Waste Characterization Waste Characterization ““Tools of the TradeTools of the Trade””

Kate ShoreKate ShoreDavisDavis--MonthanMonthan AFBAFB

kathryn.shore@dm.af.milkathryn.shore@dm.af.mil(520) 228(520) 228--48404840

OR

DavisDavis--MonthanMonthan AFB AFB –– a small citya small cityDormitories & Private Residences Dormitories & Private Residences

Bowling Alley & Movie TheaterBowling Alley & Movie Theater

Golf Course & RV ParkGolf Course & RV Park

Gymnasiums & Swimming PoolsGymnasiums & Swimming Pools

Medical/Dental Clinic & PharmaciesMedical/Dental Clinic & Pharmacies

Gas Stations & Auto Repair CenterGas Stations & Auto Repair Center

Retail Stores & Restaurants Retail Stores & Restaurants

Banks & Post OfficeBanks & Post Office

Fire Department & HAZMAT Fire Department & HAZMAT Response TeamResponse Team

DavisDavis--Monthan AFB Monthan AFB –– a small citya small citymerous Aircraft maintenance & repair shopsmerous Aircraft maintenance & repair shops--10 10 ““Wart HogWart Hog”” jetsjets

--130 130 ““HerculesHercules”” propeller planespropeller planes

HHHH--60 60 ““Pave HawkPave Hawk”” helicoptershelicopters

order Patrol aircraftorder Patrol aircraft

ransient aircraft from other basesransient aircraft from other bases

MARC MARC –– ““the the BoneyardBoneyard””

DavisDavis--MonthanMonthan AFB AFB –– a small citya small cityWeapon SystemsWeapon Systems

Small Arms Firing RangeSmall Arms Firing Range

Aircraft Guns & MissilesAircraft Guns & Missiles

Motor VehiclesMotor Vehicles

Cars & TrucksCars & Trucks

Construction EquipmentConstruction Equipment

Facility MaintenanceFacility Maintenance

Pavements Pavements -- Roads, Parking, Roads, Parking, Flight Line, Runways Flight Line, Runways

Buildings Buildings -- Electricians, Plumbers, Electricians, Plumbers, PaintersPainters

Boilers, Chillers, Emergency Boilers, Chillers, Emergency Generators Generators

Wastewater Pretreatment PlantWastewater Pretreatment Plant

Aircraft Fuel Hydrant System & TanksAircraft Fuel Hydrant System & Tanks

Large Quantity GeneratorLarge Quantity Generator

DD--M generates 100,000 pounds HW annuallyM generates 100,000 pounds HW annually

Operates a <90Operates a <90--day Central Accumulation Point and 85 day Central Accumulation Point and 85 Satellite Accumulation AreasSatellite Accumulation Areas

Most shops would be SQG or CESQG if they were not part of the Most shops would be SQG or CESQG if they were not part of the basebase

Strict hazardous material authorization and purchasing Strict hazardous material authorization and purchasing controls to prevent waste from controls to prevent waste from ““happeninghappening”” through through expiration, poor buying decisions, etc.expiration, poor buying decisions, etc.

Comprehensive Hazardous Waste procedural, training, & Comprehensive Hazardous Waste procedural, training, & accountability programs to ensure wastes are properly accountability programs to ensure wastes are properly managed in each workplacemanaged in each workplace

!

8 5

008 ,

H A ZARDO USW ASTE

FED ER A L L A W PR OH IB ITS IM PR OPE R D ISPO SA L.IF FO U ND, CO NT ACT T HE NEA REST POL ICE, OR PUB LIC SAFET Y

AUTHO RITY , O R THE U .S . E NVIRO NM ENTAL PRO TECTI ON AG ENCY .

G ENERA TO R INF OR MAT IO N:

NA ME

AD DR ESS PH ON E

EPA MAN IFESTID NO . DO CUM EN T NO .

AC CUM UL AT ION EPASTA RT DA TE W A STE N O.

D .O.T. P RO PER S HIP PIN G NA M E A N D U N OR N A NO . WITH PR E FIX

HAN DLE W ITH CAR E !

CI TY S TA TE Z IP

DR M O - Tucs on70 30 E. Ir vin g to n (52 0) 2 28-8 08 5

T u c so n A Z 85 70 7

H az ar d o u s W as te S o li d N .O . S.

D 005, D 007, D 008 ,D 035

(m eth y l e th yl ke to n e, c h ro m iu m )9, PG I II, N A 3 07 7

A Z 4 57 00 24 055

HAZARDOUS WASTE SATELLITE

ACCUMULATION AREA

NO SMOKING

DM0021PAINT SANDING RESIDUE

AGE355 EMS/MXMG

In Case of Emergency Call Base Fire Protection

Dial 911

Satellite Accumulation Area Postings

Reduce or eliminate sampling and Reduce or eliminate sampling and chemical analysis in waste chemical analysis in waste

characterization to:characterization to:

Save MoneySave Money

Describe Wastes More AccuratelyDescribe Wastes More Accurately

Be in ComplianceBe in Compliance

How to use a “common-sense” approach and document Process Knowledge(pl f tri k f th tr d )!

easons easons NotNot to Sample and Analyzeto Sample and Analyzeave money $$$$ !

