Part III

Hazardous Waste Management

This section covers the management of those wastes that are considered to pose a significant threat,
both now and in the future, to human health and the environment when improperly managed.
Wastes considered hazardous are those which are ignitable, corrosive, reactive, and toxic. It follows
that such wastes cannot be handled or disposed without following special precautions. Wastes des-
ignated as “hazardous” are generated by a wide range of industries of varying sizes. As we shall see
in this section, specific requirements for waste management by a generator will vary as a function
of the amounts generated over a specified time frame.
Unfortunately, regulations addressing hazardous waste management were few prior to 1976,
when the Resource Conservation and Recovery Act (RCRA) was enacted. Under RCRA the U.S.
EPA was granted specific authority to regulate the generation, transportation, and disposal of haz-
ardous waste. Topics in this section will adhere to requirements of RCRA (and, to a lesser extent,
other important regulatory and legal frameworks such as those of the Department of Transportation
and the Clean Air Act) and include identification of hazardous waste; hazardous waste generator
requirements; hazardous waste transportation; treatment, storage and disposal facility requirements;
incineration; hazardous waste treatment; and land disposal of hazardous waste.
Management of nuclear (radioactive) wastes is not handled in this book; radioactive wastes are
not addressed by RCRA but by other laws, for example the Nuclear Waste Policy Act of 1982.

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 Identification of Hazardous
11 Waste

I hate facts. I always say the chief end of man is to form general propositions — adding that no general
proposition is worth a damn.

Oliver Wendell Holmes, Jr.

The Mind and Faith of Justice Holmes

11.1 INTRODUCTION
As discussed in Chapter 3, the Resource Conservation and Recovery Act (RCRA) was the first truly
significant step in the comprehensive management of hazardous as well as municipal wastes in the
U.S. The ultimate goal of RCRA is to promote the protection of public health and the environment
and to conserve material and energy resources. RCRA requires the U.S. EPA to promulgate and
enforce regulations regarding the management of hazardous waste. These regulations established
mandatory procedures and requirements for compliance with RCRA. RCRA has remained current
with waste management issues and problems by being amended several times. The most sweeping
set of amendments was included in 1984 as the Hazardous and Solid Waste Amendments (HSWA).
RCRA has nine subtitles, each of which addresses some aspects of resource conservation and
waste management. Subtitle C is the primary component that deals with management of hazardous
waste. Its goal is to identify a hazardous waste and set standards for the accumulation, storage,
transportation, treatment, and disposal of hazardous waste. The provisions of Subtitle C apply to a
waste from the moment it becomes hazardous until it is no longer a hazardous waste. This embraces
the so-called “cradle-to-grave” approach to the regulation of hazardous waste.
Hazardous waste management regulations are published in the Federal Register, which is pub-
lished daily. The Federal Register provides a system for making regulations and legal notices issued
by federal agencies available to the public.

11.2 THE RCRA SUBTITLES

U.S. EPA regulations are compiled in Title 40 of the Code of Federal Regulations (40 CFR),
Protection of the Environment. The topics are as follows:

Subtitle Topic
A General Provisions
B Office of Solid Waste, Authorities of the EPA administrator
C Hazardous Waste Management
D State or Regional Solid Waste Plans
E Duties of the Secretary of Commerce in Resource Recovery
F Federal Responsibilities
G Miscellaneous Provisions
H Research, Development, Demonstration, and Information
I Underground Storage Tanks

373

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374 Waste Management Practices: Municipal, Hazardous, and Industrial

Subtitle A declares that the production of hazardous waste is to be reduced; furthermore, land
disposal is to become the least favored method of hazardous waste disposal. Wastes are to be han-
dled in order to minimize the threat to human health and the environment. Subtitle A includes a set
of objectives to achieve these goals, including:

● A prohibition of open dumping of waste

● State control of RCRA programs
● Promotion of research and development activities for sound waste management
● Encouragement of waste recovery, recycling, and treatment as alternatives to waste disposal

A summary of federal regulations implementing the hazardous waste management require-

ments of RCRA is shown in Table 11.1. Parts 124, 260 through 268, 270, 273, and 279 specifically
address the management of hazardous wastes.
Part 124 contains EPA procedures for issuing, modifying, revoking, and reissuing or terminat-
ing all RCRA permits.
Part 261 identifies the wastes that are subject to regulation as hazardous waste. This part defines
the terms “solid waste” and “hazardous waste,” identifies those wastes that are excluded from reg-
ulations, and establishes special management requirements for hazardous waste produced by con-
ditionally exempt small quantity generators and for hazardous waste which is recycled. Part 261
identifies characteristics and contains the various lists of hazardous wastes.
Part 262 contains the rules with which generators of hazardous waste must comply. This part
requires a facility to evaluate all wastes generated on-site to determine if they meet the definition of
hazardous waste. It also explains the conditions under which a hazardous waste manifest must be
used, describes a generator’s transportation requirements, and details the record keeping and report-
ing requirements.
Part 263 establishes standards that apply to people transporting hazardous wastes within the
United States. In promulgating the regulations, the U.S. EPA has adopted regulations of the
Department of Transportation (DOT) governing the transportation of hazardous materials. These reg-
ulations pertain to container labeling, marking, placarding, using proper containers, and reporting
discharges of hazardous waste.

