SPEA-E 452 Final Exam Study Set
4 step process to determine if a waste is hazardous or not and to assign the appropriate hazardous waste code(s):
1. Does it meet the definition of a solid waste as defined in 40CFR261.2? o If yes, move on to step 2. o If no, stop. The waste is not a hazardous waste. 2. Is the waste excluded from being a hazardous waste in 40CFR261.4(b)? o If yes, stop. The waste is not a hazardous waste. o If no, move on to step 3. 3. Does it meet the definition of a listed hazardous waste as defined in 40CFR261.30-261.34 (F, K, P, U)? o If yes, the waste is a hazardous waste. Assign the appropriate listed hazardous waste code(s) and move on to step 4 to determine if any additional characteristic codes are required. o If no, move on to step 4. 4. Does it test positive by laboratory analysis for any of the characteristics of hazardous waste identified in 40CFR261.20-261.24 (D001, D002, D003, or D004-D043)? o If yes, the waste is a hazardous waste. Assign the appropriate characteristic hazardous waste code(s) based on the test results. o If no and no listed hazardous waste code(s) have been assigned, the waste is not a hazardous waste. o If no but a listed hazardous waste code or codes have been assigned, the waste is still a hazardous waste based on the listing.
DOT Hazard Classes
1. Explosives 2. Compressed Gases 2.1 Flammable Gas 2.2 Non-Flammable Gas 2.3 Poison Gas 3. Flammable liquids 4. Flammable solids 4.1 Flammable Solid 4.2 Spontaneously Combustible 4.3 Dangerous When Wet 5. Oxidizers and Organic Peroxides 5.1 Oxidizers 5.2 Organic Peroxides 6. Poisonous/Infectious 6.1 Poisonous or Toxic Materials 6.2 Infectious Substances 7. Radioactive 8. Corrosive 9. Misc.
Class 2: Compressed Gases (49 CFR 173.115)
A compressed gas is a material that exerts pressure in its packaging at standard temperature and pressure. Compressed gases are divided into three divisions: Class 2.1 - Flammable Gas Class 2.2 - Non-Flammable Gas Class 2.3 - Poison Gas
Solid Waste
A solid waste for the purposes of RCRA is defined in 40CFR261.2 as "any discarded material that is not excluded by 40CFR261.4(a) or by variance"
Advantages and Disadvantages of Incineration
Advantages of incineration Permanently destroys toxic organic compounds Reduces volume of hazardous waste by converting solids and liquids to ash Land disposal of ash is safer and more efficient than land disposal of untreated hazardous waste Disadvantages of incineration Does not destroy inorganic compounds Residual ash is subject to RCRA standards because of the derived-from rule and may require further treatment before land disposal Regulations for incinerators are found in 40CFR264 and 265 Subpart O. Incinerator is defined as any enclosed device that uses controlled flame combustion and does not meet the criteria for classification as a boiler, industrial furnace, sludge dryer, or carbon regeneration unit.
APCD
Air pollution control device (for air pollution)
Class 1: Explosives (49 CFR 173.50)
An explosive is any substance or article, including a device, which is designed to function by explosion (i.e. an extremely rapid release of gas and heat) or which, by chemical reaction within itself, is able to function in a similar manner even if not designed to function by explosion, unless it is otherwise classified under the provision of the regulations. Explosives are divided into six divisions (class 1.1- class 1.6) based on their sensitivity to initiation or detonation and their potential projection hazard.
