Transcript
Page 1: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Resource Conservation and Recovery Act

“RCRA”November 18, 1980

Page 2: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Public Acts

• 1976 Resource Conservation & Recovery Act – Required permits for hazardous waste facilities that disposed or burned waste– Prohibited opened dumping without permit– Authorize funding to study waste issues – Not an enforcement program

• 1980 Resource Conservation & Recovery Act– Current Hazardous Waste laws– Includes enforcement

Page 3: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

“Title 40 of the Code of Federal Regulations, Parts 260-280

(40 CFR 260-280)• Part 260 & 261

– Defines solid and hazardous waste– Conditionally exempt SQG requirements

• Part 262– LQG and SQG quantity generator

requirements

• Part 263

– Transporter requirements

• Part 264, 265, 270– Permit requirements (TSDF)– Some LQG and SQG requirements

• Part 266– Recyclable materials requirements

• Used in a manner constituting disposal• Precious metals• Lead-acid battery reclamation• Industrial boilers and furnaces• Military munitions

• Part 268– land disposal restrictions

• Part 271 and 271– state authorization– list of authorized states (CT is subpart H)

• Part 273– universal waste rule

• Part 279– used oil rule

• Part 280– underground storage tanks

Page 4: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

The Regulations

Cradle to Grave

Preventative law

Page 5: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Love Canal, Niagara NY– 15 acres with 60ft by 3000ft canal along Niagara River– 1920, purchased by Hooker Chemical– 1920 – 1953, used as a landfill by city and manufacturers.– 1953, sold to the city’s board of education ($1.00)

• Deed stated not to dig within the area of the canal– 1954, Board of Ed. built schools and housing (1000)

• Disregarded warning on deed• Chemicals seeped into basements and storm drains• Drums popping up in ball fields and yards• Residents started complaining

– 1978, years of residents complaints forced evacuation of several city blocks

– 2010, a few city blocks still restricted

Page 6: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Times Beach, MI

Russell Bliss, waste oil company1960s - 1970s collected waste from area businessesClaimed that only waste oil was collectedLater determined other toxic waste mixed with oil Oil used for dust control on roads and stables

• 1971 – 1972, Sixty two horse die at area stables. • 1972 – 1976, Times Beach hires Russell Bliss to oil roads• 1977, EPA begins investigation into horse deaths

Some waste came from NE Pharmaceutical and Chemical Corp2,4,5T and 2,4D (agent orange)Contains dioxinPCBs also found

• 1983, EPA purchases the town and evacuates residents constructed an on-site incinerator & incinerate 26,000 tons of contaminated soil

Current – Town park (still polluted)

Page 7: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Valley of the Drums, Brooks KY13 acre gravel pit owned by A. L. Taylor1967 – 1977, took in over 38,000 drums of waste from area paint and coating manufacturers

11,000 drums buried and/or burned27,000 drums stored on the ground

1979, EPA begins cleanupCleanup continues to this day

Page 8: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

The Law

Penalties

• Civil (violation of the regulations)• $25,00.00/day/violation

– “waste determinations” – most common violation

• Criminal (knowing your violating)• Penalties ($50,000.00/day/violation)• Prison – 5 years in CT

Page 9: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Civil Penalties

• Home Depot (9 stores)• $425,000.00 & company wide compliance program in CT• Over 40,000 pounds 2,4-D

• Light Sources, Milford & Orange• $857,000.00 & clean up mercury releases• Polluted both properties with mercury

Page 10: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Criminal Penalties

• Sound Mfg, Norwich (Taftville)• 3 years, $100,000 fine & $1,000,000 cash bond for clean up• Buried 50,000 pounds lead paint sandblasting waste

• Phoenix Products, Plymouth• 3 years probation• $250,000 • 1500-gallons waste acid to sewer

Page 11: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Who is Regulated• Any business that –

– Generates hazardous waste, used oil, universal waste– Transports hazardous waste, used oil, universal waste– Stores, treats, disposes of hazardous waste, used oil, universal waste

• Must apply for an EPA Id. No.– Address specific (not by business name)– Denotes expected generator category