TABLE 11.1
Summary of Federal Regulations Implementing the
Hazardous Waste Management Requirements of RCRA
40 CFR Part Coverage of the Regulations
124 Public participation
260 General requirements, definitions, petitions
261 Identification and listing of hazardous waste
262 Generators of hazardous waste
263 Transporters of hazardous waste
264 Permitted hazardous waste facilities
265 Interim status hazardous waste facilities
266 Certain specific hazardous wastes and facilities
268 Land disposal restrictions
270 EPA administered permits
271 State hazardous waste programs requirements
273 Universal hazardous waste
279 Standards for the management of used oil

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Identification of Hazardous Waste 375

Part 264 presents the requirements that apply to facilities that treat, store, or dispose of haz-
ardous waste. It contains general standards by which all hazardous waste treatment, storage, and
disposal facilities must be operated as well as specific requirements for surface impoundments,
waste piles, landfills, incinerators, land treatment facilities, and facilities with containers and tank
systems used for storing or processing hazardous waste.
Part 265 establishes minimum standards that apply to facilities that treat, store, or dispose of
hazardous waste and have interim status. Part 265 regulations apply to facilities that were operating
before the RCRA regulations were finalized and have not yet received a final permit to operate their
facility or have closed but are under EPA orders to correct some problems on-site. This part also
contains the requirements for training, preparedness and prevention, and contingency planning.
Part 266 contains standards for the management of specific hazardous wastes and specific types
of hazardous waste management facilities. This part includes regulations that apply to recyclable
materials, hazardous waste burned for energy recovery, recyclable materials utilized for precious
metal recovery, and spent lead-acid batteries being reclaimed.
Part 268 identifies hazardous wastes that are restricted from land disposal and defines those cir-
cumstances under which a restricted waste may continue to be land disposed.
Part 270 covers basic EPA permitting requirements for hazardous waste management facilities
such as the information to be included in the permit application, monitoring and reporting require-
ments, and the conditions under which permits can be transferred or modified.
Part 271 specifies the minimum requirements with which a state must comply to receive author-
ization to administer and enforce its own hazardous waste management program in lieu of the fed-
eral programs.
Part 273 includes the management system for hazardous wastes batteries, pesticides, and ther-
mostats. This program is referred to as the Universal Waste Program. These regulations cover the
standards for universal waste handlers, transporters, and destination facilities.
Part 279 establishes minimum management standards that apply to used oil generators, collec-
tion centers, aggregation points, transporters, transfer facilities, processors, re-refiners, burners, and
marketers of used oil fuel. This part also places limitations on the use of used oil as a dust sup-
pressant and on the disposal of used oil.

11.3 SUBTITLE C: THE HAZARDOUS WASTE MANAGEMENT PROGRAM

11.3.1 DEFINITION OF A SOLID WASTE
Before a regulatory agency and a potential generator (i.e., a facility) address the issue of whether
or not a specified waste is hazardous, they must first determine whether or not the waste is a solid
waste. According to 40 CFR 261.2, a solid waste is any discarded material that is not excluded
from the regulations. Going further into the definition, a discarded material is any material which
is abandoned, recycled, “inherently waste-like,” or military munitions identified as a solid waste
in 40 CFR 266.202.
An abandoned material is one which is (1) disposed of; (2) burned or incinerated; or (3) accu-
mulated, stored, or treated (but not recycled) by being disposed or burned.
Materials are solid wastes if they are recycled, accumulated, stored, or treated before recycling.
This includes being: (1) used or placed on the land in a manner that constitutes disposal; (2) burned
for energy recovery; (3) reclaimed; or (4) accumulated speculatively.
Some of the major types of materials that are recycled include (40 CFR 261.2):

● Spent material. These are materials that have been used and as a result of contamination
can no longer serve the purpose for which it was produced without processing.
● Sludges. Solid, semisolid, or liquid waste generated from a municipal, commercial, or indus-
trial wastewater treatment plant; water supply treatment; or air pollution control facility.

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376 Waste Management Practices: Municipal, Hazardous, and Industrial

● By-products. A material that is produced as part of a production process but is not a pri-
mary product of the process. An example is process residue such as slag.
● Scrap metal. Metal parts (e.g., bars, rods, sheets, and wire) which when worn out or no
longer needed, can be recycled.
● Discarded commercial chemical products, off-specification species, container residues,
and spill residues.

Inherently waste-like materials are those which have no other possible fate except disposal. For
example, hazardous waste designated by the numbers F020, F021 F022, F023, F026, and F028 (all
chlorinated hazardous wastes), when they are recycled in any manner, fall into the inherently waste-
like category. The F-listing and other hazardous waste listings are described below.

11.3.2 WHAT IS A HAZARDOUS WASTE

If a solid waste does not qualify for an exemption, it is declared hazardous waste if it is listed by
EPA in 40 CFR Part 261, Subpart D, or if it exhibits any of the four hazardous waste characteris-
tics identified in 40 CFR Part 261, Subpart C. The complete hazardous waste lists are available on
the Internet at http://www.access.gpo.gov/nara/cfr/waisidx_03/40cfr261_03.html.

11.3.3 EXEMPTIONS AND EXCLUSIONS

The EPA regulations automatically exempt certain solid wastes from the ‘hazardous waste’ desig-
nation under Subtitle C. There are three categories of exclusions: wastes excluded from the defini-
tion of solid waste, wastes excluded from the definitions of hazardous waste, and hazardous wastes
that are partially excluded provided that they are managed in accordance with specific requirements.
Table 11.2 lists the wastes contained under these exclusions.