BDAT
Best Demonstrated Available Technology (LDR Program)
LDR Treatment Methods
Biological - aerobic or anaerobic digestion Chemical o Neutralization - best for corrosive wastes Uses acid or base to adjust the pH of the waste so that it is >2 and <12.5 Removes the corrosive characteristic waste code D002 This is often a first step to performing other chemical treatment operations even if the waste is not hazardous for corrosivity o Oxidation/reduction - common for cyanide-bearing wastes; best for wastes that have heavy metal or organic compounds with a high redox potential Chemical additives cause targeted waste constituents to undergo redox reactions Targeted constituents either precipitate or convert to less toxic forms
BIF
Boilers and Industrial Furnaces (For hazardous Waste Incineration)
LDR Treatment Methods (Cntd)
Chemical (Cntd) o Precipitation - best for inorganic liquid wastes with dissolved metal compounds Removes dissolved metals, inorganics, suspended solids, fats/oil/greases, and some organics Chemical additives cause targeted waste constituents to form insoluble compounds or coagulate and drop out of solution as precipitates (different chemicals may be necessary for different targeted constituents) Precipitates are separated from the rest of the waste and subjected to further treatment if necessary - generally stabilization o Stabilization - commonly used for treatment residue solids; best for wastes with inorganic metal compounds that have relatively uniform particle size - less effective for debris type solids Adds a stable material with a high bonding capacity, such as cement dust, to a hazardous waste in solid form to chemically bind the targeted hazardous constituents in order to inhibit their mobility in the ground and reduce their leaching potential Often used as a final step for solids collected from other treatment processes o Adsorption - best for dilute liquid wastes with hazardous organic constituents and very low solids (for example: water that is contaminated with low levels of solvent or gasoline) Waste is filtered through activated carbon (often referred to as a charcoal filter) Hazardous constituents that have an affinity for the activated carbon are drawn out of the waste and remain in the carbon as the waste filters through (when the carbon is saturated, it is replaced and generally sent for incineration) Often used as a final step for wastewater from treatment processes that is bound for discharge into the sanitary sewer system
Class 6 - Poisonous Materials and Infectious Substances (49 CFR 173.132)
Class 6.1 - Poisonous or Toxic Materials: Material (other than a gas) known to be (or presumed to be based on animal testing) so toxic to humans that it poses a health hazard during transportation. Material with properties similar to tear gas that causes extreme irritation, especially in confined spaces such as those encountered in a transport vehicle Class 6.2 - Infectious Substances (49 CFR 173.134) Material known or reasonably expected to contain a pathogen A pathogen is a microorganism or other agent that can cause disease in humans or animals. This hazard class would include materials such as bacterial and viral cultures, regulated medical waste, patient specimens, and biological products such as vaccines.
CESQG
Conditionally Exempt Small Quantity Generator, <100 kg per month or <1kg of acute waste per month AND accumulates <1000 kg or <1 kg acute or <100kg cleanup from an acute spill
Class 8 - Corrosive Materials (49 CFR 173.136)
Corrosive materials are liquids or solids that cause full thickness destruction of human skin at the site of contact within a specified period of time or a liquid that has a severe corrosion rate on steel or aluminum based on criteria in §173.137(c)(2). Corrosive materials may be acid or alkaline, organic or inorganic.
DOT
Department of Transportation
DRE
Destruction and Removal Efficiency (For hazardous waste incinerators)
Besides the prohibition on land disposal, HSWA established two other prohibitions under the LDR (Land Disposal Restriction) program:
Dilution prohibition - states that hazardous waste must be properly treated to meet the concentration based standards; the concentrations levels for hazardous contaminants cannot be artificially lowered by diluting the waste with large amounts of water, soil, or other non-hazardous waste Storage prohibition - states that hazardous waste must be treated and cannot be stored indefinitely (temporary storage done to accumulate enough waste for cost-effective treatment or disposal is allowed).
Two main differences between a secure landfill and a sanitary (municipal) landfill
Double liner required for secure landfill while only a single liner is required for a sanitary landfill Two leachate collection and removal (LCR) systems are required for a secure landfill while only one is required for a sanitary landfill
RCRA Subtitle C Generator Requirements
EPA established lists of hazard identification codes for waste materials and requires generators to perform a "waste determination" to identify their wastes using these codes based on either their own knowledge of the waste or on analytical testing. Generators must maintain documentation of their waste determinations. Other generator requirements include obtaining an identification number, recordkeeping, training, packaging, labeling, marking, storage, inspection, emergency preparedness, and reporting. When generators ship hazardous waste off-site, they must use a UHWM and ship to a permitted hazardous waste treatment, storage, or disposal facility (TSDF). They must follow all DOT hazardous materials shipping regulations in order to ship their hazardous waste off-site.
