Hazardous Waste

Management

Contents
Hazardous Materials Regulations
Categories of Hazardous Waste
Technologies for Waste Minimization
Characterizing Hazardous Waste
Container Storage Requirements
Hazardous Waste Storage Requirement
Land Disposal Requirement
Waste Minimization

Hazardous Materials Regulations

Hazardous materials are regulated by three primary government
agencies:
Department of Transportation (DOT)
Title 49, Code of Federal Regulations (49 CFR)

Occupational Safety and Health Administration (OSHA)

Title 29, Code of Federal Regulations (29 CFR)

Environmental Protection Agency (EPA)

Title 40, Code of Federal Regulations (40 CFR)

Hazardous Materials Regulations (cont.)

DOT regulations direct us how to properly package, identify, and
label hazardous materials and hazardous wastes for
transportation.
OSHA regulations tell us how to protect ourselves from the effects
of hazardous materials in the workplace.
EPA regulations tell us how to protect our environment .

DOT Regulations
DOT classifies hazardous materials into 9 primary hazard classes which are
subdivided into multiple subsidiary risk groups. You dont need to memorize
these, but the primary hazard classes are:
Class
Class
Class
Class
Class
Class
Class
Class
Class

1:
2:
3:
4:
5:
6:
7:
8:
9:

Explosives
Compressed Gases
Flammable Liquids
Flammable Solids
Oxidizers
Poisons and Toxics
Radioactive materials
Corrosives
Miscellaneous hazardous materials that dont fit any other hazard class (i.e. dry ice)

OSHA Regulations
OSHA regulations include the following standards:
Hazard Communication Standard (Hazcom, Right-to-Know)
Occupational Exposure to Hazardous Chemicals in Labs, including requirements for
Chemical Hygiene Plans
Respiratory Protection Standard
Confined Space Entry Requirements
Asbestos Standard
Lead (Pb) Standard
Bloodborne Pathogen Standard
Formaldehyde, Benzene, and Methylene Chloride standards
OSHA also establishes Permissible Exposure Levels (PELs) for hazardous chemicals

EPA Regulations
Congress placed into law several acts that the EPA uses to establish
regulation to protect our environment:
Resource Conservation Recovery Act (RCRA)
Clean Air Act
Clean Water Act
Toxic Substances Control Act (TSCA)
Emergency Planning & Community Right-to-Know Act (EPCRA)
Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA)

Hazardous Waste Regulations

EPA regulates hazardous waste in Alaska by authority of the Resource
Conservation Recovery Act. RCRA controls include:
Identification of hazardous wastes
Tracking wastes from cradle to grave
Setting standards for generators of wastes, transporters of wastes,
and Treatment, Storage & Disposal Facilities

Primary RCRA Requirements

RCRA requires that you:
Label containers with a description of their contents
Store only the permissible volume of waste in your lab
Ensure lids and caps are securely fastened at all times, except when putting
wastes into the containers
Ensure all materials are properly segregated
Use containers that are compatible with your waste
Use intact containers (no cracks, holes, etc.)
Ensure that spills and overfills do not occur
Ensure that mismanagement does not occur

RCRA Requirement for Training

The purpose of this training is to comply with requirements set forth by
the EPA under 40 CFR 265.16 (Personnel Training)
The
1.
2.
3.
4.

scope of the training is to ensure that personnel who use chemicals:

Understand how to identify hazardous wastes
Understand how to package and label hazardous wastes
Understand how to have their hazardous materials disposed
Know how to respond effectively to emergencies

Generator
Anyone who creates waste:
Has responsibility to determine if waste is hazardous or
nonhazardous
Must take proper steps to handle waste

Transporter
The licensed party in charge of offsite removal of solid waste at
any time after generation

Hazardous Waste Generators

The RCRA definition of a HW generator is:
Any person, by site, whose act or process produces
hazardous waste identified or listed in 40 CFR 261.3.
Generators are classified by the volume of HW that they produce per month:
CESQG = Conditionally Exempt Small Quantity Generator
SQG
= Small Quantity Generator
LQG
= Large Quantity Generator > 1000 kg/month

Categories of Hazardous Waste

Hazardous waste determinations are based upon whether the
material is a:
Characteristic waste
Listed on the D-list or TCLP (Toxicity Characteristic Leaching Procedure)