TABLE 11.2
Exclusions from Subtitle C of RCRA
Excluded from the Solid Waste
Definition
Domestic sewage
Mixture of domestic sewage and wastes
going to POTW
Industrial point source-discharges under
402 CWA
Irrigation returns flows
Sources, special nuclear, or by-product
material under AEA
In-situ mining waste
Reclaimed pulping liquors
Regenerated sulfuric acid
Secondary materials returned to the
original process under certain
conditions
Excluded from the Hazardous Waste Excluded Materials Requiring
Definition Special Management
Household wastes Product storage wastes
Agricultural wastes used as fertilizers Waste identification samples
Mining overburden returned to site Treatability samples
Discarded wood treated with arsenic Empty containers
Chromium wastes Small-quantity generator wastes
Underground storage tank cleanup
wastes
Specific ore processing wastes Farm wastes (pesticides)
Specific utility wastes
Oil and gas exploration, development,
and production wastes
Cement kiln dust

Source: 40 CFR Part 261.4. With permission.

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Identification of Hazardous Waste 377

11.3.4 HAZARDOUS WASTE LISTS

11.3.4.1 Hazardous Waste from Nonspecific Sources
Wastes in this category are placed on the so-called F-list. These wastes are determined to be haz-
ardous; however, they are not generated by a specific industry or manufacturing process. Wastes on
the F-list include certain solvent wastes, plating wastes, metal-treating wastes, wood-preserving
wastes, petroleum refinery oil–water–solids separation sludge, leachate from treatment, storage or
disposal facilities, wastes from the manufacture of certain chlorinated compounds, and treatment
residue from the incineration or thermal treatment of soil contaminated with certain chlorinated
compounds. The general categories of F-listed wastes are as follows:
● Solvent wastes (F001–F005)
● Electroplating wastes (F006–F009)
● Metal-treating wastes (F010–F019)
● Wood-preserving wastes (F032–F035)
● Petroleum refining wastes (F037–F038)

In addition, process wastes, discarded unused formulations, and incineration residues from the
production of certain chlorinated aliphatic hydrocarbons, trichlorophenol, tetrachlorophenol, pen-
tachlorophenol, and tetra-, penta-, or hexachlorobenzenes are included in the list of nonspecific
source wastes.

11.3.4.2 Hazardous Wastes from Specific Sources

Wastes placed on the K-list originate from specific sources or industries that EPA has determined
to be hazardous. For example, sludge from the treatment of wastewaters by the wood-preserving
industry would fall into this category (K001). K048 and K052 include certain petroleum refining
wastes, for example. Wastes on the K-list include those generated by the following industries:
● Wood preservation
● Inorganic pigment production
● Organic chemical production
● Inorganic chemical production
● Pesticide production
● Explosives manufacturing and production
● Petroleum refining
● Iron and steel production
● Primary copper production
● Primary lead production
● Primary zinc production
● Primary aluminum production
● Ferroalloy production
● Secondary lead smelting
● Veterinary pharmaceutical production
● Ink formulation
● Coking industries

11.3.4.3 Discarded Commercial Products, Off-Specification Materials, Container

Residues, and Spill Residues
Materials on the P- and U-lists are classified as acute hazardous waste and as toxic waste, respec-
tively. These wastes include certain commercial chemical products having the generic names listed
on the P- and U-lists located in 40 CFR 261.33 when they are discarded.

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378 Waste Management Practices: Municipal, Hazardous, and Industrial

Examples of commercial chemical product hazardous wastes include products from hospitals
(e.g., pharmaceuticals past their expiration date, and unused reagents), research laboratories (expired
or unused reagents intended for disposal), photography laboratories, and analytical laboratories. These
items become hazardous waste when it is decided that they must be disposed. Some products, how-
ever, can be tested in order to determine if their expiration date can be extended. If there is another use
for the material, it can be stored or used for that purpose without being classified as a hazardous waste.

11.3.5 THE CHARACTERISTIC TESTS

New chemical products are regularly available. As a result, new types of wastes are being produced
as well. Since many wastes are chemical newcomers, they will obviously not be found listed in the
Code of Federal Regulations. Other methods are needed to determine potential hazards of a waste.
The U.S. EPA has established the four so-called ‘characteristic tests’ to determine whether or not a
waste is hazardous.

11.3.6 IGNITABILITY
The ignitability characteristic indicates those wastes that pose a fire hazard during routine handling,
for example, storage, transport, processing, or disposal. Specifically, a solid waste exhibits the char-
acteristic of ignitability if a sample possesses any of the following properties (40 CFR Part 261.21):

● It is a liquid, other than an aqueous solution, containing less than 24% alcohol (by vol.)
and has flash point less than 60°C (140°F), as determined by a Pensky–Martens Closed
Cup Tester (U.S. EPA, 1986; ASTM Standard D-93-79 or D-93-80) or a Setaflash Closed
Cup Tester (ASTM Standard D-3278-78).
● 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 that it creates a hazard.
● It is an ignitable compressed gas as defined in 49 CFR 173.300.
● It is an oxidizer as defined in 49 CFR 173.151.

Examples of characteristic (D-list) hazardous wastes include:

● Solvents used for parts cleaning or degreasing

● Paint thinners and paint removing compounds
● Carbon remover and nail polish remover solutions
● Organic-solvent-based wheel strippers

A solid waste that exhibits the characteristic of ignitability is given the EPA hazardous waste
number D001.

11.3.7 CORROSIVITY
Corrosive wastes occur at extremes in pH. Wastes with very low or high pH values can corrode stan-
dard drums, oxidize skin and other living tissue, and mobilize components from certain wastes.
Examples of corrosive wastes include acid wastes and alkali wastes. A solid waste exhibits the char-
acteristic of corrosivity if a sample has either of the following properties (40 CFR Part 261.22):

● It is aqueous and has a pH ⭐ 2 or ⭓ 12.5 as determined by a pH meter (Method 9040,

U.S. EPA, 1986).
● It is a liquid and corrodes steel at a rate greater than 6.35 mm (0.25 in.) per year and at
a temperature of 55°C (130°F) as determined by the test method specified in the National

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Identification of Hazardous Waste 379

Association of Corrosion Engineers Standard TM-01-69 as standardized in U.S. EPA

(1986).