RCRA Subtitle C Treatment Storage and Disposal Facility (TSDF) Requirements
EPA requires TSDFs to obtain an operating permit. State agencies administer the permits which stipulate all regulatory requirements in addition to technical facility operating parameters and conditions as well as safety procedures, personnel training, insurance requirements, and closure assurances.
RCRA Subtitle C Transporter Requirements
EPA requires hazardous waste transporters to use the UHWM for all shipments of hazardous waste and to otherwise follow all DOT hazardous materials shipping regulations while transporting hazardous waste between generator(s) and TSDF(s) (adding the word "waste" to the proper shipping description). Other transporter requirements under RCRA include obtaining an identification number, recordkeeping, time limits for delivery, and spill cleanup/reporting.
Classes of air pollution control equipment for particulate matter
Electrostatic precipitators Venture scrubbers Ionizing wet scrubbers Baghouses Acid gas pollution control is the same as for MSW incinerators
EPA
Environmental Protection Agency
Class 3: Flammable Liquids (49 CFR 173.120)
Flammable liquids are liquids having a flash point of ≤ 141º F.
Class 7 - Radioactive Materials
For DOT requirements, radioactive material means any material having a specific activity greater than 0.002 microcuries per gram (μCi/g).
Generator knowledge of the waste and the waste generating process can be used to rule out testing for some characteristics when making a hazardous waste determination.
For example, if a generator knows based on the inputs to a process that there is no possibility for metals or volatile organics to be present, then TCLP tests for those constituents would not need to be performed for the generator to rule out those hazardous waste codes.
*Note: generator knowledge cannot be used to make the waste determination if the generating process is unknown.
For example: if a drum is found unlabeled in a generator's warehouse where several processes take place that involve a variety of chemicals, a generator cannot claim that the waste in the drum is or is not hazardous for D001-D043 without analysis because he doesn't know what may or may not have gone into the drum.
Be familiar with the Waste Determination Road Map
For the exam, a copy of the hazardous waste determination flowchart and any waste code lists needed to answer exam questions will be provided for use during the exam. You will be expected to use information given to determine whether or not waste is hazardous and what hazardous waste codes may be applicable. Exam questions will be similar to questions asked on homework and/or quizzes.
Hazardous Waste Generators
Generator is defined in 40CFR260.10 as "any person, by site, whose act or process produces hazardous waste identified or listed in Part 261 or whose act first causes a hazardous waste to become subject to regulation." Person for the purposes of this regulation is also defined in the same section as "an individual, trust, firm, joint stock company, federal agency, corporation (including a government corporation), partnership, association, state, municipality, commission, political subdivision of a state, or any interstate body." Site is not specifically defined, but refers to the location where waste is generated - contiguous property generally makes up a single site
Listed Hazardous Waste
Generator knowledge of the waste and the waste generating process must be used to determine if a waste meets the definition of a listed hazardous waste. There is no laboratory analysis involved in this step.
HMR
Hazardous Materials Regulations
HSWA
Hazardous and Solid Waste Amendments (RCRA) included hazardous waste used as fuel, financial responsibility, Minimum Technology Requirements (MTRs), and air emissions from TSDFs
Hazardous Waste Transporters
Hazardous waste transporters are subject to regulation by EPA as well as the Department of Transportation (DOT). Hazardous materials and waste transportation regulations are found in 49CFR105-180. They are referred to as the Hazardous Materials Regulations (HMR). The goal of the HMR is to insure the safety of hazardous materials shipments while in transport in order to protect human health and the environment. For this reason, many of the regulations are designed to be applicable to conditions that may be reasonably encountered during transportation. With few exceptions, any time a hazardous material is being transported, a hazardous materials shipping paper is required to track the material and to provide hazard information in the event of an accident. For shipping hazardous waste, a specific shipping paper called a Uniform Hazardous Waste Manifest (UHWM) is required to be used. The UHWM is the mechanism used by RCRA to track hazardous waste from its generating source to its treatment/storage/disposal location. If a waste has been exempted or excluded from being a hazardous waste under RCRA but is still a hazardous material, then a regular hazardous materials shipping document would be substituted for the UHWM.
