 EPA administered permits
271 State hazardous waste programs requirements
273 Universal hazardous waste
279 Standards for the management of used oil
Part 264 presents the requirements that apply to facilities that treat, store, or dispose of haz-
ardous waste. It contains general standards by which all hazardous waste treatment, storage, and
disposal facilities must be operated as well as specific requirements for surface impoundments,
waste piles, landfills, incinerators, land treatment facilities, and facilities with containers and tank
systems used for storing or processing hazardous waste.
Part 265 establishes minimum standards that apply to facilities that treat, store, or dispose of
hazardous waste and have interim status. Part 265 regulations apply to facilities that were operating
before the RCRA regulations were finalized and have not yet received a final permit to operate their
facility or have closed but are under EPA orders to correct some problems on-site. This part also
contains the requirements for training, preparedness and prevention, and contingency planning.
Part 266 contains standards for the management of specific hazardous wastes and specific types
of hazardous waste management facilities. This part includes regulations that apply to recyclable
materials, hazardous waste burned for energy recovery, recyclable materials utilized for precious
metal recovery, and spent lead-acid batteries being reclaimed.
Part 268 identifies hazardous wastes that are restricted from land disposal and defines those cir-
cumstances under which a restricted waste may continue to be land disposed.
Part 270 covers basic EPA permitting requirements for hazardous waste management facilities
such as the information to be included in the permit application, monitoring and reporting require-
ments, and the conditions under which permits can be transferred or modified.
Part 271 specifies the minimum requirements with which a state must comply to receive author-
ization to administer and enforce its own hazardous waste management program in lieu of the fed-
eral programs.
Part 273 includes the management system for hazardous wastes batteries, pesticides, and ther-
mostats. This program is referred to as the Universal Waste Program. These regulations cover the
standards for universal waste handlers, transporters, and destination facilities.
Part 279 establishes minimum management standards that apply to used oil generators, collec-
tion centers, aggregation points, transporters, transfer facilities, processors, re-refiners, burners, and
marketers of used oil fuel. This part also places limitations on the use of used oil as a dust sup-
pressant and on the disposal of used oil.
● Spent material. These are materials that have been used and as a result of contamination
can no longer serve the purpose for which it was produced without processing.
● Sludges. Solid, semisolid, or liquid waste generated from a municipal, commercial, or indus-
trial wastewater treatment plant; water supply treatment; or air pollution control facility.
● By-products. A material that is produced as part of a production process but is not a pri-
mary product of the process. An example is process residue such as slag.
● Scrap metal. Metal parts (e.g., bars, rods, sheets, and wire) which when worn out or no
longer needed, can be recycled.
● Discarded commercial chemical products, off-specification species, container residues,
and spill residues.
Inherently waste-like materials are those which have no other possible fate except disposal. For
example, hazardous waste designated by the numbers F020, F021 F022, F023, F026, and F028 (all
chlorinated hazardous wastes), when they are recycled in any manner, fall into the inherently waste-
like category. The F-listing and other hazardous waste listings are described below.
TABLE 11.2
Exclusions from Subtitle C of RCRA
Excluded from the Solid Waste Excluded from the Hazardous Waste Excluded Materials Requiring
Definition Definition Special Management
Domestic sewage Household wastes Product storage wastes
Mixture of domestic sewage and wastes Agricultural wastes used as fertilizers Waste identification samples
going to POTW
Industrial point source-discharges under Mining overburden returned to site Treatability samples
402 CWA
Irrigation returns flows Discarded wood treated with arsenic Empty containers
Sources, special nuclear, or by-product Chromium wastes Small-quantity generator wastes
material under AEA Underground storage tank cleanup
wastes
In-situ mining waste Specific ore processing wastes Farm wastes (pesticides)
Reclaimed pulping liquors Specific utility wastes
Regenerated sulfuric acid Oil and gas exploration, development,
and production wastes
Secondary materials returned to the Cement kiln dust
original process under certain
conditions
In addition, process wastes, discarded unused formulations, and incineration residues from the
production of certain chlorinated aliphatic hydrocarbons, trichlorophenol, tetrachlorophenol, pen-
tachlorophenol, and tetra-, penta-, or hexachlorobenzenes are included in the list of nonspecific
source wastes.
