RCRA Hazardous Waste Management

Exercises

RCRA Hazardous Waste

Management

© Lion Technology Inc.21-0507

RCRA Hazardous Waste Management

CONTENTS

Hazardous Waste Identification ...........................................................................................1

On-site Management of Hazardous Waste

Satellite Rules and VSQG, SQG, and LQG Exemptions Exercise ..............................6

Universal Waste and Used Oil ......................................................................................11

Land Disposal Restrictions .................................................................................................14

CERCLA Reportable Quantity—40 CFR 302 ...................................................................20

Exercises


Page 1

HAZARDOUS WASTE IDENTIFICATIONExercise

Directions: Assume that each material in the “Material Specification” column has been determined to be a solid waste and is not excluded. Based on the information provided, determine if the material is a hazardous waste and, if so, indicate ALL the applicable waste codes in the middle column. Provide regulatory references for your responses.

NOTE:

• 1% = 10,000 ppm = 10,000 mg/kg ~ 10,000 mg/L

• For liquids, total concentration = TCLP

• For solids, determine the maximum possible TCLP by dividing the total concentration (in mg/kg) by 20

Material Specification Waste Codes References

1. Spent Solvent Cyclohexanone (used in cleaning operations)

Analysis Before Use:

– Cyclohexanone: ~ 100%

Analysis After Use:

– Liquid

– Flash point: ~ 120°F

– pH: N/A

– Stable


– Chromium: 24 mg/L

– Iron: 18 mg/L

– Lead: 2 mg/L


Hazardous Waste Identification, continued


Page 2


2. Unused Cyclohexanone

Analysis:


– Liquid


– pH: N/A

– Stable

3. Wastewater Treatment Sludge Containing Metals

Analysis:

– Liquid

– Not a fire hazard

– pH: N/A

– Stable

– Arsenic: 12 mg/L

– Cadmium: 3 mg/L

– Lead: 2 mg/L

– Nickel: 18 mg/L

Exercises



Page 3


4. Unused Formaldehyde Solution from a Histology Laboratory

Active Ingredient:

– Formaldehyde: 0.1%

Inactive Ingredients:

– Water: 48–53%

– Methanol: 10–15%

– Inert ingredients: ~ 37%

Analysis:

– Liquid


– pH: N/A

– Stable

5. Spent Toluene and Xylene Blend


– Toluene: 5%

– Xylene: 30%

– Non-hazardous ingredients: 65%

Analysis After Use:

– Liquid


– pH: N/A

– Stable




Page 4


6. Unused Turpentine

Analysis:

– Turpentine: ~ 100%

– Liquid


– pH: N/A

– Stable

7. Unused Solvent Blend

Active Ingredients:

– Benzene: 25%

– Ethyl benzene: 25%

– Nitrobenzene: 50%

Analysis:

– Liquid

– Flash point: < 40°F

– pH: N/A

– Stable

8. Unused Paint Remover

Active Ingredients:

– Methylene chloride: 80%

– Methanol: 20%

Analysis:

– Liquid


– pH: N/A

– Stable

Exercises



Page 5


9. Baghouse Dust (from Air Pollution Control Device) Containing Metals

Analysis:

– Solid


– pH: N/A

– Stable

– Barium: 400 mg/kg TOTAL

– Cadmium: 40 mg/kg TOTAL

– Lead: 80 mg/kg TOTAL

10. Spent Solvent from Dye Production


– Acetone: 25–35%

– Isopropanol: 25–35%

– Nitrobenzene: 5–8%

– Toluene: 5–8%

– Xylene: 30–40%

Analysis After Use:

– Liquid

– Flash point: < 140°F

– pH: N/A

– Stable

– Chromium: 4 mg/L

– Lead: 8 mg/L

– Nickel: 14 mg/L



Page 6

ON-SITE MANAGEMENT OF HAZARDOUS WASTESatellite Rules and VSQG, SQG, and LQG Exemptions

Exercise

Directions: Determine whether the following situations are being managed properly and answer the question being asked. The scenarios cover a variety of accumulation topics, including the very small quantity, small quantity, and large quantity generator exemption rules and the rules for satellite accu-mulation, episodic generation, and generator category determination.

1. Stephen Strange is determining his generator status by counting the following materials generated in the current calendar month: 800 kilograms of an F003 spent solvent, 20 kilograms of universal waste lamps, 200 kilograms of universal waste batteries, and 200 kilograms of used oil. What type of generator is his facility?