To have a lab analyze for To have a lab analyze for everythingeverything can can cost thousands of dollars per sample cost thousands of dollars per sample (and should never be necessary)(and should never be necessary)

EPA allows generators to apply knowledge EPA allows generators to apply knowledge of the hazardous characteristics in light of of the hazardous characteristics in light of the materials and processes usedthe materials and processes used

Waste paint analysis – Flashpoint, TCLP 8 metals + TCLP VOCs

easons easons NotNot to Sample and Analyzeto Sample and Analyze

Compliance and Accuracy

MSDSs can list ingredients not detected MSDSs can list ingredients not detected by by byby commonly used analytical suitescommonly used analytical suites

If you rely solely on analytical data you may not identify If you rely solely on analytical data you may not identify regulated Underlying Hazardous Constituents (regulated Underlying Hazardous Constituents (UHCsUHCs))

example: Nickel and Zinc are example: Nickel and Zinc are UHCsUHCs, but not included , but not included in a standard TCLP metal analysis in a standard TCLP metal analysis

Elevated laboratory detection limits can cause you to miss Elevated laboratory detection limits can cause you to miss important constituents if you rely solely on lab reportsimportant constituents if you rely solely on lab reports

There is no There is no ““standardstandard”” analytical method for some types of analytical method for some types of solvents Usolvents U- and Pand P-listed chemicalslisted chemicals

Types of Generator KnowledgeTypes of Generator Knowledge

Process generating the wasteProcess generating the waste (cleaning (cleaning parts, sanding paint, fluid change, etc.)parts, sanding paint, fluid change, etc.)

What the What the ““ingredientsingredients”” of the waste areof the waste are

Hazardous materials used (review Hazardous materials used (review MSDSs for paint, soap, etc.)MSDSs for paint, soap, etc.)

NonNon--hazardous waste components hazardous waste components (filters, brushes, water, PPE, etc.)(filters, brushes, water, PPE, etc.)

Potential contaminantsPotential contaminants from the from the process (lead from munitions, process (lead from munitions, cadmium from aircraft, residual fuel, cadmium from aircraft, residual fuel, chromium primer, etc.)chromium primer, etc.)

Begin Waste CharacterizationBegin Waste Characterizationwith 5 Questionswith 5 Questions

1)1) Is the waste a pure product that is Is the waste a pure product that is unusedunused??

2)2) Is the waste a Is the waste a mixturemixture of a pure product and a nonof a pure product and a non--hazardous material (i.e., water, oil, filter, rag, soil, etc.)?hazardous material (i.e., water, oil, filter, rag, soil, etc.)?

3)3) Is the waste a product that has potentially been Is the waste a product that has potentially been contaminatedcontaminated through use?through use?

4)4) Is the waste a Is the waste a complex mixturecomplex mixture (not a pure product or a (not a pure product or a contaminated product) but not an unknown?contaminated product) but not an unknown?

5)5) Is the waste an Is the waste an unknownunknown or something that is suspicious or something that is suspicious (i.e., an unmarked (i.e., an unmarked ““foundfound”” container or something that container or something that doesndoesn’’t look or smell right)?t look or smell right)?

1)1) Is the waste a pure productIs the waste a pure productthat is unused?that is unused?

Use the MSDS to characterize the wasteUse the MSDS to characterize the wasteIf there only one active ingredient check for U or P listingIf there only one active ingredient check for U or P listing

Pitfalls of using MSDSsPitfalls of using MSDSs

Need to ensure it is the correct MSDS for the manufacture or Need to ensure it is the correct MSDS for the manufacture or that equivalent products all share the same ingredientsthat equivalent products all share the same ingredients

Sometimes proprietary ingredients are not listedSometimes proprietary ingredients are not listed

Often ingredients present at <1% (10,000 ppm) not listedOften ingredients present at <1% (10,000 ppm) not listed

MSDSs comply with OSHA, not RCRA MSDSs comply with OSHA, not RCRA

Waste disposal guidance on most MSDS is usually vague, Waste disposal guidance on most MSDS is usually vague, and when they are specific and when they are specific -- sometimes sometimes wrongwrong! !

Need to read between the lines to extract informationNeed to read between the lines to extract information

2) Is the waste a mixture of a 2) Is the waste a mixture of a pure product and a nonpure product and a non--

hazardous material (i.e., water, hazardous material (i.e., water, oil, filter, rag, soil, etc.)?oil, filter, rag, soil, etc.)?

Use MSDS to characterize ingredientsUse MSDS to characterize ingredients along with along with supplemental analyses or process knowledge to supplemental analyses or process knowledge to determine if characteristics such as toxicity, determine if characteristics such as toxicity, flashpoint, or pH have changed as the result of the flashpoint, or pH have changed as the result of the mixturemixture..