HHW
Household Waste
The F-list is for spent hazardous wastes from non-specific sources.
It contains listed hazardous waste codes that apply to spent/used waste materials or process wastes (except for F027) that are generated by generators in any industry.
The K-list is for spent hazardous wastes from specific sources.
It contains listed hazardous waste codes that apply to spent/used waste materials or process wastes that are generated by generators in specific industries with specific processes.
There are 22 specific materials excluded from being solid wastes in 40CFR261.4(a).
It is important to remember that a waste cannot be a hazardous waste if it is not first a solid waste. Some of the specific exclusions are domestic sewage, point source discharges that are regulated under the Clean Water Act, irrigation return flows, spent sulfuric acid used to produce virgin sulfuric acid, scrap metal, etc. Often materials are excluded because they are regulated by other statutes or because specific industries or interest groups have successfully lobbied that they are unduly burdened by the regulation or that their particular wastes do not represent the hazards for which similar wastes have been regulated.
LDR
Land Disposal Restriction (Part of HSWA also referred to as Land Ban)
LQG
Large Quantity Generator, >1000 kg per month or > 1 kg of acutely hazardous waste per month
LCR
Leachate Collection and Removal System (for landfill design)
Types of incinerators vary according to waste preparation and feed mechanism, combustion chamber design, air pollution control, and ash handling/disposal Common types of hazardous waste incinerators:
Liquid injection Rotary kiln - most common in U.S. Fluidized bed Plasma arc
MACT
Maximum Achievable Control Technology (for air pollution)
Class 9 - Miscellaneous Hazardous Materials (49 CFR 173.140)
Miscellaneous Hazardous Materials are materials that present a hazard during transportation but don't meet the definitions of hazard classes 1 - 8.
NWW
Non Waste Water (for LDR treatment standards, anything not WW)
OSHA
Occupational Safety and Health Administration
Performance standards for incinerators set limits on gaseous emissions in 4 categories plus fugitive emissions:
Organics Hydrogen chloride and chlorine gas Particulate matter Metals Fugitive emissions - gas that escapes the combustion chamber without going through pollution control devices.
PM
Particulate Matter (for air pollution)
Performance standards and other regulations for incinerators are implemented through approved operating permits for individual facilities
Permits are based on trial burns of hazardous waste at a facility Specify the operating parameters that are proven by the trial burn to result in the facility meeting the performance standards in all 4 categories
LDR Treatment Methods (Cntd 2)
Physical o Encapsulation - best for solid material that is not able to be treated by a chemical or biological treatment method and is prohibited from being incinerated or fuel substituted Waste is encased in an inert material that hardens and physically binds the waste (not just the hazardous constituents) in order to inhibit the mobility of the hazardous constituents in the ground and reduce their leaching potential Potential encapsulating materials include concrete, polyethylene, resins, etc. Microencapsulation - encases individual particles of waste Macroencapsulation - encases entire containers of waste o Solidification - generally used for non-hazardous waste Inert solid material such as sawdust or kitty litter is added to liquid hazardous waste to make it solid Used if a waste treatment method to be used on a liquid waste requires the material to be solid (for example: the material needs to be incinerated but the incinerator is only set up to feed solid material) *Note: solidification cannot be used to dilute the concentration of a hazardous waste and avoid further treatment because that would violate the dilution prohibition of the LDR program.
PIC
Product of Incomplete Combustion (For Hazardous Waste incinerators)
A large part of the hazardous waste management regulatory program, including the LDR program, is designed to protect groundwater. There are essentially two ways to make a hazardous waste less dangerous to groundwater:
Reduce the toxicity of the waste by destroying or removing harmful contaminants Reduce the ability of the hazardous contaminants to leach through the soil by chemically or physically immobilizing the contaminants.