2. Wade Wilson works for a large manufacturing company that also has an R&D lab. He produces 5 kilograms of acute hazardous waste in the lab area and 600 kilograms of non-acute hazardous waste in the rest of the facility. He manages the lab waste under the large quantity generator exemption at 40 CFR 262.17, and the rest of the waste generated at the site under the small quantity generator exemption at 40 CFR 262.16. Is he in compliance with the rules?

3. Barry Allen wants to be able to get rid of his old 55-gallon hazardous waste containers. To get them empty, he pumps out all the waste he can, so that there is only approximately half of an inch of res-idue remaining. He ships the empty containers out for disposal on a bill of lading. Is this acceptable or does he need to use a hazardous waste manifest?

Exercises

On-site Management of Hazardous Waste, continued


Page 7

4. Diana Prince’s facility is a VSQG. She’s training Clark Kent to be her backup, so that she can take a vacation this year. Clark is frustrated with the waste ID process and doesn’t understand why he has to understand it since VSQGs have so few rules to follow anyway. Why is it important for VSQGs to perform waste identification?

5. Victor Stone knows that the satellite rules are less stringent than the small and large quantity gener-ator exemption rules. He leaves the bung open on his satellite drum because it gets filled periodically throughout the day. At the end of the day, he closes the drum. Is he in compliance?

6. Arthur Curry does not have a “No Smoking” sign by his containers of ignitable spent methanol solvent because his entire facility is non-smoking, and signs are posted on all entrances. Is this large quantity generator facility in compliance?

7. Carol Danvers is a hazardous waste manager at a pesticide company that produces non-acute hazardous waste at various locations around the site. Carol has all waste containers in excess of 55 gallons removed from the satellite accumulation area at the end of the workday on Friday afternoons. Is Carol’s site in compliance?




Page 8

8. Clint Barton and Natasha Romanova are EHS supervisors at two different sites under the same ownership. Natasha’s site is an SQG, and Clint’s is an LQG. Every year, they gather their employees together at headquarters to do their annual RCRA training. They keep a sign-in sheet and an agenda as their record of training for both sites. Is this good enough?

9. Peter Parker works at a site that’s a small quantity generator of hazardous waste. The site generates drums of ignitable waste isopropyl alcohol in satellite locations. When the drums are full, they are moved to the central accumulation area located at the back of the property along the fence line. Is this an acceptable location for the central accumulation area?

10. William “Billy” Batson is a small quantity generator in Great Falls, Montana. He holds his waste on site in a central accumulation area for 250 days, and then ships it to a TSDF in Midland, Texas for treatment and disposal. Billy has never bothered to notify the EPA or get a permit to hold his waste for more than 180 days. Is he in trouble?

11. Jean Grey has exceeded 55 gallons of waste in the satellite area, so she marks the date and lets the waste sit for three more days. On the third day, she moves the drum to Scott Summers’ central accu-mulation area, which is managed under the large quantity generator exemption. Jean marks the date she moves the drum into the central accumulation area as the beginning of the 90-day start period. Can she do this?

Exercises



Page 9

12. Wanda and Pietro Maximoff work at a large quantity generator site. Wanda is running out of 55-gallon drums in her central accumulation area and realizes that a lot of the drums in Pietro’s cen-tral accumulation area are only half-filled. She checks the spec sheets for each waste and learns that they are all compatible, so she decides to take her waste to Pietro’s area to consolidate the wastes to free up some drums. She marks the drum holding the consolidated waste with the date she moves the drum into Pietro’s central accumulation area. Is this okay?

13. Bucky Barnes is the manager of employee training at his site. To stay on top of things, Bucky has made it a policy to keep employee training records for three years, after which time he shreds them. Is this practice in compliance with the hazardous waste training requirements?

14. Bruce Wayne and Kate Kane work for a large corporation. Bruce is the hazardous waste manager at a very small quantity generator facility, and Kate is the manager at a small quantity generator site located approximately 100 miles away. Bruce wants to make his life a little easier by sending his site’s hazardous waste to Kate’s site. Is he allowed to do that under the hazardous waste rules?

15. Peter Quill works at a site that is typically a very small quantity generator of hazardous waste. Every July and December, however, they produce more hazardous waste than usual, causing the site to exceed the quantity limits for a VSQG. Peter isn’t worried, though, since he knows that VSQGs and SQGs are allowed up to two episodic events per year. Is he right not to worry?