Wastes generated from the following processes are examples of corrosive hazardous wastes:

● Parts-cleaning operations using highly alkaline cleaning solutions

● Alkaline strippers used to strip paint
● Acidic wastes generated from electroless metal plating lines
● Battery acid and other waste acids
● Phenol wastes

A solid waste that exhibits the characteristic of corrosivity is given the EPA hazardous waste
number D002.

11.3.8 REACTIVITY
Wastes possessing the characteristic of reactivity are often unstable, and pose hazards of explosion
and release of toxic gases during routine management. Examples of reactive wastes include picrate
salts (derived from picric acid, 2,4,6-trinitrophenol), and certain epoxides and peroxides.
Other wastes generated from the following processes are examples of reactive hazardous wastes:

● Cyanide bearing electroplating solutions (unless they are listed in 40 CFR 261.31, F-list)
● Ordinances and explosives listed by DOT as Division 1.1, 1.2, or 1.3 explosive, or for-
bidden explosives

The characteristic of reactivity in a waste sample is often difficult to determine quantitatively

in the laboratory. A waste exhibits the characteristic of reactivity if a representative sample pos-
sesses any of the following properties (40 CFR Part 261.23):

● It is normally unstable and readily undergoes violent changes without detonating.

● It reacts violently with water.
● It forms potentially explosive mixtures with water.
● 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.
● 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 pose a
danger to human health or the environment.
● It is capable of detonation or explosive reaction if it is subjected to a strong initiating
source or if heated under confinement.
● It is capable of detonation or explosive reaction at standard temperature and pressure.
● It is forbidden explosive as defined in 49 CFR 173.51, a Class A explosive as defined in
49 CFR 173.53, or a Class B explosive as defined in 49 CFR 173.88, DOT regulations.

A solid waste that exhibits the characteristic of reactivity is given the EPA hazardous waste
number D003.

11.3.9 TOXICITY
The toxicity characteristic leaching procedure (TCLP) was formulated to simulate environmental
conditions in an exposed landfill. The intent of the test is to determine whether potentially toxic
components of the waste could leach to groundwater and soil if exposed to acidic precipitation.
The TCLP replaced the EP toxicity test in 1990. The new test includes 25 organic compounds as
well as the eight metals and six pesticides in the EP test. In the TCLP, a representative sample is shaken

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380 Waste Management Practices: Municipal, Hazardous, and Industrial

in dilute acetic acid for 16 to 20 h, filtered, and the filtrate is analyzed for the required metals and
organic compounds. Where the waste contains less than 0.5% filterable solids, the waste itself is con-
sidered to be the extract. Details of the method are provided in TCLP, Method 1311 (U.S. EPA, 1986).
If the extract from a representative waste sample contains any of the contaminants listed in
Table 11.3 at a concentration greater than or equal to the regulatory level, the waste exhibits the

TABLE 11.3
Details on the Toxicity Characteristic Compounds (TCLP)
EPA Hazardous Contaminant CAS No. Regulatory
Waste Number Level (mg/L)
D004 Arsenic 7440-38-2 5.0
D005 Barium 74401-39-3 100.0
D018 Benzene 71-43-2 0.5
D006 Cadmium 7440-43-9 1.00
D019 Carbon tetrachloride 56-23-5 0.5
D020 Chlordane 57-74-9 0.03
D021 Chlorobenzene 108-90-7 100.0
D022 Chloroform 67-66-3 6.0
D007 Chromium 7440-47-3 5.0
D023 o-Cresol 95-48-7 200.0
D024 m-Cresol 108-39-4 200.0
D025 p-Cresol 106-44-5 200.0
D026 Cresol 200.0
D016 2,4-D 94-75-7 10.0
D027 1,4-Dichlorobenzene 106-46-7 7.5
D028 1,2-Dichloroethane 107-06-2 0.5
D029 1,1-Dichloroethylene 75-35-4 0.7
D030 2,4-Dinitrotoluene 121-14-2 0.13
D012 Endrin 72-20-8 0.02
D031 Heptachlor (and its epoxide) 76-44-8 0.008
D032 Hexachlorobenzene 118-74-1 0.13
D033 Hexachlorobutadiene 87-68-3 0.5
D034 Hexachloroethane 67-72-1 3.0
D008 Lead 7439-92-1 5.0
D013 Lindane 58-89-9 0.4
D009 Mercury 7439-97-6 0.2
D014 Methoxychlor 72-43-5 10.0
D035 Methyl ethyl ketone 78-93-3 200.0
D036 Nitrobenzene 98-95-3 2.0
D037 Pentrachlorophenol 87-86-5 100.0
D038 Pyridine 110-86-1 5.0
D010 Selenium 7782-49-2 1.0
D011 Silver 7440-22-4 5.0
D039 Tetrachloroethylene 127-18-4 0.7
D015 Toxaphene 8001-35-2 0.5
D040 Trichloroethylene 79-01-6 0.5
D041 2,4,5-Trichlorophenol 95-95-4 400.0
D042 2,4,6-Trichlorophenol 88-06-02 2.0
D017 2,4,5-TP (Silvex) 93-72-1 1.0
D043 Vinyl chloride 75-01-4 0.2

Source: 40 CFR Part 261.24. With permission.