Listed waste
Materials specifically identified on one of the following lists: F, K, U or P
lists

Universal waste
Batteries, lamps, pesticides, mercury from thermometers

Characteristic Wastes
D001 Ignitable Wastes (flashpoint is less than
140 F) includes oxidizers
D002 Corrosive Wastes (pH less than or equal to
2 or greater than or equal to 12.5)
D003
Reactive Wastes (water reactive,
normally unstable materials, cyanides &
sulfides, etc)
D004
TCLP Wastes

Characteristics Hazardous waste (D code)

Wastes that have not been listed by the EPA
Still have to be reviewed to determine if they exhibit certain characteristics
EPA chose four characteristics that could be measured by an available
standardized test method

Four trait of hazardous waste

Ignitability (D001)
Corrossivity (D002)
Reactivity (D003)
Toxicity (D004 D043)

Ignitability (D001)
Liquid with a flash point less than 140F
Not a liquid, but is capable of causing vigorous, persistent and hazardous fire
through friction, spontaneous chemical changes

Ignitability (D001)
Ignitable compressed gas
Oxidizer

Corrosivity (D002)
Aqueous pH range:
<2 (acidic) or > 12.5 (basic)

(pH 1 6=acid;

pH 7=neutral;

pH 8 14=base)
Liquid that corrodes steel greater than 6.35 mm (0.250 inches) per
year at 130F

Reactivity (D003)
Normally unstable; readily undergoes violent changes without
detonating
Reacts violently with water, forming potentially explosive mixtures
or generating toxic gases, vapors or fumes sufficient to present a
danger to human health or the environment

Reactivity (D003)
Cyanide or sulfide containing waste that, when exposed to pH
conditions between 2 12.5, can generate toxic gases, vapors or
fumes in quantities sufficient to present a danger to human health
or the environment

Reactivity (D003)
Capable of detonation or explosive reaction at standard
temperature-pressure (STP) if subjected to strong initiating source
or heated under confinement

Toxicity (D004-D043)
Wastes likely to leach dangerous concentrations of toxic chemicals
into the groundwater
40 CFR 261.24 Table 1
Toxic Characteristic Leaching Procedure (TCLP) Method 1311

Listed Wastes
F-listed wastes are from non-specific sources
Example: halogenated solvents used to degrease equipment

K-listed wastes are from specific sources

Example: petroleum refining or pesticide manufacturing

U-listed wastes are toxic wastes

P-listed wastes are acutely hazardous wastes

Examples of U-Listed Wastes

Acetaldehyde

1,4-Dioxane

Acetone

Ethyl acetate

Acetonitrile

Ethyl ether

Aniline

Formaldehyde

Benzene

Methyl alcohol

Bromoform

Methylene chloride

1-Butanol

Phenol

Chloroform

Toluene

Examples of P-Listed Wastes

Allyl alcohol

Osmium tetroxide

Ammonium vanadate

Phenylthiourea

Arsenic acid

Potassium cyanide

Arsenic trioxide

Sodium azide

Carbon disulfide

Sodium cyanide

2,4-Dinitrophenol

Thiosemicarbazide

Fluorine

Vanadium oxide

Nitric oxide

Vanadium pentoxide

Universal Wastes
Universal wastes include the following materials that are
commonly found in the workplace

Batteries
Fluorescent lamps
Pesticides
Thermometers (containing mercury)

Other Waste: Aerosol Cans

Aerosol cans are considered hazardous waste under
Characteristic Reactivity

the definition of

40 CFR Part 261.23: .capable of detonation or explosive reaction if it is subjected to a

strong initiating source or if heated under confinement.

Often contain hazardous materials, either as the product or as the propellant

Most aerosol cans, regardless of contents, can never be completely emptied of
propellant
Aerosol cans become a waste when

their contents are used up,

malfunction (i.e. fail to spray), or

when the contents are no longer needed

Other Wastes: Used Oil

Used oil means:
any oil that has been refined from crude oil, or any synthetic oil,
that has been used and as a result of such use, is contaminated
by physical or chemical impurities (40 CFR 279.1)
Used oil must be:
Collected in clean containers in good condition (no leakers)
Storage and transfer containers must be marked with the words Used Oil
Never add solvents, part washer fluids, carb cleaners, or glycol to your used
oil

Other Wastes: Used Oil (cont.)