Estimate % of ingredients in mixturesEstimate % of ingredients in mixtures based on based on information from the generator of the waste information from the generator of the waste

If product is used to clean or degreaseIf product is used to clean or degrease, ensure that , ensure that FF li t d d dlisted codes are sed

ExamplesExamples

Acid mixed with waterAcid mixed with waterTest for pHTest for pH (dilution may have raised pH)(dilution may have raised pH)

UNLESSUNLESS

If pH analysis costs $25, and disposal costs as a RCRA If pH analysis costs $25, and disposal costs as a RCRA waste will only be $10, then waste will only be $10, then DECLAREDECLARE the mixture as the mixture as RCRA corrosive RCRA corrosive without testingwithout testing

No penalties for making No penalties for making ““worst caseworst case”” assumptions assumptions about the waste if you are wrong!about the waste if you are wrong!

If it is a larger or recurring waste stream it may be costIf it is a larger or recurring waste stream it may be cost--effective to determine if the waste is noneffective to determine if the waste is non--RCRARCRA

Use common sense!Use common sense!

A

ExamplesExamplesoil contaminated with gasolineoil contaminated with gasoline

Test for TCLP benzeneTest for TCLP benzeneto determine if present at regulated levelsto determine if present at regulated levels

UNLESSUNLESS

Analytical costs will exceed disposal costs Analytical costs will exceed disposal costs –– if so, if so, DECLAREDECLARE the mixture as RCRA without testingthe mixture as RCRA without testing

No reasonNo reason to analyze for ethyl benzene, toluene, xyleneto analyze for ethyl benzene, toluene, xyleneQuantities present will not affect regulation of this waste. On Quantities present will not affect regulation of this waste. On the the profile simply ESTIMATE the amount of gasoline in the soil, e.g.profile simply ESTIMATE the amount of gasoline in the soil, e.g., , <10% gasoline and attach MSDS for gasoline<10% gasoline and attach MSDS for gasoline

If it is a larger or recurring waste stream it may be costIf it is a larger or recurring waste stream it may be cost--effective to determine the TCLP for benzene and see if the effective to determine the TCLP for benzene and see if the waste may be disposed for less money as nonwaste may be disposed for less money as non--RCRA.RCRA.

U !U !

ExamplesExamples

NonNon--toxic, flammable tissue preparationtoxic, flammable tissue preparationsolution mixed with water from hospital labsolution mixed with water from hospital lab

Use MSDS for ingredients and test for flashpointUse MSDS for ingredients and test for flashpoint

Estimate %Estimate % of solution and water based on information of solution and water based on information from the hospital technicians responsible for using the from the hospital technicians responsible for using the productproduct

If xylene or some other FIf xylene or some other F--listed solvent is present, ask listed solvent is present, ask the technician (or call the manufacture) to determine if the technician (or call the manufacture) to determine if the role of the xylene is as a solvent (i.e., to dissolve and the role of the xylene is as a solvent (i.e., to dissolve and rinse off excess stain) or some other purpose (to help the rinse off excess stain) or some other purpose (to help the stain penetrate) stain penetrate)

Do not automatically assume all FDo not automatically assume all F--listed ingredientslisted ingredientsare used as solvents and make the waste Fare used as solvents and make the waste F listed!listed!

3) Is the waste a product that has potentially 3) Is the waste a product that has potentially been contaminated through use? been contaminated through use?

e MSDS to Characterize main redients

e analysis or process wledge to determine if racteristics such as toxicity, hpoint, or pH have changed as result of the use.

e analysis or process wledge to identify suspected taminants (i.e., volatile anics, metals, etc.)

ExampleExample

Aqueous parts washer used to clean armamentAqueous parts washer used to clean armament

Use MSDS to determine ingredientsUse MSDS to determine ingredients in soapin soap

Ask workplace if product is diluted when placed in tank Ask workplace if product is diluted when placed in tank (1:10 ratio, 1:5, etc.) or used full strength(1:10 ratio, 1:5, etc.) or used full strength

Analyze TCLP for expected metalsAnalyze TCLP for expected metals (lead (lead -- perhaps perhaps cadmium, chromium, or barium too?)cadmium, chromium, or barium too?)

OrOr………….do .do NO analysesNO analyses and just and just declaredeclare the waste the waste RCRARCRA for lead if you have some past analysis from for lead if you have some past analysis from cleaning that type of armament that shows only lead cleaning that type of armament that shows only lead comes off that type of equipmentcomes off that type of equipment

Past analysis on the same or similar equipmentPast analysis on the same or similar equipmentcan constitute can constitute ““process knowledgeprocess knowledge””!!