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Identification of Hazardous Waste 381

toxicity characteristic. The following wastes are examples of common toxicity characteristic wastes
(40 CFR Part 261.24):

● Paint waste containing metals such as lead, chromium, silver, or cadmium

● Metal strip baths used to remove paint and chrome plating
● Mercury waste from analytical instruments, dental amalgam, and batteries
● Wastewater and sludge from fabric finishing containing tetrachloroethylene
● Oily wastes and sludge from the petroleum marketing industry containing benzene

A solid waste that exhibits the characteristic of toxicity has the EPA Hazardous Waste Number
specified in Table 11.3.
The U.S. EPA has assigned specific hazardous waste numbers and codes to both characteristic and
listed wastes. Each listed hazardous waste will have one or more codes associated with it (Table 11.4).
Many hazardous wastes meet the requirements of more than one waste type. During a waste determi-
nation, all applicable waste codes must be identified and documented.
To summarize, if a solid waste is not a listed hazardous waste and does not exhibit one of the
above four characteristics, it is not in the RCRA system. Even if this is the case, however, the waste
may still be subject to regulation; for example, it may fall under state regulations.

11.3.10 MIXTURES OF HAZARDOUS WASTES WITH OTHER MATERIALS

In addition to a waste being defined as hazardous waste if it is specifically listed or exhibits a haz-
ardous characteristic, a waste is also classified as hazardous if it is: (1) a mixture of a listed haz-
ardous waste and a solid waste (i.e., the mixture rule), (2) a listed hazardous waste contained within
another material (the contained-in rule), or (3) a solid waste generated from the treatment, storage,
or disposal of a listed hazardous waste.

11.3.11 THE MIXTURE RULE

A mixture of any amount of hazardous waste and a solid (nonhazardous) waste is considered a haz-
ardous waste (40 CFR 261.3). There is no de minimis concentration that qualifies for an exclusion
from the mixture rule except for certain mixtures in wastewater treatment systems. For example, if
an employee mixes spent ethyl ether (F003) with an absorbent clay to reduce the liquid content, the
entire mixture is classified as F003.
An exception to the mixture rule is as follows: if the mixture is hazardous solely because it
exhibits a characteristic and the resultant mixture no longer exhibits the same characteristic, it is not
considered a hazardous waste. An example is a paint waste that is an ignitable hazardous waste. A
mixture of the paint waste and a nonignitable, nonhazardous waste (e.g., machine oil) would

TABLE 11.4
Codes for Hazardous Wastes under RCRA
Waste Type EPA Number EPA Code
Ignitable D001 I
Corrosive D002 C
Reactive D003 R
Toxicity characteristic D004–D043 E
Toxic F-, K-, and U-lists T
Acutely hazardous F- and P-lists H

Source: 40 CFR Part 261. With permission.

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382 Waste Management Practices: Municipal, Hazardous, and Industrial

become nonhazardous, provided the mixture no longer exhibits the ignitability characteristic. It
must be emphasized, however, that such wastes become nonhazardous only by the inadvertent,
unavoidable mixing occurring during standard processes at the facility. In other words, a facility
cannot deliberately mix a nonhazardous waste with hazardous waste to render it nonhazardous.
Treating a hazardous waste to render it nonhazardous may require a permit (40 CFR 262.34).

11.3.12 THE CONTAINED-IN RULE

The contained-in rule (40 CFR 261.3) relates to the incorporation of typically natural materials
(e.g., soil, groundwater) with a hazardous waste. For example, if a surface impoundment leaks a
listed hazardous waste into local groundwater, the resulting contaminated groundwater is to be man-
aged as a hazardous waste.

11.3.13 THE DERIVED-FROM RULE

The derived-from rule presented in 40 CFR 261.3 states that any solid waste generated from the treat-
ment, storage, or disposal of a hazardous waste including any sludge (pollution control residue), spill
residue, ash, emission control dust, or leachate (not including precipitation runoff) is a hazardous
waste. Thus, in the case of residues generated from the treatment of a listed waste, all residues remain
hazardous unless specifically delisted. The generator is required to prove that the waste is no longer
hazardous through the delisting process, or the treatment residues are managed as hazardous waste.
A facility that treats F-listed hazardous wastes, for example via incineration, must manage the incin-
erator ash as hazardous waste although the toxicity of the waste may be greatly reduced. This rule
also applies to treatment of hazardous wastes during a corrective action.

11.4 GENERATION OF HAZARDOUS WASTES

Table 11.5 presents recent national hazardous waste generation totals according to the percentage
of characteristic wastes, listed wastes, or a mixture of both. Wastes categorized as only characteris-
tic wastes represented 52% (20.9 million tons) of the national generation total, while listed-only
wastes comprised 18% (7.3 million tons), and wastes with both characteristic and listed waste codes
constituted 29% (11.8 million tons) of the national total.

TABLE 11.5
Tons of Generated Waste that were Only Characteristic Waste, Only Listed Waste, or Both
Characteristic and Listed Waste, 1999
Only Characteristic Wastes Only Listed Wastes Both a Characteristic and a Listed Waste
Ignitable only 681,936 F code only 2,213,492
Corrosive only 1,075,431 K code only 3,695,803
Reactive only 247,748 P code only 80,396
D004-17 2,379,016 U code only 496,466
D018-43 4,464,793
More than one 12,082,405 More than one 845,353
characteristic code listed code
Total 20,391,330 Total 7,331,509 Both characteristic 11,760,240
and listed

Note: All quantities are in tons.

Source: U.S. EPA, 2001.