RCRA
Resource Conservation and Recovery Act (Hazardous Waste Regs)
Each category of generator has specific requirements that they must comply with regarding training, recordkeeping, manifest usage, storage, emergency planning, etc. Requirements for each generator category are outlined in the following table:
See table in study guide CESQGs are exempt from the hazardous waste regulations as long as they sent their waste to state approved or RCRA permitted facility. They must also follow all applicable DOT requirements for shipping hazardous materials.
SQG
Small Quantity Generator, 100 kg < x < 1000 kg per month, AND accumulates <6000 kg at any time
The term solid waste for the purposes of RCRA does not have anything to do with the physical state of a waste material.
Solids, liquids, sludges, and even gases in containers can be solid wastes.
LDR Program
Specified treatment standards (either by concentration level or treatment method/technology) that must be met for each hazardous waste code prior to disposing of any waste in a landfill Instituted a tracking and recordkeeping requirement for notification from waste generators to TSDF personnel stating which treatment standards are applicable to the waste and whether or not those standards have been met prior to shipment: o LDR Notification Form (often referred to as a Land Ban Form) o Must accompany the UHWM for the initial shipment of each hazardous waste and again if there is any change in the waste o Must be retained for 3 years from the date that the waste is last shipped
HSWA
The Hazardous and Solid Waste Amendments Act of 1984 (HSWA) prohibited all untreated hazardous waste from being landfilled and gave EPA authority to establish the Land Disposal Restriction (LDR) Program in phases.
Toxicity characteristic wastes are assigned a characteristic hazardous waste code of D004-D043 depending on the specific constituent that is present in the simulated leachate of the waste. A waste tests positive for a toxicity characteristic if:
The extract of the waste (which simulates the leachate) contains a constituent that exceeds the regulatory concentration limit in 40CFR261.24(b) when tested using the toxicity characteristic leaching procedure.
LDR Treatment Methods (Cntd 3)
Thermal o Retort - typically used for elemental mercury contaminated wastes Waste is subjected to high enough heat to volatilize the mercury from the waste The volatilized mercury is then condensed and recovered for use o Fuel substitution (often referred to as fuel blending) - best for organic hazardous wastes that have low water and halogen content and have high BTU value (>5000) Fuel derived from fuel substitution is generally used by facilities governed by the Boiler and Industrial Furnace (BIF) regulations Regulations for BIFs are found in 40CFR266 - Subpart H Two classes of BIF Boilers - enclosed devices that use controlled flame combustion to recover and export energy as steam, heated fluid, or heated gases o Must have a combustion chamber and primary energy recovery system designed to insure effectiveness of the recovery system and maintain thermal recovery efficiency of 60% o Unit must export and use at least 75% of the recovered energy offsite Industrial furnaces - units that are an integral part of a manufacturing process and use thermal treatment to recover materials and energy o Most widely used example of an industrial furnace in the U.S. is a cement kiln (also called Portland cement kiln) o Other examples include coke ovens, aggregate kilns, blast furnaces, etc.
The P-list and U-list are for discarded commercial chemical products, off-specification products, and container and spill residues of those products.
They contain listed hazardous waste codes that apply to virgin/unused waste materials when they are discarded. The P-list contains codes for "acutely hazardous wastes" while the U-list contains codes for "toxic wastes". o In order for a P or U code to apply to a waste, the material must have the generic chemical name found in the list or be a commercially available product with the listed chemical as the "sole active ingredient". An example of this would be a hypothetical pesticide formulation called Ortho Orchard Spray with aldicarb given as the active ingredient on the label. If all of the rest of the ingredients are said to be "inert", then P070 would apply to the product if it was discarded unused. However, if mineral oil is given as an active ingredient along with aldicarb, then the P070 would not apply because aldicarb is not the sole active ingredient in the formulation. o There is no concentration minimum or maximum that has to be met for a material to be considered a commercial grade of a chemical. It just depends on what chemical it is and what concentrations manufacturers market for it. An example would be formaldehyde which is generally sold in 37% to 55% solutions with water, but can be purchased in 10% solutions with water as well. As long as the name of the formulation is formaldehyde or formaldehyde solution, the U122 code will apply.
Class 4 - Flammable Solids (49 CFR 173.124)
This class includes three divisions that are related but distinct. Class 4.1 - Flammable Solid Wetted explosives, self-reactive materials, readily combustible solids, powdered metals, etc. Class 4.2 - Spontaneously Combustible Pyrophorics or self-heating materials (liquids or solids that can spontaneously ignite or heat in air without an external energy or ignition source) Class 4.3 - Dangerous When Wet Materials that, when in contact with water, become spontaneously flammable or give off flammable or toxic gas at a rate of > 1L/kg of material/hr.
Class 5 - Oxidizers and Organic Peroxides (49 CFR 173.127 and 173.128)
This class includes two divisions. Class 5.1 - Oxidizers Materials that can, generally by yielding oxygen, cause or enhance the combustion of other materials, especially organics *oxidizers and flammables must not be mixed or stored together Class 5.2 - Organic Peroxides Any organic compounds containing oxygen in a bivalent -O-O- bond structure (these materials are derivatives of hydrogen peroxide in which the hydrogen atoms have been replaced by organic molecules) *organic peroxides are all reactive because they contain both the oxygen and the fuel (organic material) necessary to start and maintain a fire; the degree of reactivity depends on the particular combination and structure of organic molecules in the compound
Samples of waste collected for the purpose of waste determination and treatability are specifically exempted from regulation in 40CFR261.4(c).
This makes it possible to send material for testing to off-site lab facilities without violating regulations because you don't know how to classify it until after the testing is complete. There are quantity limits on how big samples can be so that generators don't just send an entire volume of waste off-site for testing in lieu of proper disposal.
TOC
Total Organic Carbon
TSS
Total Suspended Solids
TCLP
Toxicity Characteristic Leaching Procedure
LDR Program (Cntd)
Treatment standards are based on the performance of the best demonstrated available technology (BDAT) that is able to substantially diminish the toxicity of a waste or to reduce the mobility of the hazardous constituents in a hazardous waste as determined by EPA.
TSDF
Treatment, Storage and Disposal Facility
LDR Standards Established
Two types of standards established o Technology based Mandate a specific treatment method or technology that must be used to treat the waste After the specified treatment method/technology has been applied the waste can be landfilled No analysis needs to be done to determine if a particular concentration level has been reached unless 268.40 indicates that a technology standard must be met as well as any constituent concentration standards in 268.48. (refer to the standards for D001- D011 in 268.40 for examples of this situation) o Concentration based Specify a maximum concentration level that must be achieved through treatment before the waste may be landfilled Requires analysis to determine the concentration of individual waste constituents or Generator knowledge can be substituted for analysis of an individual constituent after treatment if the generator has no reason to believe that particular constituent would have been present in the waste at a concentration above the treatment standard level even before treatment (example: generator is disposing of a drum of paint waste that was generated by mixing several smaller containers of unused paint together, then he could certify by generator knowledge that the waste meets LDR treatment standards for any pesticide contaminants because he knows that pesticides are not a component of the paints that were mixed.) *Note: similar to the waste determination process, generator knowledge cannot be used to certify compliance with LDR standards if the generator does not know how the waste was generated or its complete composition.
RCRA Subtitle C - Hazardous Waste Regulatory Framework
Under Subtitle C of RCRA, EPA has developed a cradle-to-grave approach to tracking hazardous waste from its point of generation through its ultimate disposal utilizing the EPA identification numbers of all parties and the Uniform Hazardous Waste Manifest (UHWM) as the tracking and recordkeeping mechanism. The regulations are divided into requirements for hazardous waste generators, transporters, and facilities and based on the best way to protect human health and the environment given the physical and chemical properties of the specific waste material to be disposed.
WW
Wastewater (For LDR treatment standards <1% TOC & <1% TSS)
4 characteristics that make a waste regulated hazardous waste:
ignitability, corrosivity, reactivity, toxicity EPA has authorized specific test procedures/protocols to test for hazardous waste characteristics.
A hazardous waste for the purposes of RCRA is defined in 40CFR261.3 as:
o A solid waste as defined in 40CFR261.2, and o It has not been excluded from being a hazardous waste in 40CFR261.2(b), and o Meets one of the following criteria: When tested, it exhibits any of the characteristics of hazardous waste identified in 40CFR261.20-261.24, or Regardless of testing, it meets the definition of a waste listed in 40CFR261.30-261.34 (F, K, P, U), or It is a mixture of a non-hazardous waste and a listed hazardous waste that is listed in 40CFR261.30-261.34 (F, K, P, U), or It is a mixture of a non-hazardous waste and a characteristic hazardous waste that still exhibits the characteristic even after mixing.
Discarded Material is any material which is
o Abandoned (disposed of, burned or incinerated, or accumulated/stored/treated (not by recycling) before or in lieu of being disposed, burned, or incinerated) o Recycled or accumulated/stored/treated before recycling if the recycling involves any of the following: Use constituting disposal - applied to or placed on the land or used to produce a product that is applied to or placed on the land Burning for energy recovery or used to produce a fuel Reclaimed - treated in some manner in order to produce a usable material Accumulated speculatively o Inherently waste-like - very few and very specific materials fall into this category; the most common are F020-F023, F026, and F028 wastes
Underground Injection
o Deep well Liquid wastes are injected into confined geologic formations where they have no potential to migrate into potable water aquifers The Safe Drinking Water Act governs potential contamination of potable aquifers Injection must be shown to have no impact for 10,000 years Waste is injected beneath the lowermost underground source of drinking water (USDW) Used for industrial, municipal, and hazardous wastes o Shallow well Liquid wastes are injected above a USDW Used primarily for non-hazardous wastes such as storm water or septic systems by municipalities and small businesses to avoid the need for discharge to surface waters Note: Shallow well injection of hazardous waste has been banned in all circumstances except when it is used as a remediation device for the cleanup of a contaminated site. o Carbon dioxide well This category of well was added in 2012 Used primarily by coal-fired electric plants to send carbon dioxide into suitable rock formations for long-term storage Also called carbon sequestration
Residues of hazardous waste in empty containers or inner liners removed from containers that held hazardous waste are exempted from hazardous waste regulation in 40CFR261.7. "Empty container" is defined in the following manner depending on the material that the container held or the size of the container:
o For containers that held a compressed gas hazardous waste, it is empty when the pressure in the container approaches atmospheric pressure. o For containers that held P-listed hazardous waste, the container or inner liner (whichever actually came in contact with the waste) is empty when it has been triple rinsed with a solvent capable of removing the material. It could be water for water-soluble materials or an organic solvent may be necessary for non-soluble materials. It is important to note that the rinsate in this case would need to be collected as hazardous waste. It would carry the P-listing from the waste that is being rinsed from the container. o For containers that contained any other hazardous waste, the container is empty when all waste has been removed that can be removed using the practices commonly employed to remove waste from that type of container (i.e. pouring, pumping, aspirating, etc.) and For containers < 119 gallons in size, no more than 3% by weight of the total capacity of the container remains in the container or inner liner For containers > 119 gallons in size, no more than 0.3% by weight of the total capacity of the container remains in the container or inner liner
There are 18 specific exclusions in 40CFR261.4(b) for materials that qualify as solid wastes but are excluded from being hazardous wastes. The most common exclusions are:
o Household waste o Agricultural wastes, such as crop residues or farm animal manure, that is returned to the soil as fertilizer o Mining overburden that is returned to the mine site o Fly ash, bottom ash, and flue gas emission control waste from combustion of coal or other fossil fuels o Petroleum contaminated media (soil) and debris that fails TCLP for D018- D043 only and are already subject to corrective action regulations for underground storage tanks
LDR Treatment Methods (Cntd 4)
o Incineration - best for organic wastes that have low water and low halogen content Definition of incineration is the controlled burning of a substance. In order to be controlled the parameters of the combustion environment must be clearly defined, including: Temperature ranges Oxygen inputs Turbulence Atmospheric pressure Combustion chamber design Complete combustion is necessary for incineration to be effective at eliminating hazardous properties of waste Complete combustion depends on three factors o Time o Temperature o Turbulence - the amount of mixing of air and waste o Regulations and permit operating conditions are designed to optimized these factors Complete combustion ideally results in the release of carbon dioxide and water only, but realistically also yields small amounts of other gases including carbon monoxide, sulfur oxides, and nitrogen oxides Inefficient or incomplete combustion results in the above products but also other contaminants called products of incomplete combustion (PICs) o PICs include PCBs, benzopyrenes, dioxins, elemental carbon, etc.
