Waste Classification Session 1 Texas Commission On

Waste Classification Session 1 Texas Commission On
Waste Classification Presentation & Examples Texas Commission On Environmental Quality Environmental Trade Fair Austin Convention Center May 15, 2018 1:30pm – 2:30pm Sheila L. Meyers Waste Permits Division Industrial & Hazardous Waste Permits Section

Presentation Agenda Session 1 Session 2 1:30pm – 2:30pm
Introduction (Based on RG-022) Section I. Solid Waste Generator Notification Requirements Examples Section II. Solid Waste Categories: Hazardous Wastes and Industrial Wastes Introduction Section III. Texas Waste Code Assignments Examples Section IV. Universal Waste Section V. Hazardous Waste Recycling We will not be talking about Land Disposal Restrictions (LDR), SW Generator Improvement Rule

Session 1 & 2 Based Upon TCEQ Regulatory Guidance RG-022
Guidelines For The Classification And Coding of Industrial and Hazardous Wastes Rules are found in 30 Texas Administrative Code (TAC) Sections (§§) (Subchapter R).

Section I : Solid Waste Generator Notification Requirements
Chapter 6 in RG-22 page 16

Section I: Solid Waste Notification Requirements Covers 4 Topics
Waste Generators That Must Comply with 30 TAC 335 Subchapter R Industrial vs. Municipal Solid Waste Generators Generator Status Notification Requirements and Forms Examples

Topic 1: Waste Generators That Must Comply with 30 TAC §335 Subchapter R?
Topic 1 will help you identify which waste you much classify and code and when you must notify the TCEQ

Waste Generators That Must Comply With 30 TAC §335 Subchapter R?
Generators of industrial and hazardous solid wastes generated in Texas for treatment, storage and/or disposal (unless exempt); and Wastes generated outside of Texas and sent to Texas for treatment, storage and/or treatment. What are you complying with? Treatment Storage and Disposal (TSDs)

Waste Generators That Must Comply With 30 TAC §335 Subchapter R?
Regulatory Compliance Having each hazardous and non-industrial waste stream identified by an 8-character Texas waste code which gives information about its origin, general nature and hazardous status to ensure proper and safe disposal. Texas Waste Code will be discussed in Section III

Topic 2: Industrial VS. Municipal Generators
Why is this important? Because municipal nonhaz waste does not need to be coded.

Industrial VS. Municipal Generator
Whether to notify the TCEQ, and classify and code wastes, starts with knowing the differences between industrial wastes and municipal wastes and generator status.

Industrial VS. Municipal Generators
Industrial Wastes Industrial wastes result from (or incidental to) industry operations, manufacturing, mining or agriculture (e.g., power plants, manufacturing facilities, laboratories serving the industry and farms). Refer to the laminated handout for examples

Municipal Wastes Municipal wastes result from sources serving the public directly and do not involve manufacturing (i.e., hospitals, schools, churches, and auto shops.) Refer to the laminated handout for examples

In Summary Only generators of nonindustrial (municipal) and non-hazardous wastes, are excluded from requirements in 30 TAC Subchapter R.

Topic 3: Generator Status

Generator Status

Topic 4: Notification Requirements and Forms

Notification Requirements & Forms
Unless exempt, a generator must notify TCEQ no longer than 90-days after the wastes initial generation and before handling, shipment, or disposal using TCEQ form Notice of Registration or STEERS – the State of Texas Environmental Electronic Reporting System. If a generator is required to notify the TCEQ, a 5- digit Texas solid waste registration number will be assigned.

Exemptions For TCEQ/EPA Notice of Registration (NOR) and Assignment of the 8-Digit Waste Code Conditionally Exempt Small Quantify Generators (CESQG) unless the CESQG generates more than 220 lbs./month of Class 1. Universal waste handlers: Small quantify handler that never has more than 11,000 lbs., or 5000 kg, of universal waste on-site at any time. Generally speaking – Generators of only Class 2 and/or Class 3 wastes except if generated as the result of a “new chemical substance and you have not been given approval to verify the wastes classification

Noteworthy Information All Large quantity generators (LQGs) must use STEERS to update their NOR [(30 TAC §335.6(b)] and for the annual waste summary. If you are a CESQG and your records show that you generated over 220 lbs. (100kg) during a previous month, you would be considered as SQG for that month and subject to the hazardous waste management requirements for SQGs. This is also the same if you are a SQG, and exceed allowable generator quantities that make you a LQG.