Special Problems Characterizing Special Problems Characterizing Parts CleanersParts Cleaners

Waste parts cleaning solutions can vary in Waste parts cleaning solutions can vary in contaminant concentrationscontaminant concentrations (e.g., metals) (e.g., metals) depending upon:depending upon:

What types of parts are being cleanedWhat types of parts are being cleanedHow dirty the parts areHow dirty the parts areHow many parts are cleanedHow many parts are cleanedHow frequently the cleaning solution is changedHow frequently the cleaning solution is changed

These parameters are hard to predict and control. If any These parameters are hard to predict and control. If any RCRA toxic metals are detected, it may be best to RCRA toxic metals are detected, it may be best to ““worstworst--casecase”” parts washers for the toxic metals, rather than hope parts washers for the toxic metals, rather than hope

your samples are representativeyour samples are representative

ExampleExampletroleumtroleum--based solvent used to clean auto partsbased solvent used to clean auto parts

Use MSDS to determine ingredients and flashpointUse MSDS to determine ingredients and flashpoint

Check workplace inventoryCheck workplace inventory and ask to see if they have other and ask to see if they have other products which may be used in conjunction with the products which may be used in conjunction with the equipment equipment –– for instance an aerosol brake cleaner containing for instance an aerosol brake cleaner containing chlorinated solvent which may be used as a prechlorinated solvent which may be used as a pre--soak on soak on particularly dirty partsparticularly dirty parts

Ask about other productsAsk about other products which may contaminate the solvent which may contaminate the solvent tank tank –– gasoline, oil, diesel, etc.gasoline, oil, diesel, etc.

Ensure any FEnsure any F--listed solvents usedlisted solvents used are properly identifiedare properly identified

Analyze for expected toxic metalsAnalyze for expected toxic metals

If gasoline is present you should assume benzene toxicityIf gasoline is present you should assume benzene toxicity(>0.5 mg/L) because the laboratory detection limit will most (>0.5 mg/L) because the laboratory detection limit will most likely be too high to detect concentrations below 100 mg/Llikely be too high to detect concentrations below 100 mg/L

Consider Problems with Consider Problems with Laboratory Detection LimitsLaboratory Detection Limits

Wastes with high organic content, wastes that foam, or Wastes with high organic content, wastes that foam, or other samples may require the lab to dilute them prior to other samples may require the lab to dilute them prior to chemical analysis (1:10, 1:100, 1:1000, etc.)chemical analysis (1:10, 1:100, 1:1000, etc.)

The dilution factor (DF) raises the laboratory detection The dilution factor (DF) raises the laboratory detection limits by the same amountlimits by the same amount

Especially a problem when analyzing samples with low Especially a problem when analyzing samples with low TCLP limit (e.g., Lead 5 mg/L, Benzene 0.5 mg/L)TCLP limit (e.g., Lead 5 mg/L, Benzene 0.5 mg/L)

f the laboratory detection limits for your waste is going to bef the laboratory detection limits for your waste is going to begreater than the regulatory TCLP limit then you are better greater than the regulatory TCLP limit then you are better

off using off using ““process knowledgeprocess knowledge”” of what is likely to be in of what is likely to be in your waste than to spend the money on analytical chemistryyour waste than to spend the money on analytical chemistry

Wastewater from cleaning Wastewater from cleaning a Gasoline Tanka Gasoline Tank

Laboratory test results indicate:Laboratory test results indicate:““NonNon--detectabledetectable”” benzene with a laboratory detection limit of benzene with a laboratory detection limit of 5,000 mg/L.5,000 mg/L.Flashpoint was less than 140Flashpoint was less than 140ºº Fahrenheit (F)Fahrenheit (F)

Process Knowledge:Process Knowledge:Significant petroleum hydrocarbons must be present in the Significant petroleum hydrocarbons must be present in the wastewater for there to be such a low flashpointwastewater for there to be such a low flashpointGasoline typically contains 1Gasoline typically contains 1--3% benzene3% benzeneSample Sample couldcould exceed the TCLP level for benzene (0.5 mg/L) exceed the TCLP level for benzene (0.5 mg/L) Assume the Assume the D018D018 waste code is the most conservative callwaste code is the most conservative call

Lessons Learned:Lessons Learned:Always check detection limits on laboratory reports and note wheAlways check detection limits on laboratory reports and note where re they are not adequate for waste determination they are not adequate for waste determination Specify a detection limit and ask the laboratory to not run the Specify a detection limit and ask the laboratory to not run the sample sample if they canif they can’’t meet itt meet itIf you can smell gasoline in the wastewater maybe donIf you can smell gasoline in the wastewater maybe don’’t spend thet spend the

ExamplesExamples

Solvent cleaner on rags and patches used to clean Solvent cleaner on rags and patches used to clean weapons that may have been firedweapons that may have been fired

Use MSDS to identify solvent ingredients and determine Use MSDS to identify solvent ingredients and determine if Fif F--listed (>10% listed solvent in product)listed (>10% listed solvent in product)

No point in analyzing for VOCs to determine concentrationsNo point in analyzing for VOCs to determine concentrations

Make estimate, e.g., <5% solvent on ragsMake estimate, e.g., <5% solvent on rags

Test for TCLP leadTest for TCLP lead to determine if waste will be RCRA to determine if waste will be RCRA toxic toxic

Note: this is a variable waste stream; it may make sense to Note: this is a variable waste stream; it may make sense to worstworst--case it and case it and declaredeclare it RCRA toxic for leadit RCRA toxic for lead

ExamplesExamplesRifle and handgun cleaning bore patches and ragsRifle and handgun cleaning bore patches and rags at Security at Security Forces failed Forces failed TCLP for leadTCLP for lead (As, (As, BaBa, and Cd present but well , and Cd present but well below TCLP threshold, so below TCLP threshold, so UHCsUHCs only)only)

Combat Arms RangeCombat Arms Range

5/945/94 25 mg/L 25 mg/L –– it is okay to use a 12 year report!it is okay to use a 12 year report!