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Identification of Hazardous Waste 383

11.4.1 QUANTITIES OF TOXICS RELEASE INVENTORY CHEMICALS IN WASTE BY INDUSTRY

The Toxics Release Inventory (TRI) is a publicly available database that contains information on
waste management activities reported annually by certain industries and federal facilities. There are
nearly 650 toxic chemicals and toxic chemical categories on the list of chemicals that must be
reported to EPA and the states. These chemicals do not always correspond exactly to RCRA wastes;
however, they provide a useful overview of the types and amounts of toxic chemicals generated in
the United States.
According to the TRI, the chemical manufacturing industry reported the largest quantity of
toxic chemicals in production-related waste managed in 2001, with 10.69 billion pounds or 40% of
the total reported by all industries (Table 11.6). The primary metals industry reported the second
largest quantity of toxic chemicals in production-related waste managed in 2001, with 3.10 billion
pounds or 12% of the total. The metal mining industry reported the third largest quantities of toxic
chemicals and the largest quantity released on- and off-site in 2001. With 2.87 billion pounds, metal
mining facilities accounted for 11% of toxic chemicals in production-related waste managed by all

TABLE 11.6
Quantities of TRI Chemicals in Waste by Industry, 2001
Industry Total Production-Related
Waste Managed (lb)
Metal mining 2,869,626,395
Coal mining 16,481,994
Food 1,090,077,820
Tobacco 5,309,980
Textiles 40,714,851
Apparel 1,803,460
Lumber 69,202,953
Furniture 15,058,736
Paper 1,374,388,098
Printing 370,693,356
Chemicals 10,688,079,114
Petroleum 878,617,109
Plastics 205,625,949
Leather 8,407,158
Stone, Glass or Clay 653,183,379
Primary metals 3,100,713,329
Fabricated metals 661,029,051
Machinery 130,427,694
Electrical equipment 592,437,820
Transportation equipment 260,042,330
Measure or Photo 62,566,249
Miscellaneous 40,766,891
Multiple SIC codes 20 to 39 966,557,214
No SIC codes 20 to 39 27,510,857
Electric utilities 1,561,124,192
Chemical wholesale distributors 41,079,498
Petroleum bulk terminals or bulk storage 46,278,144
Hazardous waste or solvent recovery 957,788,017
Total 26,735,591,638

Source: U.S. EPA, 2001. With permission.

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384 Waste Management Practices: Municipal, Hazardous, and Industrial

TABLE 11.7
Top 20 Chemicals with the Largest Total Production-Related Waste, 2001
CAS Number Chemical Total Production-Related
Waste Managed (lb)
67-56-1 Methanol 2,331,011,667
108-88-3 Toluene 1,787,944,977
7647-01-0 Hydrochloric acid 1,504,105,058
— Zinc compounds 1,355,504,817
— Copper compounds 1,263,772,355
74-85-1 Ethylene 1,256,806,620
7440-50-8 Copper 1,088,001,030
110-54-3 n-Hexane 970,193,833
— Lead compounds 965,794,108
98-82-8 Cumene 832,570,075
7664-41-7 Ammonia 800,432,076
115-07-1 Propylene 797,566,959
— Nitrate compounds 701,130,070
7664-93-9 Sulfuric acid 583,305,201
107-21-1 Ethylene glycol 565,972,276
107-06-2 1,2-Dichloroethane 561,860,469
7782-50-5 Chlorine 552,091,471
1330-20-7 Xylene (mixed isomers) 479,477,559
— Manganese compounds 477,625,043
7697-37-2 Nitric acid 411,681,261
Subtotal (top 20 chemicals) 19,286,846,925
Total (all chemicals) 26,735,591,638

U.S. EPA, 2001. Data are from Section 8 of Form R.

industries in 2001. Electric utilities reported the fourth largest amount of toxic chemicals in 2001
with 1.56 billion pounds, representing 6% of the total managed. This industry reported the second
largest amount released on- and off-site, with 1.06 billion pounds or 17% of the quantity released
by all industries in 2001.

11.4.2 QUANTITIES OF TRI CHEMICALS IN WASTE BY CHEMICAL

Table 11.7 lists the 20 TRI chemicals managed in production-related waste in 2001 in the largest
quantities. Production-related waste managed from the top 20 TRI chemicals totaled 19.29 billion
pounds, i.e., 72% of all toxic chemicals in production-related waste.
The TRI chemical with the largest quantity released on- and off-site was copper compounds
(1.01 billion pounds), accounting for 16% of all releases on- and off-site in 2001. Copper com-
pounds ranked fifth for total toxic chemicals managed in production-related waste. Zinc compounds
were released on- and off-site in the second largest amounts (982.9 million pounds), and ranked
fourth for total toxic chemicals managed in production-related waste. Hydrochloric acid was
released on- and off-site in the third largest amount (587.6 million pounds) and ranked third for total
toxic chemicals managed in production-related waste and second for on-site treatment.

REFERENCES
Code of Federal Regulations, Vol. 40, Part 261, Identification and Listing of Hazardous Waste, U.S.
Government Printing Office, Washington, DC, 2004.

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Identification of Hazardous Waste 385

U.S. Environmental Protection Agency, Toxics Release Inventory (TRI), Public Data Release, Executive
Summary, 2001. See: http://www.epa.gov/tri/tridata/tri01/pdr/index.htm
U.S. Environmental Protection Agency, Method 9040. pH Electrometric Measurement. Test Methods for
Evaluating Solid Waste, Physical/Chemical Methods, EPA SW-846, Washington, DC, 1986a.
U.S. Environmental Protection Agency, Pensky–Martens Closed-Cup Method for Determining Ignitability,
Method 1010, Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA SW-846,
Washington, DC, 1986b.

