Hazmat 2021
SIXTY ONE DELTA ONE
Hazardous Waste: The Part of Hazmat Response We Usually Do Not Talk About
In the arena of hazardous materials response, there is one topic that we usually mention in either hushed tones Glenn Clapp or not even at CHMM, CFPS all —hazardous waste. While hazardous waste does not generally have the allure of, nor receive as much attention as other hazardous materials in our world of response, we need to be familiar with the specifics of hazardous waste storage, management, and transportation as we are apt to encounter such materials at fixed facilities, in transportation, or at treatment storage and disposal facilities (TSDFs). The overarching regulatory influence in terms of hazardous wastes is the Resource Conservation and Recovery Act (RCRA). RCRA covers the “cradle to the grave” management of solid wastes and hazardous wastes; and was promulgated in 1976. Whereas in hazardous materials response we are usually focused on the Department of Transportation (DOT) definition
28 Summer • 2021
of hazardous materials — “materials capable of posing an unreasonable risk to health, safety, and property when transported in commerce” — in the hazardous waste discipline we need to look at the definitions of solid and hazardous wastes. A solid waste is defined as “any garbage or refuse, sludge from a wastewater treatment plant, water supply treatment plant, or air pollution control facility and other discarded material, resulting from industrial, commercial, mining and agricultural operations and from community activities.” A solid waste is also considered to be “any material that is discarded by being abandoned, inherently waste-like, discarded military munitions, or recycled in certain ways” — with some exclusions. It is ironic that solid wastes also do not have to be in solid form, as they can also be in liquid, semi-solid or contained gaseous material states. Hazardous wastes are defined as “RCRA solid wastes that are characteristic wastes (ignitable, corrosive, reactive, or toxic) or listed hazardous wastes on what are termed the F, K, P or U lists.” There are specific types of
characteristic and listed wastes as defined in the Hazardous Waste Regulations promulgated by the Environmental Protection Agency (EPA) in 40 CFR 260 - 279. Hazardous wastes exhibiting the characteristic of ignitability are assigned the hazardous waste code D001 and consist of liquids with a flashpoint of less than 1400F, non-liquids capable at standard temperature and pressure of causing fire, ignitable compressed gases and oxidizers. An example of a D001 waste would be gasoline. Corrosive hazardous wastes are termed D002 wastes and are defined as having an aqueous pH of 2 or less or 12.5 and above; and liquids that corrode SAE 1020 steel at the rate of greater than one quarter inch per year at 1300F. Sulfuric acid is a representative D002 waste. D003 hazardous wastes exhibit the characteristic of reactivity and are defined as those wastes which are normally unstable and readily undergo violent change without detonating; those that form potentially explosive mixtures with water, and those generating toxic vapors or fumes when mixed with water, among others. Wastes such as organic peroxides exemplify the D003
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characterization. The final characteristic hazardous waste category is that of toxicity. Such wastes are given the hazardous waste codes of D004 through D043 and are defined as those wastes with constituents produced by extraction through the toxicity characteristic leaching procedure (TCLP) meeting or exceeding concentrations specified in 40 CFR 261.24. An example of such a waste is one which produces arsenic under extraction at concentrations equal to or greater than 5.0 mg/L (designated D004). Just to muddy the waters the EPA also assigns hazard codes (which are different than the DXXX hazardous waste codes previously mentioned) to both characteristic and listed wastes, as follows: I - Ignitable Waste C - Corrosive Waste R - Reactive Waste E - Toxic Waste (Based on the TCLP) H - Acute Hazardous Waste T - Toxic Waste (Based on the Presence of Toxic or Hazardous Constituents) Following the coverage above of the characteristic wastes, let us discuss the listed wastes.
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