Keep the used oil container closed (lid in place and secured) except when
adding or removing used oil
If you use a funnel for transfers, the funnel must be removed when not in
use and the container capped

Satellite Accumulation Areas

Each lab that generates waste is referred to as a Satellite
Accumulation Area (SAA)

Waste Storage Limits for SAAs

For SAAs, the waste storage limits are:
Up to 55 gallons of a hazardous waste
Up to 1 quart (1 liter) of a P-listed waste
50 gallons of waste at a SAA will likely be in violation of Fire & Building
Codes

Treatment
Method, technique or process, including neutralization
Designed to change physical, chemical or biological character or composition
of waste
Render it nonhazardous, safer for transport, suitable for recovery (storage, or
reduced in volume)
Includes activity or processing designed to change the physical or chemical
composition (render it neutral or nonhazardous)

Storage
Containment of a waste
Temporary basis
Presumption: containment of a waste in excess of one year
constitutes disposal

Disposal Defined
Incineration, deposition, injection, dumping, spilling, leaking or
placing of solid waste into or on the land or water that the solid
waste or a constituent enters the environment, is emitted into the
air or is discharged to the waters of the commonwealth

Characterizing Hazardous Waste

To determine if a waste is hazardous, subject a sample to:
Analytical testing
MSDS
Generator knowledge
Field testing

Container Storage Requirements

Kept closed except when adding or removing waste
Good condition
Containers have appropriate labels/markings:
Accumulation start date
Labeled clearly with the words HAZARDOUS WASTE
Contents

Hazardous Waste Label

Name:
Address:
City, State,
EPA ID No.:
EPA Waste No.: D003
Accumulation Start Date: accumulation starts in SAA (satellite
accumulation area) or at 90/180 day storage area)
Manifest Document/ Tracking Number: (provided by vendor)

HW Storage Area Requirements (90/180 day)

Inspect weekly for leaks and deterioration caused by corrosion or
other factors

Inspection date and time

Remedial action taken as necessary to correct problems noted
Document remedial action
Maintain inspection logs for three years

Hazardous Waste
Appropriate emergency and spill-control equipment is provided and
maintained
All drums must identify contents, a start accumulation date and
marked Hazardous Waste.

HW Storage Area Requirements

Container storage area must be maintained and
operated to minimize the possibility of fire,
explosion or any exposure to water.
All containers must be within containment.

Anything wrong with this picture?

No containment, stored on ground,
exposed to elements, drums on side
(are they empty?)

Hazardous Waste
Containers must be marked
Hazardous Waste
Cannot store more than 55
gallons of HW or one quart of
acutely HW in SAA
Move full containers to the
hazardous waste storage area
within three days

NO
Why not?
More than 55 gallons stored

Land Disposal Requirements (LDRs) 40 CFR Part

268
Land disposal: Examples- landfills, waste piles,
surface impoundments, injection well, land
treatment facility, salt dome formation, mine or
cave, concrete vault or bunker

Determine if your waste meets LDR treatment

standards for acceptance

Land Disposal Requirements

EPA prohibits land disposal of hazardous waste unless:
Wastes are treated to
specific treatment
standards or
It can be demonstrated
that waste cant release
any hazardous
components when
placed in a land disposal
unit

Land Disposal Requirements

Attach LDR forms to
manifest for each waste
stream the first time waste
is sent for disposal
Keep LDR forms in files for
three years
LDRs are not required for
CESQGs or for universal
waste

Contingency Plan
Preparation, prevention and contingency plan
- Required for LQGs
- Indicates requirements for responding to fires,
explosions or releases

Actions include:
- Emergency duty assignments
- Emergency response procedures
- Posting emergency information next to telephone

Contin

g e n cy
Plan

Waste Minimization
Concentrate on operations, processes, procedures
and production units that generate waste
Dont focus on off-site treatment and disposal
Source reduction
- Process/product modifications
- Chemical substitution

Recycling
- Returning material to the original process
- Solvent reclamation

Waste Minimization
Environmental benefits
- No dwindling landfill space
- No depletion of ozone layer
- Acid rain reduction
- Global warming reduction

Economic benefits
- Raw material cost savings
- Waste disposal
- Insurance costs

Questions