SUGGESTED READINGS AND WEB SITES

Environment, Health and Safety Online, State Government Downloads and Links, 2003. See: http://www.
ehso.com/stategov.php
Environmental Health and Safety Online, Identifying Hazardous Waste, 2002. See: http://www.ehso.com/
hazwaste_ID.htm
U.S. Department of Energy, Overview of the Identification of Hazardous Waste Under RCRA, 1999. See:
http://tis.eh.doe.gov/oepa/guidance/rcra/define.pdf
U.S. Environmental Protection Agency, Final Paint Listing, 2002. See: http://www.epa.gov/epaoswer/
hazwaste/id/paint/index.htm
U.S. Environmental Protection Agency, Hazardous Waste Identification Studies, 2002. See: http://www.epa.gov/
epaoswer/hazwaste/id/studies.htm
U.S. Environmental Protection Agency, Hazardous Waste Management System; Identification and Listing of
Hazardous Waste; Chlorinated Aliphatics Production Wastes; LDRs for Newly Identified Wastes; and
CERCLA Hazardous Substance Designation and Reportable Quantities, Final Rule, Nov. 08, 2000,
2002. See: http://www.epa.gov/epaoswer/hazwaste/id/chlorali/index.htm
U.S. Environmental Protection Agency, Hazardous Waste Management System; Identification and Listing of
Hazardous Waste: Dye and Pigment Industries; LDRs for Newly Identified Wastes; CERCLA
Hazardous Substance Designation and Reportable Quantities; Proposed Rule - July 23, 1999, 2002.
See: http://www.epa.gov/epaoswer/hazwaste/id/dyes/index.htm
U.S. Environmental Protection Agency, Hazardous Waste Characteristics Scoping Study, 1996. See: http://
www.epa.gov/epaoswer/hazwaste/id/char/scopingp.pdf
U.S. Environmental Protection Agency, 1998 RCRA §3007 Survey of the Inorganic Chemicals Industry, 1998.
See: http://www.epa.gov/epaoswer/hazwaste/id/inorchem/index.htm
U.S. Environmental Protection Agency, Petroleum Refining Process Wastes Listing Final Rule, August 6,
1998, 2002. See: http://www.epa.gov/epaoswer/hazwaste/id/petroleum/index.htm
U.S. Environmental Protection Agency, RCRA Hazardous Waste Delisting: The First 20 Years, 2002. See:
http://www.epa.gov/epaoswer/hazwaste/id/delist/index.htm

QUESTIONS
1. What is the top priority for hazardous waste management (general method) under
RCRA? What is the lowest priority?
2. Which of the following under RCRA is (are) not excluded from the rules and regulations
applicable to hazardous waste generators, treatment, storage, disposal, and transporta-
tion? (a) domestic sewage; (b) spent nuclear or by-product material; (c) household waste;
(d) spent halogenated solvents.
3. What are acute hazardous wastes? Provide an accurate technical definition.
4. Which of the following property(ies) is (are) not characteristics that define a RCRA haz-
ardous waste? (a) radioactive; (b) corrosive; (c) ignitable; (d) reactive; (e) biohazard.
5. What pH range does noncorrosive waste display?
6. What is the name of the test method used to determine if a waste is toxic? Describe the
details of the method.
7. Can a generator legally mix a listed hazardous waste with sufficient nonhazardous solid
waste to the point where it can be diluted and therefore is no longer classified as a haz-
ardous waste? Discuss.

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386 Waste Management Practices: Municipal, Hazardous, and Industrial

8. The Hi-Jinx Metalworks Corp. has produced several gallons of a spent paint stripper.
Based solely on the Material Safety Data Sheet (following pages), could this waste be a
RCRA hazardous waste?
9. Outside one of the Hi-Jinx warehouses (which has stored paint stripper in the past),
several drums are discovered and there is a sweet solvent odor. Is the contaminated soil
considered a hazardous waste? Explain.
10. The environmental safety officer at the Hi-Jinx plant identifies dozens of drums contain-
ing a reddish filter cake near the site’s electroplating wastewater treatment plant. After
analyzing the filter cake, the level of chromium in the sludge is determined to be 75
mg/kg and the TCLP test measures 2 mg/L in the resulting leachate. What can the facil-
ity conclude regarding the waste and its proper management?
11. Can a waste be both a listed hazardous waste and a characteristic hazardous waste? Explain.
12. An automobile body shop and painting facility is in operation. Metal parts are reworked
and repainted; engine components are cleaned and reworked; fiberglass and metal body
parts are repaired, replaced, and painted. List at least ten different types of waste gener-
ated at the facility. Separate into solid (nonhazardous) and hazardous (listed and charac-
teristic) wastes.
13. List potential sources of hazardous waste generated in your university. Name any listed
hazardous wastes. To what list(s) do they belong? If not listed, what are the specific char-
acteristics that render these wastes hazardous?
14. Write in the name of each list on the table below:

Name of List Waste Types Covered

—-List -Nonspecific sources
-Solvents
Provide examples of wastes your university -Electroplating wastes
generates on this list: -Wood preserving wastes
-Chlorinated aliphatic hydrocarbons
-Certain pesticide wastes

—-List -Specific source wastes

-Wood preserving
Provide examples of wastes your university -Chemical manufacturing
generates: -Petroleum refining
-Explosives manufacturing
-Metal processing

—-List Acutely hazardous commercial chemical

products
Provide examples of wastes your university
generates:

—-List Toxic commercial chemical products

Provide examples of wastes your university
generates:

15. For the four hazardous waste characteristics, list their hazardous waste numbers in the table:
Characteristic EPA Waste Number
Ignitable
Corrosive
Reactive
Toxicity characteristic

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Identification of Hazardous Waste 387

