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
Delegated authority
WI DNR – Wisconsin Department
of Natural Resources
RCRA
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 Plisted 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 (Ulisted 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 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
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.htm
http://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
 Lab pack – process of having a waste disposal
company arrive at site and package smaller
containers into one larger container
 UW-Green Bay commonly
uses this option for shipping
haz waste generated in the
lab
Disposal Options
–
removing useful parts
from waste stream for
reuse elsewhere
Reclamation
–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
 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
E.g. -UW-Green Bay
sends asbestos
material to a landfill
for disposal
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
 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.”
 The generator is legally
responsible for completion of
this document and for
submitting copies of
manifests to DNR
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
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
Universal Waste is waste that would normally have
to be treated as hazardous waste
 Has high potential for recycling
 If recycled, lower management
requirements
 Examples: mercury
thermometers and barometers,
batteries, lamps
Special Wastes have a hazardous component
 Regulatory incentives for
recycling
 If not recycled must be
treated as hazardous waste
 Examples: computers,
electronics
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.