Examples of commercial chemical product hazardous wastes include products from hospitals
(e.g., pharmaceuticals past their expiration date, and unused reagents), research laboratories (expired
or unused reagents intended for disposal), photography laboratories, and analytical laboratories. These
items become hazardous waste when it is decided that they must be disposed. Some products, how-
ever, can be tested in order to determine if their expiration date can be extended. If there is another use
for the material, it can be stored or used for that purpose without being classified as a hazardous waste.
11.3.6 IGNITABILITY
The ignitability characteristic indicates those wastes that pose a fire hazard during routine handling,
for example, storage, transport, processing, or disposal. Specifically, a solid waste exhibits the char-
acteristic of ignitability if a sample possesses any of the following properties (40 CFR Part 261.21):
● It is a liquid, other than an aqueous solution, containing less than 24% alcohol (by vol.)
and has flash point less than 60°C (140°F), as determined by a Pensky–Martens Closed
Cup Tester (U.S. EPA, 1986; ASTM Standard D-93-79 or D-93-80) or a Setaflash Closed
Cup Tester (ASTM Standard D-3278-78).
● 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.
● It is an ignitable compressed gas as defined in 49 CFR 173.300.
● It is an oxidizer as defined in 49 CFR 173.151.
A solid waste that exhibits the characteristic of ignitability is given the EPA hazardous waste
number D001.
11.3.7 CORROSIVITY
Corrosive wastes occur at extremes in pH. Wastes with very low or high pH values can corrode stan-
dard drums, oxidize skin and other living tissue, and mobilize components from certain wastes.
Examples of corrosive wastes include acid wastes and alkali wastes. A solid waste exhibits the char-
acteristic of corrosivity if a sample has either of the following properties (40 CFR Part 261.22):
Wastes generated from the following processes are examples of corrosive hazardous wastes:
A solid waste that exhibits the characteristic of corrosivity is given the EPA hazardous waste
number D002.
11.3.8 REACTIVITY
Wastes possessing the characteristic of reactivity are often unstable, and pose hazards of explosion
and release of toxic gases during routine management. Examples of reactive wastes include picrate
salts (derived from picric acid, 2,4,6-trinitrophenol), and certain epoxides and peroxides.
Other wastes generated from the following processes are examples of reactive hazardous wastes:
● Cyanide bearing electroplating solutions (unless they are listed in 40 CFR 261.31, F-list)
● Ordinances and explosives listed by DOT as Division 1.1, 1.2, or 1.3 explosive, or for-
bidden explosives
A solid waste that exhibits the characteristic of reactivity is given the EPA hazardous waste
number D003.
11.3.9 TOXICITY
The toxicity characteristic leaching procedure (TCLP) was formulated to simulate environmental
conditions in an exposed landfill. The intent of the test is to determine whether potentially toxic
components of the waste could leach to groundwater and soil if exposed to acidic precipitation.
The TCLP replaced the EP toxicity test in 1990. The new test includes 25 organic compounds as
well as the eight metals and six pesticides in the EP test. In the TCLP, a representative sample is shaken
in dilute acetic acid for 16 to 20 h, filtered, and the filtrate is analyzed for the required metals and
organic compounds. Where the waste contains less than 0.5% filterable solids, the waste itself is con-
sidered to be the extract. Details of the method are provided in TCLP, Method 1311 (U.S. EPA, 1986).