MATERIAL SAFETY DATA SHEET

Product Identification: METHYLENE CHLORIDE INDUST GRADE

ITEM DESCRIPTION
Item Name: DICHLOROMETHANE, TECHNICAL
Type of Container: DRUM

HAZARDS IDENTIFICATION, EMERGENCY OVERVIEW

Health Hazards Acute & Chronic: ACUTE:IRRITATION OF EYES, SKIN AND RESPIRA-
TORY TRACT, CNS
EFFECTS, DIZZINESS, WEAKNESS, FATIGUE, NAUSEA, HEADACHE, G. I. TRACT
DISTURBANCES, NAUSEA, VOMITING, DIARRHEA. CHRONIC: INCREASE CO LEVEL IN
BLOOD CAUSING CARDIOVASCULAR STRESS, CNS EFFECTS.
Signs & Symptoms of Overexposure:
EYE, SKN: IRRT, INHL: IRRT, DIZZ, WEAK, FATIGUE, NAUS, HEAD, UNCONSC.
INGEST: ALSO GI IRRT, NAUS, VOMIT, DIARR.
Medical Conditions Aggravated by Exposure:
PRE-EXISTING CONDITIONS MAY BE WORSENED.
Route of Entry Indicators:
Inhalation: YES
Skin: YES
Ingestion: YES
Carcenogenicity Indicators
NTP: NO
IARC: YES
OSHA: N/P
Carcinogenicity Explanation: METHYLENE CHLORIDE IS SUSPECTED CARCINOGEN BY
IARC OR ACGIH; LIVER ABNORMALITIES, LUNG DAMAGE (AMONG LAB ANIMALS).

FIRST AID MEASURES

First Aid:
INHAL: RMV TO FRESH AIR. IF NOT BRTHNG GIVE CPR; IF BRTHNG DIFF GIVE
OXYGEN. EYE: IMMED
FLUSH W/PLENTY OF WATER. SKIN: WASH W/SOAP & WATER. RMV CONTAM
CLTHG & SHOES.
INGEST: DO NOT INDUCE VOMIT. NOTHG BY MOUTH IF UNCONSC. GET MEDICAL
ATTN.

FIRE FIGHTING MEASURES

Fire Fighting Procedures:
SELF-CONTAINED BREATHING GEAR, W/FULL FACE SHIELD
Unusual Fire or Explosion Hazard:
EMITS CARBON MONOXIDE, CARBON DIOXIDE, HYDROGEN CHLORIDE, AND
PHOSGENE WHEN BURNED.
Extinguishing Media:
WATER FOG, CARBON DIOXIDE, DRY CHEMICAL

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388 Waste Management Practices: Municipal, Hazardous, and Industrial

Flash Point: Flash Point Text: NONE

Autoignition Temperature:
Autoignition Temperature Text: N/R
Lower Limit(s): 13
Upper Limit(s): 23.0

ACCIDENTAL RELEASE MEASURES

Spill Release Procedures:
ABSORB SPILL. STOP SPILL AT SOURCE. DIKE AREA. USE PROTECTIVE EQUIP.
WHEN IN AREA. FOR LARGE SPILLS PUMP LIQUID TO HOLDING TANK

EXPOSURE CONTROLS & PERSONAL PROTECTION

Repiratory Protection:
SELF-CONTAINED WITH FULL FACE SHIELD-OSHA/MESA APPROVED
Ventilation: MECHANICAL OR LOCAL AS NEEDED TO KEEP BELOW TLV
Protective Gloves: IMPERVIOUS
Eye Protection: CHEM SPLASH GOGGLES
Other Protective Equipment: IMPERVIOUS CLOTHING, EYE-WASH FACILITIES, BOOTS.
Work Hygienic Practices: AVOID CONTACT WITH EYES AND SKIN; DO NOT BREATHE
VAPORS/MIST; WASH
THOROUGHLY AFTER USE; DO NOT USE CONTAMINATED CLOTHES.

PHYSICAL & CHEMICAL PROPERTIES

Boiling Point: Boiling Point Text: 104F, 40C
Melting/Freezing Point: Melting/Freezing Text: N/A
Decomposition Point: Decomposition Text: N/A
Vapor Pressure: 355 MMHG Vapor Density: 2.9
Percent Volatile Organic Content:
Specific Gravity: 1.322
pH: N/P
Evaporation Weight and Reference: 1.8 (ETHYL ETHER=1)
Solubility in Water: SLIGHT
Appearance and Odor: CLEAR, COLORLESS LIQUID. ETHER-LIKE ODOR.
Percent Volatiles by Volume: 100

STABILITY & REACTIVITY DATA

Stability Indicator: YES
Materials to Avoid: ALUMINUM, STRONG ALKALAIS
Hazardous Decomposition Products: CARBON MONOXIDE, CARBON DIOXIDE, HYDRO-
GEN CHLORIDE, PHOSGENE
Hazardous Polymerization Indicator: NO

DISPOSAL CONSIDERATIONS
Waste Disposal Methods:

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Identification of Hazardous Waste 389

PLACE ABSORBED MATERIAL IN CONTAINERS SUITABLE FOR SHIPMENT TO DIS-

POSAL AREAS. ENVIRONMENTAL LAWS TAKE PRECEDENCE. LIQUID WASTES MAY
BE DESTROYED BY LIQUID INCINERATION WITH OFF GAS SCRUBBER

DEPARTMENT OF TRANSPORTATION INFORMATION

DOT Proper Shipping Name: DICHLOROMETHANE
Hazard Class: 6.1
UN ID Number: UN1593
DOT Packaging Group: III
Label: KEEP AWAY FROM FOOD
Non Bulk Packaging: 203
Bulk Packaging: 241
Maximimum Quanity in Passenger Area: 60 L
Maximimum Quanity in Cargo Area: 220 L
Stow in Vessel Requirements: A

© 2005 by Taylor & Francis Group, LLC