9/969/96 7.9 mg/L7.9 mg/L

10/0210/02 24 mg/L24 mg/L

10/0210/02 23 mg/L23 mg/L

ArmoryArmory

10/0210/02 1.7 mg/L 1.7 mg/L –– bad job if this was the bad job if this was the onlyonly sample!sample!

10/0210/02 41 mg/L41 mg/L

No additional sampling necessary until process changesNo additional sampling necessary until process changes(e.g., start using lead(e.g., start using lead--free ammunition)free ammunition)

4) Is the waste a complex mixture4) Is the waste a complex mixture(not a pure product or a contaminated (not a pure product or a contaminated

product) but product) but notnot an unknown?an unknown?

Determine if the waste is likely to be ignitable, corrosive, Determine if the waste is likely to be ignitable, corrosive, reactive, or contain volatile organics or toxic metals based on reactive, or contain volatile organics or toxic metals based on MSDSs and process knowledgeMSDSs and process knowledge

Test to confirm and/or quantify these Test to confirm and/or quantify these as necessaryas necessary

No testing for VOCs that are FNo testing for VOCs that are F--listedlisted

Only test to determine ignitibility, corrosivity, and toxicity Only test to determine ignitibility, corrosivity, and toxicity where there is doubtwhere there is doubt

Declare for worst case when it is in your best financial Declare for worst case when it is in your best financial interests to do so!interests to do so!

HAZARDOUSWASTE

FEDERAL LAW PROHIBITS IMPROP ER DISPO SAL.IF FOUND, CONTACT THE NEARES T POLICE, OR PUBLIC S AFETY

AUTHORITY, OR T HE U.S. ENVIRON MENT AL PROT EC TION A GENCY.

GENERATOR INFORMATION:NAM E

ADDRESS P HO NE

EPA M ANIFE STID NO. DOCUMENT NO.

ACCUM ULATION EP ASTART DATE WASTE NO.

D.O .T . PROPER SHIPPING NAME AND UN OR NA NO. WITH PREFIX

HANDLE W ITH CARE !

C IT Y STATE ZIP

DRMO - Tucson7030 E. Irvington (520) 228-8085

Tucson A Z 85707

Hazardous Waste Solid N .O.S.

D00 5, D007, D008,D03 5

(methyl eth yl ketone, chro mium)9, PG III, N A3077

AZ4570024055

ExamplesExamples

Mixed paint/solvent waste Mixed paint/solvent waste rom vehicle or aircraft paintingrom vehicle or aircraft painting

From MSDSs you can document the mixture will be ignitable and noFrom MSDSs you can document the mixture will be ignitable and not t corrosive or reactivecorrosive or reactive, so no need to test for these three characteristics , so no need to test for these three characteristics (e.g., FP <140)(e.g., FP <140)

Use MSDSs to determine toxicsUse MSDSs to determine toxics (MEK, Cd, Cr, etc.)(MEK, Cd, Cr, etc.)No need to analyze to find concentrations, just declare as worstNo need to analyze to find concentrations, just declare as worst--case case because you know the waste will be RCRA for ignitability anyway because you know the waste will be RCRA for ignitability anyway

Declare FDeclare F--listed for solventslisted for solvents used used to clean spray gun (MEK, etc.)to clean spray gun (MEK, etc.)

Get ingredients from MSDSGet ingredients from MSDS to to identfyidentfy UHCsUHCs (xylene, toluene, acetone, (xylene, toluene, acetone, etc.)etc.)

Make reasonable estimates for ingredientsMake reasonable estimates for ingredients (20(20--40% MEK, 1040% MEK, 10--20% 20% xylene, < 1% chromium, etc.) xylene, < 1% chromium, etc.)

Waste paint mixtures usually vary a lot Waste paint mixtures usually vary a lot –– you do not need to be precise you do not need to be precise on percentages of ingredients!on percentages of ingredients!

Mixed Waste IssuesMixed Waste Issues

Another reason to use Another reason to use MSDSsMSDSs instead of analyses instead of analyses to characterize paint mixturesto characterize paint mixtures

May use 95% paint with chromium and cadmium and May use 95% paint with chromium and cadmium and 5% paint containing lead5% paint containing lead

Analysis may only detect cadmium and chromium Analysis may only detect cadmium and chromium because lead is diluted below detection levels (or because lead is diluted below detection levels (or below RCRA level)below RCRA level)

RCRA requires waste be characterized at the point of RCRA requires waste be characterized at the point of generation, not after mixing with other wastes that generation, not after mixing with other wastes that may dilute contaminates below their regulatory levels may dilute contaminates below their regulatory levels

Chemical analyses without analysis of process would Chemical analyses without analysis of process would miss D008 waste code!miss D008 waste code!

ExamplesExamples

Abrasive Blast media used to remove paintAbrasive Blast media used to remove paint

““Common senseCommon sense”” tells you the blast media wontells you the blast media won’’t be t be ignitable, corrosive, or reactiveignitable, corrosive, or reactive

(Unless blast media is some kind of metal slag with uncertain (Unless blast media is some kind of metal slag with uncertain composition)composition)

If there is any uncertainty on the composition of paints If there is any uncertainty on the composition of paints and primers being stripped due to the variety of types and primers being stripped due to the variety of types and ages of equipment being stripped, and ages of equipment being stripped, DECLARE DECLARE media to be toxicmedia to be toxic for Pb, Cd, and Cr for Pb, Cd, and Cr –– do not testdo not test

If paints are wellIf paints are well--known and consistent, paint being known and consistent, paint being stripped can be identified by MSDS or even analyzing it stripped can be identified by MSDS or even analyzing it for RCRA metals one timefor RCRA metals one time

5) 5) Is the waste an unknown or Is the waste an unknown or something that is suspicious?something that is suspicious?

A drum that A drum that ““just showed upjust showed up”” that no one seems to know that no one seems to know anything aboutanything about

Waste from an uncontrolled areaWaste from an uncontrolled area with lots of access and a with lots of access and a possibility of anything being dumped into it?possibility of anything being dumped into it?

Sludge from an unattended base car wash could be one Sludge from an unattended base car wash could be one possibilitypossibility

Workplaces with known and controlled inventoriesWorkplaces with known and controlled inventories

should not produce should not produce ““unknownunknown”” wastes!wastes!

However, even standard waste streams should be However, even standard waste streams should be suspect when they donsuspect when they don’’t appear or smell as they usually t appear or smell as they usually do! do!

Unknown WastesUnknown WastesYou still have You still have some knowledgesome knowledge of what products are used at of what products are used at your facilityyour facility…………..

Unless the drum appears to be very old, you can reasonably Unless the drum appears to be very old, you can reasonably eliminate expensive testing for eliminate expensive testing for ingredients not in your ingredients not in your current inventorycurrent inventory so not likely to be in the wasteso not likely to be in the waste

PCBsPCBs

Banned PesticidesBanned Pesticides(chlordane, (chlordane, endrinendrin, DDT, etc.), DDT, etc.)

Unusual toxic semiUnusual toxic semi--volatiles such volatiles such as pentachlorophenol and pyridineas pentachlorophenol and pyridine(SVOC test costs ~ $450)(SVOC test costs ~ $450)

Unknown WastesUnknown WastesNo need to test No need to test nonnon--aqueous wastesaqueous wastes for pHfor pH

No need to test for flashpoint on wastes that are primarily No need to test for flashpoint on wastes that are primarily water or have no free liquidswater or have no free liquids

Very few wastes are sulfide or cyanide reactive, and there are Very few wastes are sulfide or cyanide reactive, and there are no RCRAno RCRA--approved analytical test methods to determine approved analytical test methods to determine these anyway (really!)these anyway (really!)

You would need a reason to declare an unknown waste as You would need a reason to declare an unknown waste as being Fbeing F--listed even if analysis detected Flisted even if analysis detected F--listed VOCslisted VOCs

Generally test only for TCLP 8 metals and toxic Generally test only for TCLP 8 metals and toxic VOCsVOCs along along with flashpoint and pH when applicablewith flashpoint and pH when applicable

Common sense still works on unknowns!Common sense still works on unknowns!

DonDon’’t fall into the costly trap of analyzing for everythingt fall into the costly trap of analyzing for everything””

Representative CharacterizationRepresentative CharacterizationAny time you have a waste producing process that is onAny time you have a waste producing process that is on--going, and will consist of more than one discreet container, going, and will consist of more than one discreet container, you need to determine how to ensure your characterization you need to determine how to ensure your characterization is is representativerepresentative of the wasteof the waste

SWSW--846 lists methods for collecting representative samples 846 lists methods for collecting representative samples from containers, but here we are asking you to consider from containers, but here we are asking you to consider how homogenous your waste stream really ishow homogenous your waste stream really is

Do you need to sample every container?Do you need to sample every container?

Every other container?Every other container?

Every third container?Every third container?

Annually?Annually?

Is there a Is there a formulaformula that will work for every situation? that will work for every situation?

Or should Or should common sense and process knowledge common sense and process knowledge be applied?be applied?

H AZ AR DO USW AST E

F ED E R A L LA W PR O H IB IT S IM P R OPE R D IS PO SA L.IF F O UN D, CO NT A CT T HE NEA REST PO L ICE , O R PUB L IC SAF E T Y

A U TH OR IT Y, OR TH E U. S . E N VI R ON ME N TA L P R OTE C TION A GEN C Y.

GEN ER ATOR I NFORMA TION:NA ME

AD DRE SS P HONE

EPA MANI FESTID NO . DO CU ME NT N O .

A CCU MULA TION EPASTA RT D ATE W ASTE NO.

D.O.T . P RO PE R S HI PP ING NAM E AND UN O R NA NO . W IT H P RE F IX

HA NDL E W IT H CARE !

CITY ST AT E Z IP

DRM O - Tuc s on7030 E . Irvin g to n ( 520) 228- 8085

T ucso n AZ 85707

H az ardo us W aste So lid N.O .S .

D 005 , D 007 , D 008 ,D 035

(m et hyl e th yl ket on e, ch rom ium )9, PG III, N A307 7

AZ 457002 4055

H AZ AR DO USW AST E

F ED E R A L LA W PR O H IB IT S IM P R OPE R D IS PO SA L.IF FOUN D, CONTA CT THE NEA REST POLICE , OR PUB LIC SAFE TY

A U TH OR IT Y, OR TH E U. S . E N VI R ON ME N TA L P R OTE C TION A GEN C Y.

GEN ER ATOR I NFORMA TION:NA ME

AD DRE SS P HONE

EPA MANI FESTID NO . DO CU ME NT N O .

A CCU MULA TION EPASTA RT D ATE W ASTE NO.

D.O.T . P RO PE R S HI PP ING NAM E AND UN O R NA NO . W IT H P RE F IX

HA NDL E W IT H CARE !

CITY ST AT E Z IP

DRM O - Tuc s on7030 E . Irvin g to n ( 520) 228- 8085

T ucso n AZ 85707

H az ardo us W aste So lid N.O .S .

D 005 , D 007 , D 008 ,D 035

(m et hyl e th yl ket on e, ch rom ium )9, PG III, N A307 7

AZ 457002 4055

H AZ AR DO USW AST E

F ED E R A L LA W PR O H IB IT S IM P R OPE R D IS PO SA L.IF FOUN D, CONTA CT THE NEA REST POLICE , OR PUB LIC SAFE TY

A U TH OR IT Y, OR TH E U. S . E N VI R ON ME N TA L P R OTE C TION A GEN C Y.

GEN ER ATOR I NFORMA TION:NA ME

AD DRE SS P HONE

EPA MANI FESTID NO . DO CU ME NT N O .

A CCU MULA TION EPASTA RT D ATE W ASTE NO.

D.O.T . P RO PE R S HI PP ING NAM E AND UN O R NA NO . W IT H P RE F IX

HA NDL E W IT H CARE !

CITY ST AT E Z IP

DRM O - Tuc s on7030 E . Irvin g to n ( 520) 228- 8085

T ucso n AZ 85707

H az ardo us W aste So lid N.O .S .

D 005 , D 007 , D 008 ,D 035

(m et hyl e th yl ket on e, ch rom ium )9, PG III, N A307 7

AZ 457002 4055

AFAF--PAM 32PAM 32--7043 says7043 says……Air Force regulations require that Air Force regulations require that ““All waste streams must All waste streams must be be ““evaluatedevaluated””** at the following frequencies:at the following frequencies:

When the process or operation generating the hazardous waste hasWhen the process or operation generating the hazardous waste haschangedchanged

AnnuallyAnnually following the initial characterization for each following the initial characterization for each highhigh--volumevolumewaste stream (4 or more 55 gallon drums/yr)waste stream (4 or more 55 gallon drums/yr)

At least every 3 years for low volumeAt least every 3 years for low volume waste stream (3 or fewer 55 waste stream (3 or fewer 55 gallon drums/yr) gallon drums/yr) ””

Individual EPA/State/County regulators may have similar Individual EPA/State/County regulators may have similar ideas on frequency of waste determinationideas on frequency of waste determination

Does Does ““evaluatedevaluated”” have to mean chemical analysis? have to mean chemical analysis? It is often interpreted that way, but..It is often interpreted that way, but..……....

A Case HistoryA Case HistoryWastestream: Wastestream: plastic media used for paint strippingplastic media used for paint stripping at EMS at EMS Structural Maintenance over a 1 year period (Structural Maintenance over a 1 year period (everyevery drum drum sampled & analyzed TCLP for 8 metals):ampled & analyzed TCLP for 8 metals):

RCRA ToxicsRCRA Toxics Lead (5 mg/L)Lead (5 mg/L) Cadmium (1)Cadmium (1) Chromium (5)Chromium (5)1 Cd, CrCd, Cr 1.01.0 84.084.0 29.529.522 CrCr 0.50.5 0.750.75 14.214.233 CrCr 0.70.7 0.160.16 5.25.244 nonnon--RCRARCRA 1.21.2 0.160.16 4.84.855 Cd, CrCd, Cr <0.5<0.5 3.813.81 17.817.866 Pb, Cd, CrPb, Cd, Cr 7.47.4 2.302.30 5.85.877 CrCr 0.80.8 0.490.49 7.07.088 Cd, CrCd, Cr 1.31.3 1.651.65 10.410.499 Cd, CrCd, Cr 1.11.1 2.072.07 24.724.7100 Cd, CrCd, Cr <0.5<0.5 3.643.64 13.313.3111 Cd, CrCd, Cr <0.5<0.5 3.163.16 20.320.3

What should the waste profile say? What should the waste profile say? Should you keep analyzing this waste?Should you keep analyzing this waste?

