1. How To Recognize a Hazardous Waste Even 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
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
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 (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.