2. How To Recognize a Hazardous Waste Even If Its Wearing Glasses

3. Classification of Hazardous Wastes zSolid Wastes zHazardous Waste Definition zUsed Oil zOther Waste Characterization Principles zUsed, Reused, Reclaimed, Recycled zDelisting

4. Classification of Hazardous Wastes zSolid Wastes: ycan be a solid liquid or gas ya material must first be a solid waste before it can be classified a hazardous waste yA material that has been abondoned through disposal, burning, storage, or treatment, or yrecycled (including use, reuse, reclamation)

5. Classification of Hazardous Wastes zHazardous Wastes: yFirst step. Is it specifically exempted? yNot a solid waste: xuntreated sanitary sewage going to POTW xPoint Source Discharge Permits (lagoon too) xirrigation return flows yThere are other very specific exemptions: xnuclear wastes xpulping liquors xmining wastes

6. Classification of Hazardous Wastes zSolid Wastes that are not hazardous wastes: yHousehold wastes yAg waste if used as fertilizer yMining spoils return to mine yWastes from exploration, development or production of crude oil, gas, geothermal yCement Kiln wastes yLeather Industry, Trivalent Chromium Process

7. Classification of Hazardous Wastes zSome Hazardous Solid Wastes are regulated by other laws: yAsbestos - CAA/NESHAP yPCBs above 50ppm - TSCA zOnly Two ways a solid waste can be a hazardous waste: ythe waste is specifically listed as hazardous ythe waste ails a characteristic test

8. Classification of Hazardous Wastes zListed Hazardous Wastes: yEPA has authority to generally lists wastes it believes are hazardous yThe waste may be delisted if you can prove that it meets delisting criteria yDelisting is granted by specific material, process and address. yDelisting will be covered later

9. Classification of Hazardous Wastes zEPA lists wastes based on three categories: yExhibits a hazardous characteristic xignitibility, reactivity, corrosivity, toxicity yAcutely hazardous xfatal to humans at low doses yToxic xIf it contains certain hazardous constituents. yListing is accompanied by a hazard code xI, C, R, E, H, T

10. Classification of Hazardous Wastes zThere are three lists of hazardous wastes yNon Specific Source Wastes ySpecific Source Wastes yDiscarded Commercial Chemical Products zNon Specific Source Wastes yBroad, General Groupings (F series) xSpent Solvents xElectroplating/Metal Finishing xOther Non Specific

11. Classification of Hazardous Wastes zSpecific Source Wastes yWastes from certain industries that EPA has defined as hazardous xK series wastes xwood preservation, organic chemicals, coking xpesticides, explosives, ink formulation, etc zDiscarded Comm. Products (U/P series) yListed in 261.33(e)(f), (very narrow) or yits sole active ingredient is listed here, and ythis material is discarded for any reason.

12. Classification of Hazardous Wastes zHazardous Waste Characteristics yIgnitability yCorrosivity yReactivity yToxicity

13. Classification of Hazardous Wastes zIgnitability yApplies to any physical state yMost common is Liquids (fp <140F) yExcludes Aqueous Alcohol if <24% yOther ignitable wastes include: xDOT oxidizers xSpontaneously Combustible xDOT flammable compressed gases yAssigned EPA HW# D0001

14. Classification of Hazardous Wastes zCorrosivity yApplies only to Liquids xIf unsure about physical state do a paint filter liquids test ypH is greater than 12.5 or less than 2.0 yor it corrodes steel at 6.35 mm/year yAssigned EP # D0002

15. Classification of Hazardous Wastes zReactivity (D0003) yThe most Nebulous characteristic yNo repeatable, sound test method yMeant to identify wastes that have the potential to explode or release toxic gases during the waste management process zThe determination is based ultimately on the your knowledge of your waste and a regulatory interpretation.

16. Classification of Hazardous Wastes zThe regulatory language ynormally unstable, undergoes violent change yreacts violently with water yforms explosive mixtures with water yexplosive if heated under confinement ydetonates, explosive decomposition, or reaction at standard T and P yis a DOT forbidden, A, or B, explosive ycyanide and sulfide available for release

17. Classification of Hazardous Wastes zToxicity Characteristic (TC) yThe TC is based on the results of the TCLP. yExtraction by DI water and acetic acid y8 heavy metals, 4 insecticides, 2 herbicides, and 25 other organic compounds yExtraction in analyzed to determine if any of these 39 compounds exceed their MCL yAssigned EPA# D0004-D043

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

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

20. Classification of Hazardous Wastes zUsed Oil (six questions): yIs it used oil (crude or synthetic used as oil) yIs the used oil mixed with a HazWaste yDoes the oil contain >1000ppm halogens yIs it used oil fuel yIs it a hazardous waste fuel yIs the used oil fuel, specification used oil fuel xAr, Cd, Cr, Pb, FP>100F, Halogen <4000ppm

21. Classification of Hazardous Wastes zEmpty Containers yall material commonly possible removed, and yno more than iI” residue on the bottom, or yresidue is less than 3% by weight <110G yresidue is less than 0.3% by weight >110G yUnless the drum contained an acute hazardous material or H series waste, xthen removed lining or triple rinsed.

22. Classification of Hazardous Wastes zMixture Rule ya characteristic waste mixed with a solid waste is a hazardous waste if it exhibits a characteristic ya listed waste mixed with a solid waste is always a hazardous waste, unless xthe listed waste is listed only because of a characteristic and the mixture exhibits a characteristic.