Home owners (and tenants) and home owner derived waste is excluded

Page 12: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Who are the HW Generators• Retail establishments

pharmacies photo shops hardware stores garden centers big & small box retailers

• Public service sectorhospitals & clinics prisons schools state parks town garage power plants gun clubs

navy coast guard air national guard army national guard atomic energy lab

• Service sectorauto body ship/boat repair electroplating lead abatement bridge painting

vehicle repair furniture repair auto recyclers printers machine shop/metal forming

dry cleaners scrap metal exterminators tank truck washing waste recyclers

• Manufacturingship & boat aircraft ball bearings lighters fluorescent lamps hardware tools

guns paint & coatings chemicals lamp posts circuit boards electronic equipment

laminated fabrics /paper bakeries extruded aluminum structures foundry glass products

asphalt shoe inserts wire guitars racing engines surgical thread space suits

batteries cabinets filter elements furniture glides cosmetic containers explosives

ant traps pharmaceuticals galvanized guard rails metal boxes buckles Styrofoam

Page 13: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Generator Categories• Treatment, storage, disposal facilities (TSDF)

• Can also be LQG, SQG, CESQG

• Large quantity generator (LQG)• Greater than 1000 kilograms (or greater than 1 kilogram acute waste) per month

• Small quantity generators (SQG)• 100 to 1000 kilograms (or 1 kilogram acute waste) per month

• Conditionally exempt small quantity generators (CESQG)• Less than 100 kilograms (or less than 1 kilogram acute waste) per month

LQG, SQG, CESQG is based on a month to month determination. Can be CESQG one month and LQG the next depending on amount of waste generated and/or stored on-site during

each respective month

Page 14: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Generator Categories

• Waste transporters

• Permit exempt reclamation/recycling• Lead-acid batteries, precious metals, industrial boilers, recyclers (no storage, burning, disposal)

• Used oil handlers, burners, blenders

• Universal waste handlers

Page 15: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Treatment Storage Disposal Facilities (TSDF)

– RCRA Part B Permit• EPA Id. No. (example CTD116502534)• Type and volume of waste on-site• Storage, treatment, and handling methods• Waste tracking and analysis• Secondary containment systems• Emission controls (VOCs)• Employee training• Job descriptions• Weekly/daily inspections and logs• Emergency response plan• Shipping records• Annual reporting• Closure plan and cost estimate• Financial assurance and insurance• Groundwater monitoring (land disposal units)• Site wide corrective action

Page 16: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Large Quantity Generator (LQG)

• Greater than 1000 kilograms/month or at any one time (5 drums)• Greater than 1 kilogram acute HW (1 quart)• 90-day storage limit

• Exceed 90-days – considered TSDF without permit• Substantial management requirements

– EPA Id. No. (example CTD000502534)– Determining if waste is HW– Secondary containment/impervious base– Weekly/daily inspections and logs– Employee training– Job descriptions– Emergency response plan– Emission controls (VOCs)– Shipping records– Biennial reporting

Page 17: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Small Quantity Generator (SQG)

• 100 to 1000 kilograms/month• Never exceed 1000 kilograms at any one time• Never exceed l kilogram acute HW• 180-day storage limit (270 days if over 200 miles)• Exceed any above – considered TSDF without permit

• Less substantial management requirements– EPA Id. No. (example CTD000502534)– Determine if waste is HW– HW manifests– Weekly/daily inspections and logs– Secondary containment/impervious base– No open top tanks– Employee training (no records required)– Posting emergency information near phone

Page 18: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Conditionally Exempt Small Quantity Generator (CESQG)

• Less than 100 kilograms/month• Less than 1 kilogram acute HW • Never exceed 1000 kilograms (or 1 kilogram acute waste) at any one time• Exceed 1000 kilograms (or 1 kilogram of acute waste) – considered LQG • Even less substantial management requirements

– Determine if waste is HW– Don’t dispose of HW in CT solid waste facilities (LF, CRRA, etc)– Can use household hazardous waste collection

Page 20: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Generators in CT

• LQG 300• SQG 1700• CESQG unknown (don’t have to get EPA Id. No.)

Other “state” permitted facilities• Treating contaminated soil (on & off-site)• Blend used oil fuel• Recover precious metals from HW• Lead-acid battery recycling• Used electronics recycling• Fluorescent lamp recycling • Bio diesel (from waste vegetable/animal oil)

Page 21: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Questions/Comments

Page 23: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

****Scrap metal

***Commercial chemical products (listed in 262.33)

***By-products (exhibiting a characteristic of hazardous waste)

****By-products (listed in 262.31 or 32)

***Sludge (exhibiting a characteristic of hazardous waste)

****Sludge (listed in 262.31 or 32)

****Spent material

Speculative accumulation

ReclaimedEnergy recovery (fuel)

Use constituting disposal

Page 24: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Couple of exclusions to the definition of solid waste

• Waste fuel reused as a fuel– Water/gas mixtures sent for fuel blending

• Waste is effective substitute for a commercial chemical product, provided the product is not used in a manner constituting disposal or burned.

– Spent plastic bead blast media (paint removal)– Used in water resistant concrete block (Sealtech block)

– Applied above ground – not solid waste– Applied on the ground – is solid waste

– Fly ash used to make zinc powder (Exeter Energy) – Used in galvanizing – not solid waste (US Zinc)– Used in plant food – is solid waste (Bay Zinc)

Page 25: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

The Hazardous Wastes

A solid waste that is:

LISTED AS HAZARDOUS WASTE(Part 261.31 – 33)

and/or

EXHIBITS A CHARACTERISTICOF HAZARDOUS WASTE

(Part 261.21 – 24)

Page 26: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

And 2 sub-categories…………

“Used Oil”(part 279)

and

“Universal Waste”(part 273)

Page 27: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Couple of exclusions from the definition of hazardous waste

“lobbyist exclusions”

• Drilling fluids from oil and gas production•heavy metals, volatile organic compounds, corrosives•Cabot Oil, 2009, water supply well explode, 14 water supplies polluted

• Fly & bottom ash from burning coal or fossil fuel•heavy metals and volatile organic compounds

•TVA Kingston Plant, 2008, 1,000,000-gallon coal ash slurry release

• Waste from extraction/processing of ore•heavy metals and volatile organic compounds

•Asarco mine & ore sites (11 mid west) waste piles with heavy metals & radioactive materials

Page 28: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Waste Codes

Hazardous wastes are identified by “waste codes”

(except for used oil and universal waste)

The listed waste codes

F, K, U, P(Example – F006 metal hydroxide sludge from electroplating)

The characteristic waste codes

D waste codes(Example – D001 ignitable)

Page 29: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Reason for Waste Codes

National statistical informationObserve trends in waste generation

Pollution prevention programsEliminate/reduce large volume waste types

Hazard recognitionWaste codes represent specific hazards

Page 30: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

“LISTED HAZARDOUS WASTE”

THREE TYPES:

• NON-SPECIFIC SOURCE “F” waste codes (40 CFR 261.31)

• SPECIFIC SOURCE “K” waste codes (40 CFR 261.32)

• COMMERCIAL CHEMICAL PRODUCTS U & P waste codes

(40 CFR 261.33)

Page 31: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

SOME FACTS ABOUT LISTED HAZARDOUS WASTE

Reasons for Listing

Ignitable (I)

Corrosive (C)

Reactive (R)

Acutely Hazardous (H)

Toxic (T)

Page 32: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

SOME FACTS ABOUT LISTED HAZARDOUS WASTE

Mixture Rule

– mixing a listed waste with any other solid waste makes the entire mixture a listed waste!

– not dependent on amount (one drop, one gallon, etc). – not dependent on the source (intentional mixing, accidental

mixing).– Can cause an otherwise inexpensive waste to become more

expensive when shipped off-site

Page 33: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Listed Hazardous Waste “Non-Specific Source”

“F” Waste Codes(261.31)

Waste from generic sources:

F001 – F039

• Solvents (F001 – F005)

• Metal finishing (F006 – F019)

• Pesticides/wood preservative [dioxin] (F020 - F035)

Page 34: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Common “F” Waste in CT

• F001 (T)

• F002 (T)

• The following spent halogenated solvents used in degreasing: tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1 trichloroethane, carbon tetrachloride, chlorinated fluorocarbons, still bottoms from solvent recovery

• The following spent halogenated solvents: tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1 trichloroethane, carbon tetrachloride, chlorinated fluorocarbons, still bottoms from solvent recovery

Page 35: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

HALOGENS

Chemical with the word chloro or fluoro in its name

Perchloroethylene (1.6)

Trichloroethylene (1.46)

methylene chloride (1.33)

“HEAVIER THAN WATER”

IMPROPER TREATMENT = DIOXINS

Page 36: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Common “F” Waste in CT

• F003 (I)

• F005 (I,T)

The following spent non-halogenated solvents: xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether, methyl isobutyl ketone, butyl alcohol, cyclohexanone, methanol, still bottoms from solvent recovery.

The following spent non-halogenated solvents: toluene, methyl ethyl ketone, carbon disulfide, isobutanol, pyridine, benzene, 2-ethoxyethanol, 2-nitropropane ; still bottoms from recovery of spent solvents

Page 37: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Common “F” Waste in CT

• F006 (T)

• F019 (T)

Wastewater treatment sludge from electroplating operations except from the following processes: (1) sulfuric acid anodizing of aluminum; (2) tin plating on carbon steel; (3) zinc plating on carbon steel; (4) aluminum or zinc-aluminum plating on carbon steel; (5) cleaning/stripping associated with tin, zinc, aluminum plating on carbon steel; (6) chemical etching of aluminum.

Wastewater treatment sludge from chemical conversion coating of aluminum except zirconium phosphating in aluminum can washing (beer and soda exemption)

Page 38: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Listed Hazardous Waste “Specific Source” “K” Waste Codes

(261.32)

Waste from specifically identified industrial sources:

K001 – K160• Refineries (K048, K170)• Pharmaceutical (K084, K101)• Foundry (K061, K069)• Explosives (K044, K45)

Page 39: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Example

Industry and EPA hazardous waste

No.

Hazardous waste Hazard code

Wood PreservationK001

Bottom sediment sludge from treatment of wastewater from wood preserving process that uses creosote and/or pentachlorophenol

(T)

Inorganic PigmentsK002

Wastewater treatment sludge from the production of chrome yellow and orange pigments

(T)

Organic ChemicalsK013

Bottom stream from the acetonitrile column in the production of acrylonitrile

(T, R)

ExplosivesK044

Wastewater treatment sludge from the manufacturing and processing of explosives

(R)

Page 40: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Listed Hazardous Waste “Commercial Chemical Product”

“U” & “P” Waste Codes

(261.33)

Waste that is a commercial product

solvents

pesticides

Pharmaceuticals

Chemical ingredients

Page 41: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Commercial Chemical Product, continued

• Waste chemical product that is unused

• pure or technical grade of chemical• sole active ingredient

• A waste because: • no longer needed or wanted• off-specification • old/outdated

Page 42: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Commercial Chemical Product, continued

• Spilled virgin chemical product• discarded (spilled on non-soil) • disposal (spilled on soil/water)

Page 43: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

“P” Commercial Chemical Productexamples

“acutely hazardous”

P001 - P205(H)– Empty containers of “P” listed materials (unless triple rinsed)

– Rinsate from rinsing empty containers

Hazardous waste No.

Chemical abstract No.

Substance

P006 20859-73-8 Aluminum phosphide (R)

P075 54-11-5 Nicotine

P110 78-00-2 Plumbane tetraethyl

P105 26628-22-8 Sodium azide

P001 81-81-2 Warfarin

Page 44: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

“U” Commercial Chemical Productexamples

U001 – U411(T)

Hazardous waste No.

Chemical abstract No.

Substance

U002 67-64-1 Acetone (I)

U080 75-09-2 Methylene chloride

U210 127-18-4 Tetrachloroethylene

U220 108-88-3 Toluene

U240 94-75-7 2,4, Dichlorophenoxyacetic acid

U023 98-07-7 Benzotrichloride (C, R)

U160 1338-23-4 2-butanone peroxide (R)

Page 45: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

QUESTIONS

Discarded Disposed

Listed hazardous waste Mixture rule

Page 46: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Characteristic Hazardous Wastes(261.21 – 24)

Four waste types“D” waste codes

–Ignitable (D001)–Corrosive (D002) –Reactive (D003)–Toxicity Characteristic (D004-D043)

Page 47: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Some Facts About Characteristic Hazardous Waste

• All solid waste must be evaluated for the characteristics– Paper – Tires– Chemicals– Lamps – Electronic equipment– Paint– Scrap metal– Building debris

Page 48: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Some Facts About Characteristic Hazardous Waste

• Some characteristics are based on physical properties

• flash point• pH• compressed or pressurized gases• oxidizer

Page 49: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Some More Facts

• Some characteristics are based on concentration limits (toxic above the limits)

• milligrams per liter (mg/L)

• test method “Toxicity Characteristic Leachate Procedure”

• limits range between 0.008 to 400 mg/L

note: one percent (1%) equals 10,000 ppm

Page 50: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Ignitable Characteristic“D001”(261.21)

• Liquid with a flashpoint less than 140 degrees

• Oxidizers (49 CFR 173.151)

• Ignitable compressed gas (49 CFR 173.300)

• Not a liquid – fire through friction, moisture, spontaneous chemical change, & burns vigorously and persistently

Page 51: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Ignitable CharacteristicExamples

Liquid – flash point less than 140• Mineral spirits• Contact cement• Aerosol paint

Oxidizers• Nitric acid• Peroxides• Fertilizer (sodium nitrate)

Ignitable compressed gas• Aerosol products• Propane

Not a liquid• Metal fines and chips

aluminum, zirconium, magnesium

Page 52: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Corrosive Characteristic“D002”(261.22)

• Aqueous liquid, pH less than 2 or greater than 12.5.

• A liquid that corrodes steel at greater than 0.025 inches per year at 130 degrees F.

Page 53: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Corrosive Characteristicexamples

• pH less than 2– Nitric acid (etch)– Sulfuric acid (battery)– Muriatic acid (concrete)– Hydrofluoric (aluminum)

• pH greater than 12.5– Potassium hydroxide (oven)– Sodium hydroxide (drain)– Ammonium hydroxide (cleaner)– Sodium hypochlorite (bleach)

Page 54: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Reactive Characteristic“D003”(261.23)

• Normally unstable

• Reacts violently with water or forms toxic fumes or vapors

• Capable of detonation or explosion when heated under confinement or initiating force

Page 56: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Toxicity Characteristic “D004 - D043”

(261.24)• 39 elements and compounds

• cause damage to tissue, impair CNS, cause severe illness or

death when ingested, inhaled, or absorbed.

• based on concentration limits (mg/L).

• testing using Toxicity Characteristic Leachate Procedure.

Page 57: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

List of Toxicity Characteristic Waste

Waste Code Contaminant Limit mg/LD004 arsenic 5.0

D005 barium 100.0

D006 cadmium 1.0

D007 chromium 5.0

D008 lead 5.0

D009 mercury 0.2

D010 selenium 1.0

D011 silver 5.0

D012 endrin 0.02

D013 lindan 0.4

D014 methoxychlor 10.0

D015 toxaphene 0.5

D016 2,4-D 10.0

Page 58: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Waste code Contaminant Limit mg/LD017 2,4,5-TP 1.0D018 benzene 0.5D019 carbon tetrachloride 0.5D020 chlordane 0.03D021 chlorobenzene 100.0D022 chloroform 6.0D023 o-cresol 200.0D024 m-cresol 200.0D025 p-cresol 200.0D026 cresol 200.0

D027 1,4-dichlorobenzene 7.5

Page 59: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Waste code Contaminant Limit mg/LD028 1,2-dichloroethane 0.5 mg/LD029 1,1-dichloroethylene 0.7 mg/LD030 2,4-dinitrotoluene 0.13 mg/LD031 heptachlor 0.008 mg/LD032 hexachlorobenzene 0.13 mg/LD033 hexachlorobutadiene 0.5 mg/LD034 hexachloroethane 3 mg/LD035 methyl ethyl ketone 200 mg/LD036 nitrobenzene 2 mg/LD037 pentachlorophenol 100 mg/LD038 pyridine 5 mg/LD039 tetrachloroethylene 0.7 mg/LD040 trichloroethylene 0.7 mg/LD041 2,4,5 trichlorophenol 400 mg/LD042 2,4,6 trichlorophenol 2.0 mg/LD043 vinyl chloride 0.2 mg/L

Page 60: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Examples• Lead

• Silver

• Mercury

• Chromium

• 2,4-D• Benzene• Tetrachloroethylene• Pentachlorophenol

• Paint, wire coating, electronics, gun range, electroplating, fly ash, foundry, batteries

• X-ray & photo developing, electronics, electroplating, batteries

• Batteries, lamps, switches, dental fillings

• Electroplating, paint, fly ash, foundry• Weed & feed products• Gasoline, oil, labs• Aerosol degreasers, dry cleaners• Egg farms, wood preservers

Page 61: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Questions

ignitable corrosive

reactive test methods

toxicity characteristic

Page 62: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

The Other RCRA Waste

Hazardous wastes that can be managed under reduced requirements–

• Used Oil (40 CFR 279)

• Universal Waste (40 CFR 273)

Page 63: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Used Oil

“Any oil 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”

Lube oil (crank case, tub/wire drawing)

Heat transfer oil (machining, hot plate)

Hydraulic oil

Does not include animal or vegetable oil

Page 64: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Used Oil(40 CFR 279)

• Used oil includes filters & absorbents• Can exhibit a HW characteristic or be listed HW• Presumed to be recycled (disposed = full regulation)• Must test for total halogens• > 1000 ppm halogens - presumed mixed with hazardous waste.

- halogenated solvents (100 ppm = HW)

Page 65: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Used Oil Generators(40 CFR 279)

– Don’t have to get EPA Id. No.– Burn in an on-site space heater– Can take from residential DIY– No storage time or quantity limits

• 1340-gallons petroleum waste and/or product – SPCC Plan

– Can be sold as fuel• Off-spec – industrial boilers/furnaces regulated under Part 266• On-spec – to anyone

– non-residential in CT.

Page 66: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Used Oil Fuel Specifications• On-specification used oil fuel

– Arsenic 5 ppm– Cadmium 2 ppm– Chromium 10 ppm– Lead 100 ppm– Flash point 100 F – Total halogens 4000 ppm

• Off-specification used oil fuel– Exceed any of the above

Page 67: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Universal Waste Rule(40 CFR 273)

• Waste generated at any type of business– Manufacturers– Repair shops– Office buildings– Hotels– Casinos

• Are a listed or characteristic HW– Except for some FIFRA recalled pesticides

Page 68: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Universal Waste• The universal waste:

– Batteries (HW corrosive, heavy metals)• Lead-acid, NiCad, Hg cell, Li cell, Ag cell

– Thermostats (HW mercury)– Lamps (HW mercury)– FIFRA recalled pesticides–

Page 69: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Universal Waste

• States can add other HW– Mercury containing equipment (HW mercury)– All fluorescent lamps (HW & non-HW mercury)– Used electronics (HW lead, silver, mercury)

Page 70: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Universal Waste• EPA Id. No., only if handling <5000 kilograms• Store for up to one year

• Handle in an environmentally safe manner• Spilled/released becomes fully regulated HW

• Ship to other UW handler• Still UW

• Ship to final destination facility• TSDF or permit exempt recyclers• Becomes fully regulated HW

Page 71: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

In the works

• Many states are considering adding pharmaceuticals• Being pushed by hospitals and pharmacies

– “P” and “U” listed waste• Warfarin• Nicotine• Epinephrine

– Characteristic waste• Heavy metal compounds

– Mercury, selenium, barium, chromium

• Pesticides– Lindan

• Ignitable liquids

Page 72: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Questions

Used oil & handling requirements

Universal Waste & handling requirements

Page 73: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Some Statistics

Virgin (waste) Oil

29,000,000 gallons/year run-off into oceans

• 85% land run-off (24,650,000 gallons)• 8% pipeline and oil tanker (2,320,000 gallons)• 3% oil exploration (870,000 gallons)

Page 74: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Some Statistics

Used Oil

1,378,000,000 gallons/year generated

• 67% burned as fuel (928,000,000 gallons)• 13% illegally disposed (185,000,000 gallons)• 10% landfilled (140,000,000 gallons)• 4% rerefined (56,000,000 gallons)

Page 75: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Some Statistics

Used Oil Filters

400,000,000 filters/year generated

• 90% illegally disposed (360,000,000)• 10% recycled (40,000,000)• 1 ton recycled filters equals 1,700 pounds of steel

60 gallons of oil

Page 76: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Some Statistics

Lead-acid Batteries

70,000,000 Batteries/year generated

• 20 pounds lead/2 gallons acid• 80% are recycled (56,000,000)• 20% are disposed (14,000,000)

– 280,000,000 pounds lead disposed– 28,000,000 gallons acid disposed

Page 77: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Some Statistics

Mercury Containing Lights600,000,000 Waste bulbs/year

• 14 to 80 milligrams mercury/bulb• Pre 1996, most disposed• Post 1996:–80% recycled (480,000,000 bulbs)–20% disposed (*120,000,000 bulbs)

* About 20,000 pounds of mercury disposed each year

Page 80: Public Acts 1976 Resource Conservation & Recovery Act –Required permits for hazardous waste facilities that disposed or burned waste –Prohibited opened

Sources of Assistance

• David Stokes, DEP Waste Management– 860-424-3269– E-mail – [email protected]

• DEP Compliance Assistance Phone Line– Toll free 888-424-4193– RCRA main line 860-424-3023


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