1. Real World RCRA Fall, 2004

2. Hazardous Waste Regulations Current hazardous waste management rules are based on: Resource Conservation and Recovery Act, 1976 and Hazardous and Solid Waste Amendments of 1984 Significant additional requirements for hazardous waste management

3. RCRA First national law to address hazardous waste disposal issues Regulates the proper handling, storage and transportation of hazardous waste Introduced the concept of “cradle to grave” Cradle to grave liability means that the entity that creates a hazardous waste is morally and financially responsible for that waste until it has been destroyed.

4. Who enforces these regulations? EPA – Environmental Protection Agency WI DNR – Wisconsin Department of Natural Resources RCRA Delegated authority

5. Basic components for haz waste management There are three basic components to proper hazardous waste management Accurate waste determination Proper handling of waste on site Safe transportation and disposal Will begin by looking at accurate waste determination

6. What is hazardous waste? Two part question Is this a solid waste? Is this a hazardous solid waste? The term “solid waste” has nothing to do with the physical state of the material. A solid waste is any solid, liquid or gas that has served its intended purpose or is no longer wanted.

7. Examples of solid waste Spent ethanol used in preserving aquatic samples A liquid that has served its intended purpose Excess quantity of potassium cyanide in stockroom A solid that is no longer needed

8. Is it a hazardous waste? – cont’d A solid waste is a hazardous waste if it falls into one of the following two categories: Is specifically listed by the WI Department of Natural Resources in the NR 600 codes (listed waste) or Displays any of the four hazardous waste characteristics (characteristic waste): Ignitability, corrosivity, reactivity or toxicity

9. Is the solid waste a listed hazardous waste? RCRA has specifically listed certain solid wastes as hazardous wastes. Listed wastes are found in Tables II, III, IV, V of Wisconsin Administrative Code section NR 605.09 These listed wastes are categorized based upon their source.

10. Listed Waste Table II wastes – the F-list Wastes from non-specific sources Includes many spent solvents E.g. spent acetone, toluene Wastes listed in this table will carry a waste code beginning with “F” Table III wastes – the K-list Wastes from specific sources or processes K-listed wastes are not typically generated in a lab

11. Listed Waste Table IV wastes – the P-list Chemicals in the P-list table are unused chemicals considered acutely hazardous They can be extremely dangerous to human and environmental health with even short term exposure or in very small doses Wastes listed in this table will carry a waste code beginning with “P” Waste carrying a “P” code have significant impact on determining hazardous waste generator status

12. Table V wastes – the U-list Chemicals in the U-list table are unused chemicals considered hazardous but not as dangerous as the acutely hazardous P- listed chemicals Wastes listed in this table will carry a waste code beginning with a “U” E.G. butyl alcohol

13. Example – listed waste Remember the potassium cyanide the stock room supervisor wants to get rid of? It is unused and in its original container so it definitely is not an F or K-listed waste. Check Table IV (P-listed wastes) and Table V (U- listed wastes) for potassium cyanide. Potassium cyanide shows up in Table IV and is given a waste code of P098

14. Characteristic wastes A solid waste may still be a hazardous waste even if it does not appear on the F, K, P, or U list if it demonstrates one of four hazardous characteristics: Ignitability Corrosivity Reactivity Toxicity

15. Ignitability Ignitability relates to the waste’s ability to burn or stimulate the burning of something else. A liquid waste with a flash point < 140 o F is considered an ignitable hazardous waste

16. Ignitability – an example You do a flash point test on the spent ethanol mentioned earlier. It has a flash point of 85 0 F It is considered a hazardous waste because it has the hazardous characteristic of ignitability It will carry a waste code of D001 Note: The NR 605.08 definition of ignitability includes a few other categories that are not covered in this module.

17. Corrosivity Corrosivity relates to the waste’s ability to destroy or deteriorate materials (including skin) An aqueous (water-containing) waste with a pH 12.5 Example You generate a waste that contains a lot of sulfuric acid. You pH the solution and find the pH = 1. This is considered a hazardous waste because it has the hazardous characteristic of corrosivity It will carry a waste code of D002 Note: The NR 605.08 definition of corrosivity also includes liquid waste that corrodes plain carbon steel at a rate >.25”/year

18. Reactivity Reactivity relates to the waste’s extreme instability and tendency to react violently or explode. These wastes include water reactives, air reactives, and pyrophorics

19. Potassium reacts readily when exposed to air or water. If you wish to dispose of potassium, it will be considered a hazardous waste because of its characteristic of reactivity and carry a waste code of D003 Note: The NR 605.08 definition of reactivity also includes cyanides and sulfides that can generate toxic gases and forbidden Class A and B explosives

20. Toxicity Toxicity relates to the waste’s ability to contaminate groundwater. Wastes are considered toxic if they release or leach any of 39 specified heavy metals, pesticides or organic chemicals above their regulatory level concentrations. The laboratory test used to determine this characteristic is called the Toxic Characteristic Leaching Procedure (TCLP) Waste codes for toxic wastes are D004-D043

21. Toxicity Example You suspect the sink trap sludge from your lab sink may contain some mercury (one of the heavy metals specified). You have a TCLP test done on the sample and are told the leachate contains concentrations of mercury > 0.2 mg/L – the permitted regulatory level. The sink trap sludge is a hazardous waste because of its toxicity characteristic and will carry a waste code of D009

22. Toxicity – one more comment Don’t be confused –the term “toxicity” when used to describe a hazardous waste is not the same as the general category of toxic substances. To be a hazardous waste because of the toxicity characteristic means the waste contains one of 39 specified substances and fails the TCLP test.

23. Summary -Is it a hazardous waste? A solid waste is a hazardous waste if Is specifically listed in the haz waste codes F, K, P and U lists Listed wastes will be assigned a 4 character code beginning with F, K, P or U Or Demonstrates a hazardous characteristic Ignitable, corrosive, reactive or toxic Characteristic wastes will be assigned a 4 character code beginning with “D” Waste determination is the first step in proper management of hazardous waste

24. Basic Components for proper hazardous waste management Three basic components Accurate waste determination Proper handling of waste on site Safe transportation and disposal

25. Proper handling of hazardous waste Once you have determined you have generated hazardous waste you must then manage that waste properly. Haz waste management requirements are partially dependent on your generator status

26. Hazardous Waste Generator Status Generators of hazardous waste are divided into three categories in Wisconsin Very small quantity generator (VSQG) Small quantity generator (SQG) Large quantity generator (LQG)

27. Your hazardous waste generator status depends on three factors: How much hazardous waste you generate in a calendar month How much hazardous waste you accumulate on site How much acute hazardous waste you generate per month All acute hazardous waste carries a “P” code (with the exception of F027 waste which is also considered acute haz waste).

28. Determining Generator Status LQGSQGVSQG HW per month>2205 lbs<2205 lbs<220 lbs HW accumulated No limit<13,230 lbs <2205 lbs Acute HW> 2.2 lbs< 2.2 lbs

29. Generator Status In general, the amount of waste you generate and accumulate on site will determine your generator status It is preferable to be a very small quantity generator (VSQG) rather than a large quantity generator (LQG) Large quantity generators have more compliance requirements for managing hazardous waste

30. The amount of acute hazardous waste (those with a P or F027 code) generated can significantly impact generator status Anyone generating over 2.2 LB of acute hazardous waste at one time automatically becomes a LQG

31. Waste Management All generators of hazardous waste must do certain things – although the requirements vary a bit depending on generator status. Obtain an EPA ID number – EPA monitors and tracks generator activity by assigning EPA ID numbers. EPA ID numbers can be obtained from the DNR

32. Place Waste in Proper Containers Good condition Compatible Closed at all times (except when adding or removing contents) Labeled with the words “Hazardous Waste”, identity of contents and hazard of contents Date when waste enter accumulation (hazardous waste storage area)

33. Properly store and accumulate Once waste is containerized and labeled it must be moved to a storage or accumulation site. Accumulation time limits vary based on generator status LQG – 90 days SQG – 180 Days (there is one exception) VSQG – when 2200 lbs is accumulated Haz waste must be shipped off site once accumulation time limits are reached. Storage site must be inspected weekly

34. Additional requirements depending on generator status Designate an emergency coordinator Annual DNR reporting (LQG and SQG) Training program for personnel handling haz waste Emergency preparedness and response plans Records maintenance

35. Common haz waste violations Not marking containers as “hazardous waste” Accumulating too much waste at a satellite accumulation area Not marking start date for waste containers in haz waste storage site Accumulating waste on site for more than 90 or 180 days – depending on generator status Open haz waste containers Improper haz waste containers, containers in poor condition

36. Common violations cont’d Failure to have a contingency plan Not providing or maintaining personnel training Poor record maintenance (e.g. container inspection logs) Manifests/LDR paper work not maintained

37. Enforcement of RCRA rules Proper management of hazardous waste is not only good science but also it’s the law. EPA has been actively enforcing RCRA rules in academic institutions in recent years. http://www.epa.gov/r02earth/news/2003/03133.htm http://www/epa.gov/r02earth/news/2002/02118.htm

38. Up to this point we have considered how to accurately determine whether you have generated a hazardous waste and handle it properly while on-site. The next thing to consider is how to properly ship and dispose of this waste. It is important to remember that “cradle to grave” makes the generator liable for hazardous waste generated until it is destroyed – even if you hire someone else to ship and dispose of that waste.

39. Disposal options Terms to know when considering disposal options  Onsite treatment involves physical, chemical or biological alteration of a hazardous waste to make the waste less hazardous  Specific treatment permits are typically required for this  UW-Green Bay is limited to elemental neutralization and photo waste silver reclamation without a permit.

40. Disposal Options Fuel blending involves utilization of hazardous waste combustible material (with energy value) as an alternative fuel – often in cement kilns Benefits -cost efficient and effective method of recycling, treatment and destruction -cement (or some other product) is produced

41. Disposal options UW-Green Bay commonly uses this option for shipping haz waste generated in the lab Lab pack – process of having a waste disposal company arrive at site and package smaller containers into one larger container

42. Disposal Options Reclamation – removing useful parts from waste stream for reuse elsewhere –UW-Green Bay reclaims silver from photo waste on site –UW-Green Bay sends items containing mercury off-site for mercury reclamation

43. Disposal options Recycling/reuse – to process so that basic raw material can be used again. UW-Green Bay sends spent lamps off site to recycle parts

44. Disposal Options Incineration – process of burning haz waste and subsequently disposing of the remaining stabilized ash into a landfill UW-Green Bay uses this disposal option for the majority of haz waste generated. Most waste for incineration goes to a licensed haz waste incinerator in Illinois.

45. Disposal options Solidification/encapsulation – this process involves “locking up” the hazardous parts of the waste so that they cannot change or leach out into the landfill. UW-Green Bay sends aqueous mercury salt solutions to Canada for stabilization, encapsulation and landfill. UW-Green Bay has sent low level radioactive waste for encapsulation and landfill disposal.

46. Disposal options E.g. -UW-Green Bay sends asbestos material to a landfill for disposal Landfill – direct disposal of haz waste into a designated excavation or “cell.” Make sure the landfill you use is licensed to accept the material you wish to landfill. Most only accept dry material

47. Waste Management Disposal Priorities Reuse, reclaim or recycle Elementary neutralization Fuel blending Treatment Destruction via incineration Licensed permitted hazardous waste landfills

48. Disposal options Inspect and research the facility your waste is being sent to. You, the “generator,” are responsible for this waste long after it has left your facility and has been disposed of.

49. Vendor services UW-Green Bay utilizes a haz waste vendor that provides a package of services Technical team comes to facility to prepare and package waste for shipment Technical team transports waste to a treatment, storage and disposal facility Vendor coordinates transportation of waste to appropriate disposal facilities. Vendor prepares paperwork used in tracking waste shipment

50. Creating a paper trail The generator is legally responsible for completion of this document and for submitting copies of manifests to DNR Uniform hazardous waste manifest is a document used when transporting hazardous waste. It creates a paper trail for tracking haz waste from “cradle to grave.”

51. Waste Minimization: Less is Better In addition to proper management of haz waste, generators (especially LQG) are also expected to minimize haz waste generated. Potential Options: Procedure changes Reduce scale Material substitution

52. There’s more Up to this point we have focused on hazardous waste management. Solid waste can actually be separated into three categories Special waste Universal waste Hazardous waste

53. Has high potential for recycling If recycled, lower management requirements Examples: mercury thermometers and barometers, batteries, lamps Universal Waste is waste that would normally have to be treated as hazardous waste

54. Regulatory incentives for recycling If not recycled must be treated as hazardous waste Examples: computers, electronics Special Wastes have a hazardous component

55. Disposal costs Typical lab waste – mobilization plus technician plus actual disposal cost – may cost a campus the size of UW-Green Bay $5,000 per year. Haz waste with special handling requirements Picric acid – approaching $3000 Radioactive waste $5000-10,000 for a small quantity of low level radioactive waste

56. Example 3.4 - answer The preferred and likely most economical option is to utilize the spent solution in a fuel blending process. Check with you waste vendor for fuel blending options.