If the extract from a representative waste sample contains any of the contaminants listed in
Table 11.3 at a concentration greater than or equal to the regulatory level, the waste exhibits the
TABLE 11.3
Details on the Toxicity Characteristic Compounds (TCLP)
EPA Hazardous Contaminant CAS No. Regulatory
Waste Number Level (mg/L)
D004 Arsenic 7440-38-2 5.0
D005 Barium 74401-39-3 100.0
D018 Benzene 71-43-2 0.5
D006 Cadmium 7440-43-9 1.00
D019 Carbon tetrachloride 56-23-5 0.5
D020 Chlordane 57-74-9 0.03
D021 Chlorobenzene 108-90-7 100.0
D022 Chloroform 67-66-3 6.0
D007 Chromium 7440-47-3 5.0
D023 o-Cresol 95-48-7 200.0
D024 m-Cresol 108-39-4 200.0
D025 p-Cresol 106-44-5 200.0
D026 Cresol 200.0
D016 2,4-D 94-75-7 10.0
D027 1,4-Dichlorobenzene 106-46-7 7.5
D028 1,2-Dichloroethane 107-06-2 0.5
D029 1,1-Dichloroethylene 75-35-4 0.7
D030 2,4-Dinitrotoluene 121-14-2 0.13
D012 Endrin 72-20-8 0.02
D031 Heptachlor (and its epoxide) 76-44-8 0.008
D032 Hexachlorobenzene 118-74-1 0.13
D033 Hexachlorobutadiene 87-68-3 0.5
D034 Hexachloroethane 67-72-1 3.0
D008 Lead 7439-92-1 5.0
D013 Lindane 58-89-9 0.4
D009 Mercury 7439-97-6 0.2
D014 Methoxychlor 72-43-5 10.0
D035 Methyl ethyl ketone 78-93-3 200.0
D036 Nitrobenzene 98-95-3 2.0
D037 Pentrachlorophenol 87-86-5 100.0
D038 Pyridine 110-86-1 5.0
D010 Selenium 7782-49-2 1.0
D011 Silver 7440-22-4 5.0
D039 Tetrachloroethylene 127-18-4 0.7
D015 Toxaphene 8001-35-2 0.5
D040 Trichloroethylene 79-01-6 0.5
D041 2,4,5-Trichlorophenol 95-95-4 400.0
D042 2,4,6-Trichlorophenol 88-06-02 2.0
D017 2,4,5-TP (Silvex) 93-72-1 1.0
D043 Vinyl chloride 75-01-4 0.2
toxicity characteristic. The following wastes are examples of common toxicity characteristic wastes
(40 CFR Part 261.24):
A solid waste that exhibits the characteristic of toxicity has the EPA Hazardous Waste Number
specified in Table 11.3.
The U.S. EPA has assigned specific hazardous waste numbers and codes to both characteristic and
listed wastes. Each listed hazardous waste will have one or more codes associated with it (Table 11.4).
Many hazardous wastes meet the requirements of more than one waste type. During a waste determi-
nation, all applicable waste codes must be identified and documented.
To summarize, if a solid waste is not a listed hazardous waste and does not exhibit one of the
above four characteristics, it is not in the RCRA system. Even if this is the case, however, the waste
may still be subject to regulation; for example, it may fall under state regulations.
TABLE 11.4
Codes for Hazardous Wastes under RCRA
Waste Type EPA Number EPA Code
Ignitable D001 I
Corrosive D002 C
Reactive D003 R
Toxicity characteristic D004–D043 E
Toxic F-, K-, and U-lists T
Acutely hazardous F- and P-lists H
become nonhazardous, provided the mixture no longer exhibits the ignitability characteristic. It
must be emphasized, however, that such wastes become nonhazardous only by the inadvertent,
unavoidable mixing occurring during standard processes at the facility. In other words, a facility
cannot deliberately mix a nonhazardous waste with hazardous waste to render it nonhazardous.
Treating a hazardous waste to render it nonhazardous may require a permit (40 CFR 262.34).