Waste Evaluation Includes:Waste Evaluation Includes:

Reviewing the Reviewing the processesprocesses occurring in the workplaceoccurring in the workplace

Has the equipment changed?Has the equipment changed?Have the procedures that generate the waste changed?Have the procedures that generate the waste changed?

Reviewing Reviewing hazardous materialshazardous materials used which contribute to the used which contribute to the waste generating processwaste generating process

DD--M AFB does this on an onM AFB does this on an on--going basisgoing basis through our hazardous through our hazardous material authorization process (not just every 1material authorization process (not just every 1--3 years)3 years)

Sampling and Sampling and chemical analysis (if necessary)chemical analysis (if necessary)Can use Can use pastpast analytical data as analytical data as ““process knowledgeprocess knowledge”” of current waste of current waste compositioncompositionCan use analytical data from other facilities where identical prCan use analytical data from other facilities where identical processes ocesses and hazardous materials are usedand hazardous materials are used

When to When to ““Worst CaseWorst Case””(declare your waste as RCRA (declare your waste as RCRA

without analyzing it)without analyzing it)When you have a good idea of the what the constituents are or coWhen you have a good idea of the what the constituents are or could beuld be(but uncertainty on concentrations)(but uncertainty on concentrations)

When analysis costs more than disposalWhen analysis costs more than disposalVery small waste streamsVery small waste streamsUnique occurrence (contaminated soil)Unique occurrence (contaminated soil)Waste stream is hard to predict or known to be variable (sandinWaste stream is hard to predict or known to be variable (sanding or g or blasting residue)blasting residue)

When it must be disposed as RCRA regardless of test resultsWhen it must be disposed as RCRA regardless of test resultsIf waste paint is RCRA due to flashpoint, may as well assume If waste paint is RCRA due to flashpoint, may as well assume presence of typical toxic paint constituents (MEK, Cd, Cr, Pb, epresence of typical toxic paint constituents (MEK, Cd, Cr, Pb, etc.)tc.)

When itWhen it’’s such a variable waste stream that its such a variable waste stream that it’’s nearly impossible to get s nearly impossible to get a representative samplea representative sample

Rags, gloves, masking materials, brushes, and other debris Rags, gloves, masking materials, brushes, and other debris contaminated with paint and solventcontaminated with paint and solvent

When to Sample and AnalyzeWhen to Sample and AnalyzeWhen you know very little about the waste generating processWhen you know very little about the waste generating processWhen you are uncertain about what hazardous materials are When you are uncertain about what hazardous materials are being used in the workplacebeing used in the workplaceWhen there is poor control over containers and you donWhen there is poor control over containers and you don’’t know t know what is really in themwhat is really in them

Note: All of the above indicate a Note: All of the above indicate a poorly managed hazardous waste program!poorly managed hazardous waste program!

To quantify whether levels of contaminants are RCRA or notTo quantify whether levels of contaminants are RCRA or notIt is a large waste stream, and is costIt is a large waste stream, and is cost--effective spend the effective spend the money to determine it is nonmoney to determine it is non--RCRARCRA

Statistical methods can be used to show a waste stream is Statistical methods can be used to show a waste stream is nonnon--RCRA, even if it occasionally fails the TCLP RCRA, even if it occasionally fails the TCLP

Summary: To reduce costs Summary: To reduce costs andand improve compliance:improve compliance:

Use MSDSsUse MSDSsUnderstand limitations of MSDS informationUnderstand limitations of MSDS information

““Worst CaseWorst Case”” small waste streams (small waste streams (declaredeclare them RCRA)them RCRA)Think about analytical costs vs. disposal costsThink about analytical costs vs. disposal costs

Do not analyze for FDo not analyze for F--listed wasteslisted wastesIngredients & process, not concentration is importantIngredients & process, not concentration is important

Understand limitations of analytical reportsUnderstand limitations of analytical reportsWhat What ““Not DetectedNot Detected”” really meansreally meansChoose Choose analytesanalytes based on common sense based on common sense –– dondon’’t need to test t need to test for everything, every time!for everything, every time!

Perform less chemical analyses and substitute Perform less chemical analyses and substitute process knowledge whenever you can! process knowledge whenever you can!

Waste Characterization Waste Characterization ““Tools of the TradeTools of the Trade””

Kate ShoreKate ShoreDavisDavis--MonthanMonthan AFBAFB

kathryn.shore@dm.af.milkathryn.shore@dm.af.mil(520) 228(520) 228--48404840

OR