1. Hazardous Waste Identification
Charles Corcoran
Waste Identification and Recycling Section
Regulatory and Program Development Division
Hazardous Waste Management Program
Department of Toxic Substances Control
February 13, 2007

2. Purpose of Course
To provide the knowledge to enable you to make a “hazardous waste determination”
To familiarize you with laws and regulations pertaining to hazardous waste identification
February 13, 2007

3. Objectives
Understand the terms “waste”, “exclusion”, “exemption”, “listing”, and “characteristic”
To know where to find the above
To be able to work with sample data to make a hazardous waste determintaion
February 13, 2007

4. Administrative Essentials
Breaks/Lunch
Restrooms
Food/Drinks in Classroom
Cell Phones
Other?
February 13, 2007

5. Golden Rule for this Course: ASK QUESTIONS!!!
This course is its most useful when you explore the concepts with me.
If something is unclear or doesn’t make sense, ask for clarification.
February 13, 2007

6. Hazardous Waste Identification
Part 1: Introduction
This class is about a procedure (or a process).
You put info in and crank the handle.
And you get info out.
February 13, 2007

7. Accuracy is Essential
All other waste management requirements hinge upon this one decision
Generator’s responsibilities are defined
Regulator’s authority is defined
February 13, 2007

8. Mistakes Happen Because: Lack of information Poor judgement
Misinformation
Lack of knowledge about the laws and regulations
Misclassification Happens:
Intentional
Cost to classify
Future Liability
Conservative decision-making
Desire to deceive or avoid penalties
Complexity of waste or waste generation activity
February 13, 2007

9. Misclassification: Does it really matter?
February 13, 2007

10. Case 1: Nonhazardous wastes (mis)classified
as hazardous wastes
Generators - legally no problem
Regulators - could result in unsuccessful litigation: wasted resources and effort
EPA self-declared wastes.
So why not classify everything as hw cost
February 13, 2007

11. Case 2: Hazardous wastes misclassified as nonhazardous wastes
Generators
Legally BIG problems
Illegal management/ disposal of hazardous wastes
Regulators
BIG problems-fails to identify potential waste mismanagement
Could prolong conditions that endanger public health and the environment
Of course protection of public health is what all this env. Stuff is about.
Its why we have HW LAWS
February 13, 2007

12. Laws & Regulations Dual System Federal and State laws and regulations
This course is about laws.
Meaning of “law” and “regulation” and “statute”
February 13, 2007

13. Federal Laws
Statute: Resource Conservation and Recovery Act or RCRA, Chapter 42, United States Code
Regulations: Title 40, Code of Federal Regulations (40 CFR,Parts )
February 13, 2007

14. State Laws
Statute: Hazardous Waste Control Law, California Health and Safety Code, Division 20, Chapter 6.5, (
Regulations: California Code of Regulations, Division 4.5, Title 22 (
February 13, 2007

15. State Requirements
Important Note: Unlike the federal requirements, in California both statutes and regulations contain specific requirements
Need to use 2 books
February 13, 2007

16. California is a federally “authorized” state
Generally, California’s requirements contain all hazardous waste requirements that apply in California
Most newly adopted federal regulations do not apply in California until California adopts them
Note requirements – not regulations
February 13, 2007

17. Title 22 CCR: Contents Chapter 10 - Scope and Definitions
Chapter 11 - Identification and Listing of Hazardous Wastes
Chapter 12 - Generator Standards
See section
February 13, 2007

18. Title 22 CCR: Contents Chapter 13 - Transporter Standards
Chapter 14 - Requirements for Permitted Facilities
Chapter 15 - Requirements for Interim Status Facilities
Chapter 16 - Requirements for Recyclable Wastes
Chapter 18 - Land Disposal Restrictions
Chapter 20 - The Hazardous Waste Permit Program
Chapter 22 – Enforcement, Inspections, and Informant Rewards
Chapter 23 - Universal Waste Management
February 13, 2007

19. Organization of Chapter 11
Article 1
General Provisions
Definition of Waste
Definition of Hazardous Waste
Article 2
Criteria for Identifying the Characteristics of Hazardous Waste
February 13, 2007

20. Organization of Chapter 11
Article 3
Characteristics of Hazardous Waste
Article 4
Lists of RCRA Hazardous Wastes
Article 4.1
Additional Lists of Hazardous Wastes
February 13, 2007

21. Chapter 11 Appendices Article 5 Appendix I Appendix II
Categories of Hazardous Waste
(waste classification)
Appendix I
Representative Sampling Methods (Alternatives to SW-846)
Appendix II
Waste Extraction Test Procedures
February 13, 2007

22. Chapter 11 Appendices Appendix III Appendix VII Appendix VIII
Chemical Analytical Test Methods
Appendix VII
Basis for listing RCRA hazardous wastes
Appendix VIII
Hazardous constituents found in RCRA-listed hazardous wastes
February 13, 2007

23. Chapter 11 Appendices Appendix X Appendix XI Appendix XII
List of Chemical Names and Common Names of Hazardous Wastes
Appendix XI
Organic Lead Test Method
Appendix XII
California Hazardous Waste Codes
Whole chapter and a bunch of appendices for hw DET.
February 13, 2007

24. Who determines whether the waste is a hazardous waste. 22 CCR §66260
Who determines whether the waste is a hazardous waste? 22 CCR § (c)
Generator’s responsibility to make determination
Who is regulated (is subject to) these Laws & Regulations.
February 13, 2007

25. Hazardous Waste Determination 22 CCR §66262.11
How?
The information a waste generator may use to classify their waste falls into two categories:
Analytical testing data
Generator knowledge of materials and processes used
February 13, 2007

26. What if the generator does it wrong? 22 CCR §66260.200(c)
Subject to enforcement action if hazardous waste is mismanages hazardous waste as nonhazardous waste
Implements HSC (b)
February 13, 2007

27. How does an inspector know if the generator did the waste determination wrong?
That’s why we are here
February 13, 2007

28. Overview of the hazardous waste determination procedure
Is the material a waste?
Is the material excluded or exempted?
Is the waste excluded or exempted?
Is the waste listed in Article 4 or 4.1?
Is the waste listed in Appendix X?
Does the waste exhibit a characteristic of hazardous waste?
February 13, 2007

29. Hazardous Waste Determination Process
Part 2: Waste Identification
February 13, 2007

30. STEP 1: Do I have a “waste” ?
Most of the time this easy.
But not always
February 13, 2007

31. What is a Waste? Layperson’s definition
Some thing that someone has, but that they don’t have a use for.
Probably going to get rid of.
February 13, 2007

32. Definition of Waste §66261.2 22 CCR §25124 HSC
A waste is any discarded material (in any physical form, such as solid, liquid, semi-solid, contained gas) that is not excluded by (a), (e), or (b) or (d)
1) Discuss RCRA “solid waste”.
2) Different than lay person’s definition
February 13, 2007

33. What does “Discarded” mean? 22 CCR 66261.2(b)
A material is discarded if it is:
Relinquished
Recycled (sometimes)
Inherently waste-like
Gee, that’s not much help!
As described below
February 13, 2007

34. Relinquished 22 CCR 66261.2(c) A material is relinquished if it is:
disposed of
burned or incinerated
accumulated, stored or treated (but not recycled) before, or in lieu of, being relinquished
RCRA uses “abandoned”. U.S. Courts have colored “abandoned”. Those decisions don’t impact California, but in the final analysis abandoned and relinquished mean thrown away.
February 13, 2007

35. Recycled CCR (d)
A material is a waste if it is recycled (or accumulated, stored or treated prior to recycling) if it is:
used in a manner constituting disposal (placed on land)
burned for energy recovery
reclaimed
accumulated speculatively
4 types of recycling.
Tomorrow
More layers
February 13, 2007

36. Inherently Waste-like Materials 22 CCR 66261.2(e)
A material is a waste if it is inherently waste-like when it is recycled
RCRA waste codes F020, F021, F022, F023, F026 and F028 (contain dioxins)
secondary materials that are otherwise hazardous waste and are fed to a halogen acid furnace
More circular reasoning
February 13, 2007

37. Improper Packaging/Labeling 22 CCR 66261.2(f)
Materials are also wastes if they are:
mislabeled or inadequately labeled, unless labeled correctly within 10 days
in a deteriorated or damaged container, unless repackaged within 96 hours
Must pose a threat to human health or the environment
February 13, 2007

38. Exclusions §25124 HSC Materials that are not discarded:
Intermediate manufacturing process streams
Coolants, lubricants or cutting fluids that are filtered to extend their useful life
1) Exclusion: sets the jurisdictional line.
February 13, 2007

39. Exclusions §25143.2 HSC Certain recyclable materials
ingredients in industrial processes
substitutes for commercial products
returned to original process w/out reclamation
recycled/reused onsite
1) Different 4 kinds of recycling.
February 13, 2007

40. Waste Exclusions 22 CCR §66261.4(a)
Materials that are not wastes:
Point source discharges subject to CWA (NPDES permits)
Nuclear wastes
Spent sulfuric acid used to produce virgin sulfuric acid
February 13, 2007

41. Waste Exclusions 22 CCR §66261.4(a)
Materials that are not wastes:
reclaimed pulping liquors
reclaimed secondary materials returned to original process
February 13, 2007

42. STEP 2: So you have a waste. Is it a hazardous waste? Wait…
How to you do it.
Go through them one by one
February 13, 2007

43. Overview of Hazardous Waste Classification
Is the material a waste?
Is the material excluded or exempted?
Is the waste excluded or exempted?
Is the waste listed in Article 4 or 4.1?
Is the waste listed in Appendix X?
Does the waste exhibit a characteristic of hazardous waste?
February 13, 2007

44. Hazardous Waste Exclusions 22 CCR §66261.4(b)
Wastes that are not hazardous wastes:
Infectious wastes (animal carcasses)
Used oil re-refining still bottoms used in asphalt products
Used CFCs that are reclaimed
Mining wastes
Wastes excluded under 40 CFR §261.4 *
Blue –pulls in another whole list to go through –or does it
February 13, 2007

45. Hazardous Waste Exclusions 22 CCR §66261. 4(b)
Hazardous Waste Exclusions 22 CCR § (b) *Wastes excluded under 261.4(b), unless the waste also exhibits an Article 3 characteristic
Household wastes
Agricultural wastes used as fertilizers
Mining overburden
Fossil fuel combustion wastes
Trivalent chromium wastes (leather tanning)
Mining wastes
Cement kiln dust
Arsenic treated wood
February 13, 2007

46. Hazardous Waste Exclusions 22 CCR §66261. 4(b)
Hazardous Waste Exclusions 22 CCR § (b) *Wastes excluded under 261.4(b), unless the waste also exhibits an Article 3 characteristic
Used CFC refrigerants
Used oil filters
Landfill leachate or gas condensate
Petroleum contaminated media and debris (D018-D043)
Reinjected groundwater from refinery cleanups
February 13, 2007

47. Hazardous Waste Exemptions 22 CCR §66261.4(c-g)
materials in product or raw material storage tanks are exempt until removed (within 90 days of ceasing operation)
samples - subject to regulation as a waste after use as a sample ceases
treatability study samples for generator and labs
controlled substances
1) Not tied to federal regulations.
February 13, 2007

48. Statutory Exemptions §25141.5(b)(2)(B) HSC
These substances are not hazardous wastes if only hazardous by acute toxicity criteria.
acetic acid calcium fluoride
aluminum chloride calcium formate
ammonium bromide calcium propionate
ammonium sulfate cesium chloride
anisole magnesium chloride
boric acid potassium chloride
February 13, 2007

49. Statutory Exemptions §25141.5(b)(2)(B) HSC
These substances are not hazardous wastes if only hazardous by acute oral toxicity criteria
sodium bicarbonate food flavoring oils:
sodium borate allspice oil
decahydrate Ceylon cinnamon oil
sodium carbonate clarified slurry oil
sodium chloride dill oils
sodium iodide lauryl leaf oils
sodium tetraborate
February 13, 2007

50. Statutory Exclusion/Exemption §25141.5(b)(3)(A) HSC
Effective January 1, 1996
Excluded from hazardous waste classification for disposal purposes only
Hazardous only because of Total Threshold Limit Concentration
February 13, 2007

51. Statutory Exclusion/Exemption §25141.5(b)(3)(A) HSC
Must be managed per the regulations prior to disposal
Does not apply to:
liquids, sludges, sludge-likes, soils, finely divided or tarry materials
organic constituents
February 13, 2007

52. Statutory Exemptions HSC §25143.1 (c) (1)
Geothermal drilling wastes that are generated from exploration, development, or production of geothermal energy (excluding filter cake) is exempt.
February 13, 2007

53. Statutory Exclusions/Exemptions §25143.1.5 HSC
Treated wood wastes (TWW)
Effective January 1, 2007
treated wood wastes regulated pursuant to RCRA must comply with hazardous waste requirements
Treated wood wastes that is a CA hazardous waste, but not a RCRA-TWW and is not from electric, gas, or telephone service is eligible for the provisions of HSC § and
1) “RCRA” treated wood waste (RCRA-TWW) must comply with the applicable California hazardous waste requirements, including, as applicable’ generator, transportation, and facility management standards. An example of a RCRA-TWW is chromated copper arsenate (CCA) treated wood waste scrap generated within a wood treating plant which is classified or characterized as hazardous under the federal rules.
February 13, 2007

54. Statutory Exclusions §25143.8 HSC
Cementitious materials
effective January 1, 1996
cement, cement kiln dust, clinker, clinker dust
not required to be tested for solid corrosivity
if hazardous solely due to corrosivity for solids, excluded from classification as hazardous waste
February 13, 2007

55. Statutory Exemptions §25143.12 HSC
Petroleum contaminated debris if
wood, paper, textiles, concrete rubble, metallic objects, solid manufactured objects
not Federally regulated
does not contain free liquids
disposed in Class I or II landfill
February 13, 2007

56. Statutory Exemptions §25143.7 HSC
Asbestos wastes
may be disposed in a landfill that is not Class I
February 13, 2007

57. Statutory Exemptions §25117.5 and §117635 HSC
Biohazardous waste
formaldehyde fixed human surgery specimens or tissues
Wastes contaminated with chemotherapeutic agents
pharmaceuticals
February 13, 2007

58. Hazardous Waste Exemptions 22 CCR §66261.7
Contaminated containers
Exempted if “empty”
February 13, 2007

59. Hazardous Waste Exemptions 22 CCR §66261.7
Containers empty when:
Pourable wastes no longer pour when container inverted
Nonpourable wastes are scraped or otherwise removed
February 13, 2007

60. Hazardous Waste Exemptions 22 CCR §66261.7
5 gallons or smaller - destroyed and disposed
Larger than 5 gallons - reclaimed for scrap value, reconditioned, remanufactured, or refilled
Aerosols if completely discharged of contents and propellant
February 13, 2007

61. Hazardous Waste Determination Procedure
Is the material a waste?
Is the material excluded or exempted?
Is the waste excluded or exempted?
Is the waste listed in Article 4 or 4.1?
Is the waste listed in Appendix X?
Does the waste exhibit a characteristic of hazardous waste?
February 13, 2007

62. Waste Determination Process
Is the waste listed in Article 4 or 4.1?
Hazardous waste identification - listings
Go through them one by one
February 13, 2007

63. Definition of Hazardous Waste 22 CCR §66261.3
A waste is a hazardous waste if it:
listed in or contains constituents listed in Appendix X, unless the waste is determined to be nonhazardous
is a mixture of a waste and a Article 4 (Federal) listed hazardous waste
February 13, 2007

64. 22 CCR Article 4: RCRA Lists
Lists were created based on U.S. EPA established criteria (40 CFR )
pose a threat in the absence of special regulation
pose a threat even when properly managed
typically exhibits a hazardous waste characteristic
otherwise hazardous
1) Four lists: F, K, P, and U.
February 13, 2007

65. RCRA Listed Hazardous Wastes 22 CCR Article 4
A waste is compared to the wastes described in the lists
The source of the waste (i.e., the process that generated the waste) is just as (maybe more) important than the waste’s constituents
must meet all aspects of the listing for it to apply.
February 13, 2007

66. Three categories of lists
1. Non-specific sources (F)
2. Specific sources (K)
- Hazard code - the reason the waste was listed (I, C, R, E, H, T)
1) Talk about F vs. K.
February 13, 2007

67. Three categories of lists
3. Discarded commercial chemical products, off-specification species, and spill residues (P, U)
- Hazard code H
acute hazardous waste (P-list)
- Hazard code T
toxic (U-list)
February 13, 2007

68. Non-specific Sources (F-List) 22 CCR §66261.31
Waste codes with "F" followed by a three-digit number (e.g., F001)
Not dependent on industry or process that generates the waste
Not dependent on constituents or their concentrations present in the waste
February 13, 2007

69. Non-specific Sources (F-List) 22 CCR §66261.31
Spent solvent wastes (F001 - F005)
Electroplating and metal finishing operations wastes (F006 - F012, F019)
Dioxin-bearing wastes (F020 - F023; F026 - F028)
February 13, 2007

70. Non-specific Sources (F-listed) 22 CCR §66261.31
Chlorinated aliphatic hydrocarbons production wastes (F024, F025)
Wood preserving wastes (F032, F034, and F035)
Petroleum refinery wastewater treatment sludges (F037 and F038)
Multisource leachate (F039)
1) Discuss 1999/2000 changes to F037
February 13, 2007

71. Example: F001
“The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1‑trichloroethane, carbon tetrachloride, and chlorinated fluorocarbons; all spent solvent mixtures/blends used in degreasing containing, before use, a total of ten percent or more (by volume) of one or more of the above halogenated solvents or those solvents listed in F002, F004, and F005; and still bottoms from the recovery of these spent solvents and spent solvent fixtures.”
February 13, 2007

72. Example: F001-Degreasing operations
To be listed, a waste:
must be one of the listed solvents
must be "spent"
must have been used for degreasing
must have been ten percent or more before use, or
must be still bottoms from solvent recycling
February 13, 2007

73. Specific Sources (K-List) 22 CCR §66261.32
Waste codes with ”K" followed by a three-digit number (e.g., K001)
Dependent on the industry, process, or waste source specified in the description
Not dependent on constituents or their concentrations present in the waste
1) Talk about K048 and Lead.
February 13, 2007

74. Specific Sources (K-List) 22 CCR §66261.32
Manufacturing and Production Wastes from:
Wood preservation
Inorganic pigment
Organic chemicals
Inorganic chemicals
Pesticides
Explosives
Petroleum refining
Iron and steel
Veterinary pharmaceuticals
Primary copper
Primary lead
Primary zinc
Primary aluminum
Ferroalloys
Secondary lead processing
Ink formulation
Coking (processing of coal to produce coke
February 13, 2007

75. Example: K001
“Bottom sediment sludge from the treatment of wastewaters from wood preserving processes that use creosote and/or pentachlorophenol.”
February 13, 2007

76. Example: K001 To be listed:
wood preserving facility or where wood preservation is/was performed
facility must use creosote or pentachlorophenol
facility must generate and treat wastewater
only bottom sediment sludge from a wastewater treatment unit
Note; background listing documents
February 13, 2007

77. Discarded Commercial Chemical Products, Off-Spec
Discarded Commercial Chemical Products, Off-Spec. Species, & Spill Residues (P-& U-lists) 22 CCR § (e) & (f)
Waste codes with ”P" or “U” with a three digit number (e.g., P001. U001)
“P” wastes are acutely hazardous wastes (H)
“U” wastes are toxic hazardous wastes (T)
Most misunderstood of the RCRA listings
February 13, 2007

78. Discarded CCP, Off-Spec
Discarded CCP, Off-Spec. Species, and Spill Residues (P- & U-lists) 22 CCR § (e) & (f)
To be listed
the chemical must be unused
the chemical must be pure (i.e., a sole active ingredient in a formulation)
Cannot have been used or become spent
Cannot have been mixed with other chemicals/active ingredients to form a product
February 13, 2007

79. Example: U220 - Toluene Must be unused
Must be the sole active ingredient
A waste that contains toluene is not listed as U220 only because toluene is present
Examples:
Laboratory chemicals, expired or shelf-life materials, raw material spills
February 13, 2007

80. Example: U220 - Toluene
A paint formulation containing toluene would not meet the U220 listing just because the paint contained toluene
1) Pigment binders are active ingredients (AI); toluene is a solvent , not an AI.
February 13, 2007

81. Hazardous Waste Determination Procedure
Is the material a waste?
Is the material excluded or exempted?
Is the waste excluded or exempted?
Is the waste listed in Article 4 or 4.1?
Is the waste listed in Appendix X?
Does the waste exhibit a characteristic of hazardous waste?
February 13, 2007

82. Article 4.1 DTSC Listed Wastes
Effective March 15, 2003
Adopted M-Listed Wastes
Mercury (Hg) containing wastes
February 13, 2007

83. Article 4.1 DTSC Listed Wastes
M001: Hg light switches in cars and cars with them prior to crushing, baling, shredding, or shearing
M002: Other Hg switches in products, including appliances (effective 2/9/06)
M003: Hg containing lamps and products with Hg lamps
M004: Hg added novelties
February 13, 2007

84. Regulations Unique to Federal RCRA Listed Wastes
Mixture Rule
Derived-From Rule
Contained-In Policy
February 13, 2007

85. Mixture Rule – RCRA Listed Wastes 22 CCR §66261.3 (a)(2)(E) & (F)
Mixtures of wastes and RCRA listed hazardous wastes are hazardous wastes
Concentrations are irrelevant
Once listed always listed
February 13, 2007

86. Mixture Rule – RCRA Listed Wastes 22 CCR §66261.3(a)(2) (E) & (F)
Exemptions:
waste has been delisted by US EPA
wastes listed solely due to a characteristic other than (t) or (h), and mixture does not exhibit the characteristic (example, F003 - ignitability)
February 13, 2007

87. Mixture Rule – RCRA Listed Wastes 22 CCR §66261.3(a)(2)(F)
Exemptions:
wastewaters containing de minimus concentrations of listed wastes discharged under CWA provisions
wastes containing minimal losses of P and U wastes due to normal handling or minor leaks
others
February 13, 2007

88. Derived-From Rule- RCRA Listed Wastes 22 CCR §66261.3(c)
Wastes generated from the treatment, storage or disposal of listed wastes are hazardous wastes
Example: incineration of K001 sludge, resulting ash is derived from a RCRA listed waste
February 13, 2007

89. Derived-From Rule – RCRA Listed Wastes 22 CCR §66261.3(c)
Exemptions
waste is delisted by US EPA
pickle liquor sludge
slag from high temperature metal recovery (F006, K061, and K062)
biological treatment sludge (K156 and K157)
February 13, 2007

90. RCRA Contained-in Policy
Applies to contaminated media and debris
Environmental media (water or soil) that contain listed wastes are hazardous wastes
unless DTSC determines that the listed waste is present in insignificant concentrations (risk-based evaluation)
Actually two parts to the contained in policy codified nad uncodified
February 13, 2007

91. Example - Technical Grade - 80% 2,4 dinitrotoluene
- unused, but to be discarded
- listed as U105
Listed Hazardous Waste
February 13, 2007

92. Class Example
- Product Containing 5% p-chloroaniline and other active ingredients
- Product is unused, but spilled onto land
- P-chloroaniline listed as P024
Not a Listed Hazardous Waste
February 13, 2007

93. Class Example - Sole Active Ingredient: 5% p-chloroaniline
- unused, but spilled onto land
- listed as P024
Listed Hazardous Waste
Soil contains a listed hazardous waste
1) When actively managed.
February 13, 2007

94. Class Example - Sole Active Ingredient: 5% p-chloroaniline
- unused, but spilled onto land
- spill residue treated
- listed as P024
Hazardous Waste because
Derived From Listed Waste
Waste Residue
1) Soil is non-hazardous only if a DTSC letter was obtained.
Nonhazardous
contained-in det.
Treatment
Clean soil
February 13, 2007

95. Delisting 40 CFR §260.22
A waste producer can petition U.S.EPA to delist a listed waste
Involved, time consuming process
Delisting petitions that are granted are adopted into regulation (see 40 CFR Part 261, Appendix IX)
DTSC does not issue delistings
February 13, 2007

96. CA Mixture Rule for M-Listed Wastes 22 CCR §66261. 3(b)(4) (Article 4
Not like the RCRA listed waste mixture
Is a hazardous waste only if it meets a characteristic of a hazardous waste (toxic, corrosive, ignitable, reactive)
February 13, 2007

97. Derived-From Rule: M-Listed Waste 22 CCR §66261.3(c)(5)
Not like the RCRA listed waste derived from rule
Addresses waste derived from treatment or recycling of Article 4.1 listed wastes
Is a hazardous waste only if it meets a characteristic of a hazardous waste (toxic, corrosive, ignitable, reactive)
February 13, 2007

98. What if my waste isn’t listed (is not a listed HW)?
If a waste is not on any of the lists, the next step is to determine if the waste exhibits one of the characteristics of hazardous waste
February 13, 2007

99. Hazardous Waste Determination Procedure
Is the material a waste?
Is the material excluded or exempted?
Is the waste excluded or exempted?
Is the waste listed in Article 4 or 4.1?
Is the waste listed in Appendix X?
Does the waste exhibit a characteristic of hazardous waste?
February 13, 2007

100. Hazardous Waste Determination Procedure
Step 4: Hazardous Waste Identification
- Characteristics
February 13, 2007

101. Characteristics of Hazardous Wastes 22 CCR Article 3
Ignitability
Corrosivity
Reactivity
Toxicity
1) I, R the same as RCRA, C,T differ.
February 13, 2007

102. Ignitable Wastes
Wastes that can readily catch fire and sustain combustion
Same as federal characteristic
February 13, 2007

103. Characteristics of Ignitability 22 CCR §66261.21
Liquid with a flashpoint < 140°F (60°C)
Not a liquid and is capable, under STP, of causing fire through friction, absorption of moisture or spontaneous chemical changes and, when ignited, burns so vigorously and persistently that it creates a hazard
Ignitable compressed gas
Oxidizer
Waste code D001
1) Other than <24% alcohol.
February 13, 2007

104. Characteristic of Ignitability 22 CCR §66261.21
Flash point testing for liquids
For nonliquids, more difficult
SW-846 Method 1030 to test rate of combustion
no tests available to measure friction, absorption of moisture or spontaneous chemical changes
February 13, 2007

105. Corrosive Wastes
acidic or alkaline (basic) wastes that can readily damage materials (skin or containers) they contact
California included solids (22 CCR § (a) (3) & (a) (4)
February 13, 2007

106. Characteristic of Corrosivity 22 CCR §66261.22
Measured by pH
Measured by rate of steel corrosion
Waste code D002
February 13, 2007

107. Characteristic of Corrosivity 22 CCR §66261.22pH
Aqueous solution with a pH  2 or > 12.5
Not aqueous and, when mixed with an equal weight of water, has pH  2 or > 12.5
1) Alcohol exclusion method 9040.
February 13, 2007

108. Characteristic of Corrosivity 22 CCR §66261.22
Steel corrosion rate
Liquid that corrodes steel at a rate greater than 6.35mm per year
Not liquid, and, when mixed with an equal weight of water, corrodes steel at a rate greater than 6.35mm per year
February 13, 2007

109. Reactive Wastes wastes that readily explode, or
undergo violent reactions
February 13, 2007

110. Characteristic of Reactivity 22 CCR §66261.23
explode or react violently when exposed to water or under normal handling conditions
create toxic fumes or gases when exposed to water or under common handling conditions
meets the criteria for classification as an explosive under Department of Transportation rules.
February 13, 2007

111. Characteristic of Reactivity 22 CCR §66261.23
Consists exclusively of narrative criteria
For pure or relatively pure compounds which are wastes, a reactivity determination is relatively easy and straightforward
Mixtures pose a dilemma
February 13, 2007

112. Characteristic of Reactivity 22 CCR §66261.23
In many cases, there are no test methods
Generators to use their best knowledge
Assumes that the dangers these wastes pose are well known to the few waste handlers who deal with them
1) Generators will I.D these wastes by special precautions required.
February 13, 2007

113. Characteristic of Reactivity 22 CCR §66261.23
DTSC limited to using only tests, procedures and thresholds established by U.S.EPA (§ HSC)
Therefore, unless DTSC adopts a new regulation, the reactivity characteristic should be applied as U.S. EPA would apply it
February 13, 2007

114. Toxic Wastes
wastes that can deleteriously effect human health or the environmental
February 13, 2007

115. Characteristic of Toxicity 22 CCR §66261.24
Eight elements (or parts) to this characteristic
Waste can be toxic by any of these elements (by any one criterion)
TCLP is limited to federal hazardous wastes
February 13, 2007

116. Characteristic of Toxicity 22 CCR §66261.24
Persistent and Bioaccumulative Toxic Substances (PBTs)
PBTs were considered public health threat and/or environmental hazard in the 1970’s
Elements (a)(1) and (a)(2) of toxic characteristic
Toxicity is where California really differs
February 13, 2007

117. Characteristic of Toxicity (TCLP) 22CCR66261.24(a)(1)
The federal toxicity characteristic is based upon a leach test called the TCLP or the “Toxicity Characteristic Leaching Procedure”
Simulates landfill disposal of a hazardous waste
February 13, 2007

118. Characteristic of Toxicity (TCLP) 22 CCR66261.24(a)(1)
Subsection (a)(1) (or element (a)(1)) incorporates the TCLP into California hazardous waste regulations
To determine if a waste exhibits the characteristic of toxicity by this element, samples of the waste are extracted using the TCLP
The extracts are analyzed and the lab (analytical) results are compared to the RLs in the table
February 13, 2007

119. Characteristic of Toxicity (TCLP) 22 CCR66261.24(a)(1)
If the result, in milligrams of hazardous constituent per liter of extract, equals or exceeds the RL, the waste exhibits the characteristic of toxicity.
In California, the TCLP is not applied to RCRA excluded or exempted wastes.
February 13, 2007

120. TCLP Example
A waste sample is analyzed for chromium & cadmium using the TCLP. The analytical report states:
chromium mg/L
cadmium mg/L
R.L Chromium is 5.0mg/L
R.L Cadmium is 1.0mg/L
February 13, 2007

121. Federal Toxicity Characteristic 22 CCR §66261.24(a)(1)
D004 Arsenic
D005 Barium 
D018 Benzene 
D006 Cadmium 
D019 Carbon tetrachloride 
D020 Chlordane 
D021 Chlorobenzene 
D022 Chloroform
D007 Chromium 
D023 o-Cresol
D024 m-Cresol 
D025 p-Cresol 
D026 Cresol
D016 2,4-D 
D027 1,4-Dichloro- benzene
D028 1,2-Dichloro- ethane
February 13, 2007

122. Characteristic of Toxicity 22 CCR §66261.24(a)(1)
D029 1,1 Dichloroethylene 
D030 2,4 Dinitrotoluene 
D012 Endrin  
D031 Heptachlor (and its epoxide) 
D032 Hexachlorobenzene 
D033 Hexachlorobu- tadiene 
D034 Hexachloroethane 
D008 Lead 
D013 Lindane 
D009 Mercury 
D014 Methoxychlor 
D035 Methyl ethyl ketone
D036 Nitrobenzene 
D037 Pentachlorophenol
February 13, 2007

123. Characteristic of Toxicity 22 CCR §66261.24(a)(1)
D038 Pyridine 
D010 Selenium
 D011 Silver  
D039 Tetrachloro- ethylene
D015 Toxaphene 
D040 Trichloro- ethylene 
D041 2,4,5 Trichloro- phenol
D042 2,4,6 Trichloro- phenol 
D017 2,4,5‑TP (Silvex) 
D043 Vinyl chloride
February 13, 2007

124. Characteristic of Toxicity 22 CCR §66261.24(a)(1)
Each constituent has a Regulatory Level (RL)
If the measured concentration in the TCLP extract exceeds the RL, the waste is toxic (and therefore hazardous waste.)
Wastes identified as toxic hazardous wastes carry the waste codes indicated.
February 13, 2007

125. Characteristic of Toxicity 22 CCR §66261.24(a)(2)
Inorganic constituents
Both WET soluble and total concentrations
Organic constituents
Ca. tables
February 13, 2007

126. Characteristic of Toxicity 22 CCR §66261.24(a)(2)
Subsection (a)(2) (or element (a)(2)) is unique to California’s hazardous waste regulations
To determine if a waste exhibits the characteristic of toxicity by this element, samples of the waste are prepared for analysis of their total and extractable contents
February 13, 2007

127. Characteristic of Toxicity 22 CCR §66261.24(a)(2)
The digests (total) and extracts (WET) are analyzed and the results are compared to their respective limits (in the tables in subsection (a) (2)).
February 13, 2007

128. Persistent and Bioaccumulative Toxic Substances 22 CCR §66261.24(a)(2)
Toxic and hazardous if:
The WET extract content > Soluble Threshold Limit Concentration (STLC) by the WET (mg/L), or
The digest content > Total Threshold Limit Concentration (TTLC) by analysis for total concentration in waste (mg/kg)
February 13, 2007

129. Inorganic Constituents 22 CCR §66261.24(a)(2)(A)
Antimony
Arsenic
Asbestos
Barium
Beryllium
Cadmium
Chromium
Chromium VI
Cobalt
Copper
Fluoride Salts
Lead
Mercury
Molybdenum
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
February 13, 2007

130. Organic constituents 22 CCR §66261.24(a)(2)(B)
Aldrin
Chlordane
DDT,DDE, DDD
2,4-Dichlorophen
oxyacetic acid
Dieldren
Dioxin
(2,3,7,8-TCDD)
Endrin
Heptachlor
Kepone
Organic Lead Compounds
Lindane
Methoxychlor
Mirex
Pentachloro phenol
PCBs
Toxaphene
Trichloro-
ethylene
2,4,5-Tri-
chloro phenoxy-propionic acid
(Silvex)
February 13, 2007

131. Characteristic of Toxicity TCLP vs. WET
TCLP WET
Simulated landfill leachate
Acetic acid extractant
18 hour extraction
7 inorganic constituents
23 organic constituents
less aggressive for inorganic constituents
zero headspace extractor for volatile organic compounds
Simulated landfill leachate
Citric acid extractant
48 hour extraction
19 inorganic constituents
18 organic constituents
more aggressive for inorganic constituents
More organic compounds
February 13, 2007

132. Characteristic of Toxicity Comparing Total and WET or TCLP
One can guesstimate what the concentrations will be in the extracts from the WET and TCLP methods using the concentrations in the total digest.
February 13, 2007

133. Characteristic of Toxicity Comparing Total and WET or TCLP
WET uses a 10:1 ratio of solid sample (waste) to extractant fluid
TCLP uses a 20:1 ratio of solid sample (waste) to extractant fluid
February 13, 2007

134. Characteristic of Toxicity Comparing Total and WET or TCLP
If a substance in a waste were 100% soluble (in the extractant), then the maximum possible extract concentration would be:
WET: 1/10 the total concentration
TCLP: 1/20 the total concentration
February 13, 2007

135. Example 1
Total digest = 530 mg/kg lead concentration, the maximum soluble results would be
WET: 53 mg/l
TCLP: mg/l
Both federal and state soluble thresholds for lead are 5 mg/l
February 13, 2007

136. Example 2
Total digest = 53.0 mg/kg lead concentration, the maximum soluble results would be
WET: 5.3 mg/l
TCLP: mg/l
Both federal and state soluble thresholds for lead are 5 mg/l
February 13, 2007

137. Example 3
To proceed with the WET or TCLP (for a solid waste), the minimum total lead concentration (in the digest) needs to be
WET : 50 mg/kg
TCLP: 100 mg/kg
February 13, 2007

138. Acute Toxicity • Oral Toxicity • Dermal Toxicity • Inhalation Toxicity
• Acute Aquatic Toxicity
February 13, 2007

139. Acute Oral Toxicity 22 CCR §66261.24(a)(3)
Acute Oral LD50
the dose of a substance or mixture of substances, in milligrams per kilogram of test animal body weight, which, when administered orally as a single dose, produces death within 14 days in half of a group of 10 or more laboratory white rats.
February 13, 2007

140. Acute Oral Toxicity 22 CCR §66261.24(a)(3)
Waste is hazardous if oral LD502500 mg/kg (§ HSC)
February 13, 2007

141. Acute Oral Toxicity Exclusion HSC §25141.5
Wastes consisting of these substances are not hazardous wastes if they are only hazardous due to acute oral toxicity
acetic acid calcium fluoride
aluminum chloride calcium formate
ammonium bromide calcium propionate
ammonium sulfate cesium chloride
anisole magnesium chloride
boric acid potassium chloride
February 13, 2007

142. Acute Oral Toxicity Exclusion HSC §25141.5
Wastes consisting of these substances are not hazardous wastes if they are only hazardous due to acute oral toxicity
sodium bicarbonate food flavoring oils:
sodium borate allspice oil
decahydrate ceylon cinnamon oil
sodium carbonate clarified slurry oil
sodium chloride dill oils
sodium iodide lauryl leaf oils
sodium tetraborate
February 13, 2007

143. Acute Dermal Toxicity 22 CCR §66261.24(a)(4)
Acute dermal LD50
dose of a substance or mixture of substances, in milligrams per kilogram of test animal body weight, which, when applied continuously to the bare skin for 24 hours, produces death within 14 days in half of a group of 10 or more rabbits.
February 13, 2007

144. Acute Dermal Toxicity 22 CCR §66261.24(a)(4)
Waste is hazardous if dermal LD50 4300 mg/kg
February 13, 2007

145. Acute Inhalation Toxicity 22 CCR §66261.24(a)(5)
Acute inhalation LC50
concentration of a substance or mixture of substances in air, which when inhaled continuously for 8 hours by a group of 10 or more laboratory white rats produces death in half the group within 14 days.
February 13, 2007

146. Acute Inhalation Toxicity 22 CCR §66261.24(a)(5)
Waste is hazardous if inhalation LC50  10,000 ppm
February 13, 2007

147. Acute Toxicity
In many cases, toxicity data is available for pure chemical compounds found in wastes
Although not common, in theory a generator could perform an animal bioassay on their waste
February 13, 2007

148. Calculated Inhalation Toxicity 22 CCR §66261.24(b)
A waste mixture that contains one or more compounds that are acutely toxic (inhalation) can be shown to be nonhazardous
Measure headspace vapor concentration
Concentration in headspace must be less than its LC50 or LC LO
February 13, 2007

149. Calculated Oral or Dermal Toxicity 22 CCR §66261.24(c)
A waste mixture that contains one or more compounds that are acutely toxic (oral or dermal) can be calculated to be nonhazardous
100
Calculated LD50 =
n %Ax 
x=1 TAx
February 13, 2007

150. Calculated Oral or Dermal Toxicity 22 CCR §66261.24(c)
For the calculation, LD50 or LDLO values can be used
February 13, 2007

151. Calculated Oral or Dermal Toxicity 22 CCR §66261.24(c)
100
% chem 1 % chem 2 …
LD50 chem 1 LD50 chem 2
February 13, 2007

152. Aquatic Toxicity 22 CCR §66261.24(a)(6)
Also known as the “fish test”
LC50 Measured using:
fathead minnows
rainbow trout
golden shiners
Hazardous if 96-hour LC50500 mg/liter
February 13, 2007

153. Carcinogenicity 22 CCR §66261.24(a)(7)
List of 16 carcinogenic substances
Hazardous if present in a waste or material in single or combined concentration exceeding percent (10 ppm)
February 13, 2007

154. Carcinogenic Substances
2-acetylaminofluorene
acrylonitrile
4-aminodiphenyl
bzenzidine
bis(chloromethyl)ether
Methyl chloromethyl ether
1,2-dibromo-3-chloropropane
3,3-dichlorobenzidine
Dimethylaminoazoben-zene
ethyleneimine
alpha-naphthylamine
beta-naphthylamine
4-nitrobiphenyl
N-nitrosodimethylamine
beta-propiolactone
vinyl chloride
February 13, 2007

155. Experience or Testing 22 CCR §66261.24(a)(8)
Wastes shown through experience or testing to pose a hazard
The criteria were not expected to capture all possible wastes that could be hazardous
Use Best Professional Judgment
Now really only DTSC applied.
February 13, 2007

156. Experience or Testing 22 CCR §66261.24(a)(8)
DTSC is required to modify Chapter 11 if a waste is identified as hazardous using this section and has statewide application (§ HSC)
Examples: ethylene glycol (spent antifreeze)
Ethylene glycol hazardous per (a)(8) is not in title 22
February 13, 2007

157. Mixture Rule - Characteristic Wastes 22 CCR §66261.3(b)(4)
Wastes mixed with either a RCRA or a nonRCRA characteristic hazardous waste are hazardous waste only if the resulting mixture still exhibits a hazardous characteristic
Intentional mixture to avoid regulation is treatment, and requires authorization
February 13, 2007

158. Derived From Rule - Characteristic Wastes 22 CCR §66261.3(c)
Wastes derived from the treatment, storage or disposal of either a RCRA or a nonRCRA characteristic hazardous waste are hazardous waste only if the resulting waste still exhibits a hazardous characteristic
February 13, 2007

159. Skipped a step
February 13, 2007

160. What if a waste is not on one of the lists?
If a waste is not listed, the next step is to determine if the waste exhibits one of the characteristics of hazardous waste
February 13, 2007

161. Hazardous Waste Determination Procedure
Is the material a waste?
Is the material excluded or exempted?
Is the waste excluded or exempted?
Is the waste listed in Article 4 or 4.1?
Is the waste listed in Appendix X?
Does the waste exhibit a characteristic of hazardous waste?
February 13, 2007

162. What is Appendix X?
A tool for generators
February 13, 2007

163. Appendix X List of 791 chemicals
List of 66 common names or types of hazardous wastes
Characteristic of concern noted (X,C,I,R)
February 13, 2007

164. Appendix X List creates a “presumption”
Wastes listed in Appendix X or containing a listed chemical are presumed hazardous by characteristic
Can be classified as nonhazardous using testing or knowledge, as with other wastes
February 13, 2007

165. And another thing ….
February 13, 2007

166. Used Oil A waste can be hazardous by being “used oil,” or
By being contaminated with or containing used oil.
Its not in the HW regulations!
Does not have to exhibit a characteristic.
February 13, 2007

167. The Procedure Should Be:
Is the material a waste?
Is the material excluded or exempted?
Is the waste excluded or exempted?
Is the waste listed in Article 4 or 4.1?
Does the waste exhibit a characteristic of hazardous waste?
- Is the waste listed in Appendix X?
Is the waste “Used Oil” or
a material that contains “Used Oil”?
February 13, 2007

168. Part 5: Hazardous Waste Categories
22 CCR Article 5
Break?
February 13, 2007

169. Categories of Hazardous Wastes 22 CCR Article 5
RCRA Hazardous Wastes
NonRCRA Hazardous Wastes
Acutely Hazardous Wastes
Extremely Hazardous Wastes
Special Wastes
Universal Wastes
Others
February 13, 2007

170. Who cares about which category my waste fits into?
February 13, 2007

171. Proper Classification (categorization) of Hazardous Wastes is Necessary for:
Land disposal restrictions/treatment standards
Fees
Generator, Disposal
Hazardous waste management requirements
Universal Waste managment
DTSC discretionary authority
Variances, tiered permitting
February 13, 2007

172. RCRA Hazardous Wastes 22 CCR §66261.100
Not excluded from RCRA regulation
Listed (F,K,P,U lists)
Ignitable
Corrosive liquid
Reactive
Toxic (using TCLP)
Hazardous Wastes are presumed to be RCRA HWs unless determined otherwise
February 13, 2007

173. NonRCRA Hazardous Wastes 22 CCR §66261.101
Listed (M listed)
Corrosive solid
Toxic for anything except for federal toxicity [22 CCR § (a)(1)]
Excluded under 40 CFR 261.4
Container residues that are “RCRA-empty”
February 13, 2007

174. Acutely and Extremely Hazardous Wastes
Hazardous wastes that, if exposure were to occur, may likely result in death, disabling personal injury, or serious illness
Not only hazardous, but, are even more hazardous than ordinary hazardous wastes
February 13, 2007

175. Acutely and Extremely Hazardous Wastes
Acutely (Federal)
“P” listed
Extremely (State)
Criteria-based
Appendix X (asterisks)
February 13, 2007

176. Extremely Hazardous Waste Criteria 22 CCR §66261.110 & §66261.113
Acute toxicity
Carcinogenicity
Experience or testing
Water Reactivity
Persistent and bioaccumulative toxic subtances
February 13, 2007

177. Extremely Hazardous Waste Criteria 22 CCR §66261.110
Acute Oral Toxicity
22 CCR § (a)(1)
Extremely hazardous if LD50  50 mg/kg
Acute Dermal Toxicity
22 CCR § (a)(2)
Extremely hazardous if LD50  43 mg/kg
February 13, 2007

178. Extremely Hazardous Waste Criteria 22 CCR §66261.110
Acute Inhalation Toxicity
22 CCR § (a)(3)
Extremely hazardous if LC50  100 ppm
Carcinogenicity
22 CCR § (a)(4)
Same list of carcinogens
single or combined concentration equal to or exceeding 0.1 percent (1000 ppm)
February 13, 2007

179. Extremely Hazardous Waste Criteria 22 CCR §66261.110
Experience or Testing
22 CCR § (a)(5)
Like hazardous waste criteria, wastes shown through experience or testing to pose an extreme hazard
February 13, 2007

180. Extremely Hazardous Waste Criteria 22 CCR §66261.110
Water Reactive
22 CCR § (a)(6)
Like hazardous waste, narrative criteria
“When contacted by water, reacts violently, generating extreme heat, burning, exploding, or rapid reaction”
Calculated Acute Toxicity
22 CCR § (b)
Same equation as for hazardous waste
Water reactive not clearly defined in reg.
February 13, 2007

181. Extremely Hazardous Waste Criteria 22 CCR §66261.113
Persistent and Bioaccumulative Toxic Substances
Total concentrations only
List and TTLCs differ from hazardous waste TTLCs
February 13, 2007

182. Extremely Hazardous Persistent and Bioaccumulative Toxic Substances
Aldrin
Arsenic
Beryllium
Cadmium
Chlordane
2,4-D
Dieldrin
Dioxin (2,3,7,8-TCDD)
Endrin
Heptachlor
Kepone
Organic lead
Lindane
Mercury
Mirex
PCBs
Selenium
Thallium
Toxaphene
2,4,5-Trichlorophenoxy-propionic acid
February 13, 2007

183. Special Waste 22 CCR §66261.120 Subset of nonRCRA hazardous wastes
Typically used for large-volume wastes
NOT self implementing - a generator must apply to DTSC to receive special waste classification
Eligible to be managed according to less stringent standards (not automatic)
February 13, 2007

184. Special Waste Criteria 22 CCR §66261.122
Can be hazardous for only inorganic constituents
Constituent concentrations may exceed their respective STLCs or TTLCs
WET-soluble concentration (when expressed in mg/kg) cannot exceed its TTLC value
Note: multiply WET result by 10 and then compare to the TTLC.
For type ii wastes less than 10.
February 13, 2007

185. Special Waste Management 22 CCR §66261.126
Waste can go into Class III landfill
Landfill must have WDRs for special waste
Landfill operator must have a variance from DTSC
February 13, 2007

186. “Other Category” Universal Waste Not in Article 5
Reduced regulation to encourage proper management
Reverts back to HW at the “destination facility”
Scrap metal (skip?)
Silver-only wastes, bottom ashes from biomass
February 13, 2007

187. Hazardous Waste Determination Basics
Part 6: Miscellaneous Information
February 13, 2007

188. Waste Classification Options
Self-classify, and manage accordingly [§ (c)]
DTSC concurrence [§ (d)]
DTSC reclassification [§ (f)]
DTSC special waste (§ )
All DTSC determinations are subject to fee for service
February 13, 2007

189. Who determines whether a waste is a hazardous waste?
Generator’s responsibility to make determination
22 CCR § (c)
February 13, 2007

190. Hazardous Waste Determination 22 CCR §66262.11
How?
The information a waste generator may use to classify their waste falls into two categories:
Generator knowledge of materials and processes used
Analytical testing data
U.S> EPA generator knowledge is objective demonstrable facts.
Can’t shrug your shoulders.
February 13, 2007

191. Knowledge: any information that a generator finds that helps them to understand or anticipate their waste’s characteristics or properties.
February 13, 2007

192. Information = Knowledge
A generator may use anything known about the physical properties and characteristics of the waste in lieu of testing the waste.
February 13, 2007

193. Information about the waste generation activity
Information about the chemicals or ingredients in the process
Information about the quantities and concentrations of chemicals in the process
February 13, 2007

194. Analytical results from similar wastes
Industry studies
Internet/web searches
Multiple Business Locations
Hotline Information
Material Safety Data Sheets
February 13, 2007

195. Toxicity Data Information from chemical manufacturers On-line sources
TOXNET (
February 13, 2007

196. Can I classify my waste based entirely on knowledge? Yes
February 13, 2007

197. Use of “generator knowledge”
Address or rule out as many criteria as possible using "knowledge."
Analytical testing for any criteria for which information is not available.
February 13, 2007

198. Analytical Testing
What characteristics are expected (or cannot be ruled out through knowledge)?
What tests correspond to the hazardous waste criteria?
Sampling
February 13, 2007

199. To run a test, you’ll first need to take a sample of the waste
February 13, 2007

200. Sampling Considerations for sampling Purpose of sampling
Generator classification
Compliance verification/enforcement
Site investigation/characterization
February 13, 2007

201. Sampling 22 CCR § (c)
“Sampling and sample management of wastes and other materials for analysis and testing pursuant to this article shall be in accord with chapter nine of "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," SW‑846, Third Edition . . .”
February 13, 2007

202. Number of Samples
For formal petitions to DTSC, minimum of four samples required
Will always be a function of variability of waste and use of the data
February 13, 2007

203. A sample result above a threshold
Not Automatically Hazardous Waste
Depends
Statistically, you can expect some individual results to exceed the threshold
Take a closer look
February 13, 2007

204. A sample result below a threshold
Not Automatically Nonhazardous Waste
Depends
Statistically, for hazardous wastes you can expect some individual results to be below the threshold
Don’t discount outright
February 13, 2007

205. Part 7: SW-846
“Test Methods for Evaluating Solid Waste, Physical/Chemical Methods”
EPA Publication SW-846
[Third Edition, November 1986)
Updates I, II, IIA, IIB, III and IIIA
February 13, 2007

206. SW-846
Contains sampling and analysis methods related to hazardous waste regulations
Sample collection and sampling data considerations
Analytical methods for:
organic constituents
inorganic constituents
physical properties of wastes
waste characteristics
February 13, 2007

207. SW-846: Chapter Nine Sampling Plans Design Development Implementation
February 13, 2007

208. Basic Premise
Data from the testing of a sample is only as meaningful as the purpose for which the sample was collected
Data is meaningless if you don’t know what it represents
February 13, 2007

209. “Plan” for sampling
Know exactly what sample you need, why you’re taking it, and how to take it before you take the sample
February 13, 2007

210. Sampling Plan Design and Development
The level of detail and effort in planning for sampling is proportional to the importance of the use of the data
generators vs. inspectors
February 13, 2007

211. Regulatory and Scientific Objectives
Data to determine what, if anything, is present (unknowns)
Data to confirm the presence (or absence) of contaminants
Data to compare to criteria thresholds
February 13, 2007

212. Comparison to thresholds
For a generator to use their data to draw accurate conclusions about their waste, the data must “represent” the waste
Representative data comes from representative samples
February 13, 2007

213. Representative Sample
Sample that can be expected to exhibit the average properties of the whole waste
Not biased in any way
February 13, 2007

214. Fundamental Statistical Concepts
Need to predict the characteristics of the whole using data of a few samples
Accuracy
Precision
February 13, 2007

215. Sampling accuracy
How close the data from your sample(s) is to the true average properties of the waste
Better accuracy through random selection of a sample
February 13, 2007

216. Sampling precision The variability between results of sets of samples
Better precision by taking more samples, and by taking larger samples
February 13, 2007

217. Balance Accuracy/precision vs. Cost of sampling and analyses
The closer to the regulatory threshold, more accuracy and precision needed
February 13, 2007

218. Accuracy and precision measurements
Mean (average)
Standard deviation
Confidence interval
February 13, 2007

219. Mean Average Add up all values, divide by the number of values
February 13, 2007

220. Standard deviation
A measurement of the distance between the sample mean and the true mean
February 13, 2007

221. Confidence Interval
The range where you would expect to find the true mean
February 13, 2007

222. Confidence Interval
For regulatory purposes, the probability is specified as 80% (90% one-tail)
Unless demonstrated otherwise, assume “normal” distribution
February 13, 2007

223. Confidence Interval
The true mean has a 90% chance of being at or below the upper confidence limit
Only a 10% chance of being above it (only a 10% chance of being wrong)
February 13, 2007

224. Confidence Interval
If the upper confidence limit is at or above the threshold, the waste is hazardous
February 13, 2007

225. Basic Sampling Strategies
Probability
versus
Authoritative
February 13, 2007

226. Probability Sampling Simple Random Sampling Stratified Random Sampling
Systematic Random Sampling
February 13, 2007

227. Authoritative Sampling
Sample point selected by sampler
For classification purposes, validity of the data depends on knowledge of sampler
For classification, may raise more questions than it answers
February 13, 2007

228. Probability vs. Authoritative
Depends on how much you already know about the waste
Depends on how you want to use the data
February 13, 2007

229. Simple Random Sampling
Best approach if little or nothing is known about the waste
All parts of the waste have an equal chance of being selected
Avoids bias (conscious or unconscious)
February 13, 2007

230. Stratified Random Sampling
Necessary if there is some sort of regularly occurring or predictable strata in the waste
e.g. phase liquids (oil & water) or liquid with sludges
February 13, 2007

231. Systematic Random Sampling
Sampling points are based on one randomly selected point
e.g., timed intervals of a process stream
February 13, 2007

232. Additional Considerations
Waste Form
Solid or Liquid (or both)
Waste Accessibility
Piles
Containers, Tanks
Impoundments
Process stream
February 13, 2007

233. Composite Sampling Lose information about individual samples
May not be able to detect unknown waste variations
Analytical results are a pre-calculated “average”
Additional statistical analysis cannot be performed
February 13, 2007

234. Other sampling plan factors
Sampling equipment
Sample containers
Sample preservation
Chain-of-Custody
Health and Safety
February 13, 2007

235. The End? Charles Corcoran 916-327-4499 ccorcora@dtsc.ca.gov
February 13, 2007