TABLE 11.5
Tons of Generated Waste that were Only Characteristic Waste, Only Listed Waste, or Both
Characteristic and Listed Waste, 1999
Only Characteristic Wastes Only Listed Wastes Both a Characteristic and a Listed Waste
Ignitable only 681,936 F code only 2,213,492
Corrosive only 1,075,431 K code only 3,695,803
Reactive only 247,748 P code only 80,396
D004-17 2,379,016 U code only 496,466
D018-43 4,464,793
More than one 12,082,405 More than one 845,353
characteristic code listed code
Total 20,391,330 Total 7,331,509 Both characteristic 11,760,240
and listed
The Toxics Release Inventory (TRI) is a publicly available database that contains information on
waste management activities reported annually by certain industries and federal facilities. There are
nearly 650 toxic chemicals and toxic chemical categories on the list of chemicals that must be
reported to EPA and the states. These chemicals do not always correspond exactly to RCRA wastes;
however, they provide a useful overview of the types and amounts of toxic chemicals generated in
the United States.
According to the TRI, the chemical manufacturing industry reported the largest quantity of
toxic chemicals in production-related waste managed in 2001, with 10.69 billion pounds or 40% of
the total reported by all industries (Table 11.6). The primary metals industry reported the second
largest quantity of toxic chemicals in production-related waste managed in 2001, with 3.10 billion
pounds or 12% of the total. The metal mining industry reported the third largest quantities of toxic
chemicals and the largest quantity released on- and off-site in 2001. With 2.87 billion pounds, metal
mining facilities accounted for 11% of toxic chemicals in production-related waste managed by all
TABLE 11.6
Quantities of TRI Chemicals in Waste by Industry, 2001
Industry Total Production-Related
Waste Managed (lb)
Metal mining 2,869,626,395
Coal mining 16,481,994
Food 1,090,077,820
Tobacco 5,309,980
Textiles 40,714,851
Apparel 1,803,460
Lumber 69,202,953
Furniture 15,058,736
Paper 1,374,388,098
Printing 370,693,356
Chemicals 10,688,079,114
Petroleum 878,617,109
Plastics 205,625,949
Leather 8,407,158
Stone, Glass or Clay 653,183,379
Primary metals 3,100,713,329
Fabricated metals 661,029,051
Machinery 130,427,694
Electrical equipment 592,437,820
Transportation equipment 260,042,330
Measure or Photo 62,566,249
Miscellaneous 40,766,891
Multiple SIC codes 20 to 39 966,557,214
No SIC codes 20 to 39 27,510,857
Electric utilities 1,561,124,192
Chemical wholesale distributors 41,079,498
Petroleum bulk terminals or bulk storage 46,278,144
Hazardous waste or solvent recovery 957,788,017
Total 26,735,591,638
TABLE 11.7
Top 20 Chemicals with the Largest Total Production-Related Waste, 2001
CAS Number Chemical Total Production-Related
Waste Managed (lb)
67-56-1 Methanol 2,331,011,667
108-88-3 Toluene 1,787,944,977
7647-01-0 Hydrochloric acid 1,504,105,058
— Zinc compounds 1,355,504,817
— Copper compounds 1,263,772,355
74-85-1 Ethylene 1,256,806,620
7440-50-8 Copper 1,088,001,030
110-54-3 n-Hexane 970,193,833
— Lead compounds 965,794,108
98-82-8 Cumene 832,570,075
7664-41-7 Ammonia 800,432,076
115-07-1 Propylene 797,566,959
— Nitrate compounds 701,130,070
7664-93-9 Sulfuric acid 583,305,201
107-21-1 Ethylene glycol 565,972,276
107-06-2 1,2-Dichloroethane 561,860,469
7782-50-5 Chlorine 552,091,471
1330-20-7 Xylene (mixed isomers) 479,477,559
— Manganese compounds 477,625,043
7697-37-2 Nitric acid 411,681,261
Subtotal (top 20 chemicals) 19,286,846,925
Total (all chemicals) 26,735,591,638
industries in 2001. Electric utilities reported the fourth largest amount of toxic chemicals in 2001
with 1.56 billion pounds, representing 6% of the total managed. This industry reported the second
largest amount released on- and off-site, with 1.06 billion pounds or 17% of the quantity released
by all industries in 2001.