Ignitable wastes are assigned a characteristic hazardous waste code of D001. A waste tests positive for ignitability if:
o It is a liquid with a flashpoint of < 140 degrees Fahrenheit or o It is an oxidizer (this includes organic peroxides), or o It is an ignitable compressed gas, or o 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 as to create a hazard
Corrosive wastes are assigned a characteristic hazardous waste code of D002. A waste tests positive for corrosivity if:
o It is aqueous and has a pH < 2 or > 12.5, or o It is a liquid and corrodes steel at a rate > 0.25 inch per year at 130 degrees Fahrenheit
Reactive wastes are assigned a characteristic hazardous waste code of D003. A waste tests positive for reactivity if:
o It is normally unstable and readily undergoes violent change without detonating, or o It reacts violently with water (a violent reaction would be characterized by rapid heating or boiling without the addition of heat, spattering, or flames), or o It forms potentially explosive mixtures with water, or o When mixed with water it generates toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health or the environment, or o It is a cyanide or sulfide bearing waste which, when exposed to pH conditions between 2 and 12.5, can generate toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health or the environment, or o It is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under confinement, or o It is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure, or o It is a forbidden explosive as defined in 49CFR173.54 or is a Division 1.1, 1.2, or 1.3 explosive as defined in 49CFR173.50 and 49CFR173.53.
There are 3 categories of hazardous waste generators defined by RCRA:
o Large quantity generators (LQGs) produce the most waste (2,200 lbs/1,000 kg or more) o Small quantity generators (SQGs) produce moderate amounts (between 220 and 2,200 lbs or 100 and 1,000 kg) o Conditionally exempt small quantity generators (CESQGs) produce the least amount (220 lbs/100kg or less)
Secure Landfill
o Referred to as subtitle C landfills because the requirements for them are found in subtitle C of RCRA o Also referred to as hazardous waste landfills even though wastes are required to be treated before disposal in the landfill
EPA recognized that the amenability of a hazardous waste to any particular treatment could be substantially affected by its form (whether the hazardous contaminants are very dilute or concentrated and the solids content of the waste), so they established two categories for each hazard code or hazardous constituent:
o Wastewater (indicated by WW in the tables of 40CFR268.40 and 268.48) The waste contains <1% total organic carbon (TOC) and <1% total suspended solids (TSS) This category of waste is mostly inorganic liquid with very little particulate contamination - examples could include highly concentrated inorganic solutions such as hydrochloric acid or rinse water from cleaning out a pesticide application tank that contains <1% of the pesticide residue. o Non-wastewater (indicated by NWW in the tables of 40CFR268.40 and 268.48) The waste contains >1% total organic carbon (TOC) and >1% total suspended solids (TSS) This is by far the larger category since it includes everything that does not meet the definition of WW.
Hazardous Waste Determination
this is the determination that must be made for every waste that is generated to determine if it is or is not a hazardous waste and to identify the applicable hazardous waste codes if it is determined to be a hazardous waste. The determination must be made by a combination of laboratory analysis and "generator knowledge" of the waste.