Page 10

16. Which of the following containers and tanks are in compliance with the required markings?

The Satellite Accumulation Area

The Small Quantity Generator Central Accumulation Area

Start date:

01/15/21

Hazardous Waste

Ignitable

F003,

D001

Hazardous Waste

Ignitable

Spent Acetone

Start date:

01/15/2021

Hazardous Waste

Ignitable

Spent Acetone

01/15/2021

01/15/2021

F003 D001

Spent Acetone

01/15/2021

Hazardous Waste

Ignitable

Pending Analysis

Exercises


Page 11

ON-SITE MANAGEMENT OF UNIVERSAL WASTE AND USED OIL

Exercise

Directions: Determine whether the following situations are being managed properly and answer the question being asked. The scenarios cover a variety of on-site management topics pertaining to the universal waste and used oil rules.

1. Selina Kyle manages the universal waste at her facility. Rather than date the individual waste con-tainers, she uses an alpha-numeric code to identify each container, which can then be traced back to a computerized inventory log, in date order. Is this an allowable practice?

2. Harleen Frances Quinzel ships her universal waste off site twice a year following all applicable DOT rules and utilizing a bill of lading. Is she in compliance?

3. Helena Bertinelli is managing her dirty used oil under the less stringent rules found at 40 CFR 279, even though she knows that due to the process, there is a really good chance the used oil will have to go for disposal instead of recycling. Is she in compliance?

4. Eddie Brock analyzes his used oil that he generates from his process mechanism. At the point of generation, the used oil exhibits some toxicity characteristics for cadmium and chromium, but he still manages it under the used oil rules instead of the hazardous waste rules. Is he in compliance?


On-site Management of Universal Waste and Used Oil, continued


Page 12

5. Dr. Pamela Lillian Isley works in a lab that is a small quantity handler of universal waste. Her protocol is to send all spent lamps to her company’s main large quantity handler facility, from which the company will make one larger combined shipment to its recycler each year. Can she ship her universal waste to her main site?

6. Jason Todd’s boss insists that the universal waste rules require documented training for all univer-sal waste personnel. Jason is trying to convince him that, technically, no documentation is required, but that it’s still probably a good idea. Who is correct?

7. Floyd Lawton has some left-over unused oil and fuel oils that he doesn’t want, so he decides to empty the containers into the same drum as the used oil he’s collecting to send off for recycling. Is that allowed under the used oil rules?

8. Erik Lensherr manages the used oil storage area at his facility. Erik has been told to cut costs, so he decides that instead of paying someone to transport the used oil to the recycling facility, he’ll just have one of his employees load up two 55-gallon drums of used oil and take it to the recycler. Are they allowed to do this?

Exercises

On-site Management of Universal Waste and Used Oil, continued


Page 13

9. Take a look at the containers used to store universal waste and used oil. Which of the following are labeled properly? Circle your answer choices.

Universal Waste

Used Oil

Universal Waste Lamps

Waste Batteries

Universal Waste Fluorescent

Lamps

Used Mercury

Thermostats

UW Lamps

Waste Bulbs

1

65

32

4

321

Used OilWaste Oil

01/01/2020

Used Oil



Page 14

LAND DISPOSAL RESTRICTIONSExercise

Directions: For each waste listed below, determine the significant waste codes, subcategories, treat-ability group (wastewater or nonwastewater), treatment standards, underlying hazardous constitu-ents (UHCs), and constituents of concern (where applicable).

Significant Codes:

Listed only: All significantCharacteristic only: All significantBoth: Listed: All significant

Characteristic: Maybe; if the listed code is already treating for the constituent causing the characteristic code, then the characteristic code is not significant.

Resource: 40 CFR 268.40

Subcategory: Choose the subcategory that best describes the waste.

Treatability Group:

Wastewater = < 1% TOC AND < 1% TSS Nonwastewater = ≥ 1% TOC OR ≥ 1% TSS

Treatment Standards: Identify the treatment standard for each significant waste code.

UHCs:

1. Treatment standard must contain the phrase “and meet §268.48 standards” in the treatment standard for a D code.

2. There must be a reasonable expectation that there is something in the waste that hasn’t already been treated for.

Exercises

Land Disposal Restrictions, continued


Page 15

Example Material – Spent Cyanide Plating Bath Solutions from Electroplating Operations

Spent Cyanide Plating Bath Solutions from Electroplating Operations

Waste Profile:

Waste codes: F007, D005 (barium), and D006 (cadmium)

Total organic carbons: > 1%

Total suspended solids: > 1%

TCLP: antimony = 2 mg/L; barium = 215 mg/L; cadmium = 7 mg/L; thallium = 0.05 mg/L

Wastewater or Nonwastewater?

Nonwastewater – Both the TOC and TSS are greater than 1%.

Significant Waste Codes Subcategories Treatment Standards

F007 Only one description offered The waste needs to be treated to meet the standards for ALL seven constituents listed for a F007 waste in Column 3, to the levels identified for each constituent in the Non-wastewater column:

• Cadmium: 0.11 mg/L TCLP

• Chromium (Total): 0.60 mg/L TCLP

• Cyanides (Total): 590 mg/kg

• Cyanides (Amenable): 30 mg/kg

• Lead: 0.75 mg/L TCLP

• Nickel: 11 mg/L TCLP

• Silver: 0.14 mg/L TCLP

D005 Only one description, toxicity characteristic for barium

Treat barium down to at least 21 mg/L TCLP and meet §268.48 standards




Page 16

Spent Cyanide Plating Bath Solutions from Electroplating Operations

UHCs

Antimony must be treated as a UHC.

• The antimony in this waste is above the regulatory limit found at 40 CFR 268.48 and must be treated down to 1.15 mg/L TCLP.

Barium, cadmium, and thallium are NOT UHCs.

• The barium and cadmium are above the regulatory limits found at 40 CFR 268.48, but are treated for by the D005 and F007 waste codes, respectively.

• Thallium is not a UHC because it is below the regulatory limit of 0.20 mg/L TCLP found at 40 CFR 268.48.

Exercises



Page 17

Material 1 – Spent Solvent Blend Containing Metals

Spent Solvent Blend Containing Metals

Waste Profile:

Waste codes: F005, D001 (benzene, hexane, toluene), D011 (silver), D018 (benzene)

Total organic carbons (TOC): > 90%

Total suspended solids (TSS): > 1%

TCLP: iron = 30 mg/L; lead = 0.5 mg/L; nickel = 20 mg/L; silver = 6 mg/L






Page 18

Material 2 – Spent Acid Solution Used in Automotive Parts Degreasing

Spent Acid Solution Used in Automotive Parts Degreasing

Waste Profile:

Waste codes: D002 (phosphoric acid, hydrochloric acid), D006 (cadmium), D008 (lead)

Total organic carbons (TOC): < 1%

Total suspended solids (TSS): < 1%

TCLP: barium = 80 mg/L; cadmium = 2 mg/L; chromium = 3.5 mg/L; lead = 7 mg/L; nickel = 11 mg/L



Exercises



Page 19

Material 3 – Spent Solvent Blend

Spent Solvent Blend

Waste Profile:

Waste codes: K086, D007 (chromium), D008 (lead)

Total organic carbons (TOC): < 1%

Total suspended solids (TSS): > 10%

TCLP: chromium = 9.5 mg/L; copper = 10 mg/L; lead = 15 mg/L; nickel = 12 mg/L; silver = 2 mg/L





Page 20

CERCLA REPORTABLE QUANTITY—40 CFR 302Exercise

1. Calculate the reportable quantities (RQ) for the materials below. (Assume everything would be discarded if it were spilled, UNLESS OTHERWISE STATED.)

2. To complete this exercise, use the following tools:

– The List of Hazardous Substances and Reportable Quantities Table at 40 CFR 302.4

– The Clean Water Act mixture rule:

Material Reportable Quantity

1. Unused Formic Acid

– D001

– D002

– U123

2. Unused Turpentine

– D001

3. Unused Ethylene Oxide

– D001

– D003

– U115

4. Copper shavings (diameter of the pieces ~250 micrometers)

Will be recovered and used, so will not be waste

RQ (Mixture) = RQ (Constituent)

Wt. Fraction (Constituent)

Exercises

CERCLA Reportable Quantity—40 CFR 302, continued


Page 21

Material Reportable Quantity

5. Unused Solvent Solution

– D001

– 50% acetone

– 25% ethyl acetate

– 25% toluene

6. Process Residue With 10 mg/L TCLP for Silver

– D011

7. Unused Solvent Solution

– D001

– D018

– 25% benzene

– 50% toluene

– 25% unknown

8. Spent Acidic Solution

– D002

– 20–30% hydrobromic acid

– 10–25% sulfuric acid

– 45–60% water



Page 22

NOTES

Documents

RCRA Hazardous Waste Management