REFERENCES
Code of Federal Regulations, Vol. 40, Part 261, Identification and Listing of Hazardous Waste, U.S.
Government Printing Office, Washington, DC, 2004.
U.S. Environmental Protection Agency, Toxics Release Inventory (TRI), Public Data Release, Executive
Summary, 2001. See: http://www.epa.gov/tri/tridata/tri01/pdr/index.htm
U.S. Environmental Protection Agency, Method 9040. pH Electrometric Measurement. Test Methods for
Evaluating Solid Waste, Physical/Chemical Methods, EPA SW-846, Washington, DC, 1986a.
U.S. Environmental Protection Agency, Pensky–Martens Closed-Cup Method for Determining Ignitability,
Method 1010, Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA SW-846,
Washington, DC, 1986b.
QUESTIONS
1. What is the top priority for hazardous waste management (general method) under
RCRA? What is the lowest priority?
2. Which of the following under RCRA is (are) not excluded from the rules and regulations
applicable to hazardous waste generators, treatment, storage, disposal, and transporta-
tion? (a) domestic sewage; (b) spent nuclear or by-product material; (c) household waste;
(d) spent halogenated solvents.
3. What are acute hazardous wastes? Provide an accurate technical definition.
4. Which of the following property(ies) is (are) not characteristics that define a RCRA haz-
ardous waste? (a) radioactive; (b) corrosive; (c) ignitable; (d) reactive; (e) biohazard.
5. What pH range does noncorrosive waste display?
6. What is the name of the test method used to determine if a waste is toxic? Describe the
details of the method.
7. Can a generator legally mix a listed hazardous waste with sufficient nonhazardous solid
waste to the point where it can be diluted and therefore is no longer classified as a haz-
ardous waste? Discuss.
8. The Hi-Jinx Metalworks Corp. has produced several gallons of a spent paint stripper.
Based solely on the Material Safety Data Sheet (following pages), could this waste be a
RCRA hazardous waste?
9. Outside one of the Hi-Jinx warehouses (which has stored paint stripper in the past),
several drums are discovered and there is a sweet solvent odor. Is the contaminated soil
considered a hazardous waste? Explain.
10. The environmental safety officer at the Hi-Jinx plant identifies dozens of drums contain-
ing a reddish filter cake near the site’s electroplating wastewater treatment plant. After
analyzing the filter cake, the level of chromium in the sludge is determined to be 75
mg/kg and the TCLP test measures 2 mg/L in the resulting leachate. What can the facil-
ity conclude regarding the waste and its proper management?
11. Can a waste be both a listed hazardous waste and a characteristic hazardous waste? Explain.
12. An automobile body shop and painting facility is in operation. Metal parts are reworked
and repainted; engine components are cleaned and reworked; fiberglass and metal body
parts are repaired, replaced, and painted. List at least ten different types of waste gener-
ated at the facility. Separate into solid (nonhazardous) and hazardous (listed and charac-
teristic) wastes.
13. List potential sources of hazardous waste generated in your university. Name any listed
hazardous wastes. To what list(s) do they belong? If not listed, what are the specific char-
acteristics that render these wastes hazardous?
14. Write in the name of each list on the table below:
15. For the four hazardous waste characteristics, list their hazardous waste numbers in the table:
Characteristic EPA Waste Number
Ignitable
Corrosive
Reactive
Toxicity characteristic
ITEM DESCRIPTION
Item Name: DICHLOROMETHANE, TECHNICAL
Type of Container: DRUM
DISPOSAL CONSIDERATIONS
Waste Disposal Methods: