Real World RCRA

Fall, 2004

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

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.

Who enforces these regulations?

EPA – Environmental Protection Agency

WI DNR – Wisconsin Department of Natural

Resources

RCRA

Delegated authority

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

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.

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

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

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.

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

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

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

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

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

Ignitability

Ignitability relates to the waste’s ability to burn or stimulate the burning of something else.

A liquid waste with a flash point < 140oF is considered an ignitable hazardous waste

Ignitability – an example

You do a flash point test on the spent ethanol mentioned earlier. It has a flash point of 850 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.

Corrosivity

Corrosivity relates to the waste’s ability to destroy or deteriorate materials (including skin)

An aqueous (water-containing) waste with a pH < 2.0 or > 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

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

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

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

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

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.

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 UOr 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

Basic Components for proper hazardous waste management Three basic components

Accurate waste determination Proper handling of waste on site Safe transportation and disposal

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

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)

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).

Determining Generator Status

LQG SQG VSQG

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 < 2.2 lbs

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

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

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

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)

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

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

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

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

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.htmhttp://www/epa.gov/r02earth/news/2002/02118.htm

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.

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.

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

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

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

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

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.

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.

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

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

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.

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

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.”

Waste Minimization:Less is BetterIn 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

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

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

Regulatory incentives for recycling

If not recycled must be treated as hazardous waste

Examples: computers, electronics

Special Wastes have a hazardous component

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

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.