Noteworthy Information Non-hazardous wastes shipped into Texas are automatically considered Class 1 unless: You request the TCEQ to review your waste classification supporting lower classification such as Class 2 or 3; and TCEQ concurs with lower classification.

How Do You Get Forms and/or Access STEERS? Notification forms can be accessed by the following: TCEQ Regional Office near you; then “Forms” link; TCEQ publications unit by fax – (512) , voice (512) ; STEERS then STEERS reporting or registration links

Need More Help? CONTACT Permitting and Registration Support Division Registration and Reporting Division Phone: (Queue) Ed Minter: (512)

Section I Exercises

Section I: Exercise 1

Section I: Exercise 2

Section I Answers

Section II: Solid Waste Categories
Hazardous Class 1 Section II: Solid Waste Categories Class 3 Class 2

Section II: Solid Waste Categories Covers 4 Topics
Solid Waste Definitions Making a Hazardous Waste Determination (Listed and Characteristic) Industrial Wastes Process Knowledge, Testing, and Documentation Examples

Topic 1: Solid Waste Definitions

Solid Waste Definitions
To Understand Compliance Better Let’s Introduce Some Terms: Solid Waste Hazardous Waste Industrial Waste

Solid Waste Definitions
What is a Solid Waste? 40 CFR Part 261.2 A material is a solid waste when it can no longer be used for its intended purpose and it will be disposed, reclaimed, or recycled. A solid waste can be hazardous, nonhazardous, industrial or municipal (nonindustrial).

Solid Waste Definition
What is a Hazardous Waste? Can be found in Title 40 Code of Federal Regulations (CFR), Part 261. Only materials that meet the definition of solid waste under RCRA can be classified as hazardous waste and are subject to more regulations. Known to be harmful or potentially harmful to human health or the environment.

Solid Waste Classes Hazardous Nonhazardous Industrial Listed Class1
F, K, P & U Characteristic Ignitability Reactivity Corrosivity Toxicity Nonhazardous Industrial Class1 Class 2 Class 3

Topic 2: Making a Hazardous Waste Determination (Listed and Characteristic)

Making a Hazardous Waste Determination
Classifying your waste is called “making a hazardous waste determination” in federal regulatory language. All waste generators should work through Part 1 of the RG checklist to determine if the waste is hazardous as defined by EPA. Page 4 in RG-22

Making a Hazardous Waste Determination Step #1 – Determine inventory of all wastes generated, also called waste streams. Overall flow of wastes from your ordinary operations or processes. Within this overall flow of waste, a number of particular waste streams may be identified. Covered in Chapter 2 or RG-022 Chapter 2 in RG-22 page 3

RG-022 Table 2-1, gives examples of some situations in which waste flow from an operation or process can produce more that one waste stream. Page 3

Example 1: Your process produces a hazardous acidic waste, and at some point you neutralize that waste. You now have two separate waste streams. Example 2: Dewatering of sludge may produce a solid waste stream and a liquid waste stream.

Step #2 – for each waste stream generated, recycled or reclaimed, determine if any are exempt wastes. Listings of exempt wastes can be found in 40 CFR §261.4 Discharged to the POTW or a permitted NPDES outfall Mining overburden Household Wastes Exclusions from SW regulation are listed in 40 CFR and 261.4

Step #3 – Determine if your waste is (1) a listed hazardous waste and/or (2) a characteristic hazardous waste. Listed wastes 264 Subpart D and Characteristic wastes in Subpart C.

Section 40 CFR specifies that the generator should first determine whether the solid waste is a listed waste. In addition to the generator determining whether the solid waste is or is not listed, the waste must still be evaluated to determine if the solid waste exhibits any one of four hazardous waste characteristics.

Be aware that a four-character hazardous waste code is assigned to each waste on these lists. This code is used for reporting and manifesting, and critical under the Land Disposal Restriction (LDR) regulations. This hazardous waste code is not part of the Texas Waste Code.

Listed Hazardous Wastes Listed hazardous wastes are determined to always be hazardous when generated. Listed wastes fall under four categories (F,K,P and U); Description of listed wastes found in 40 CFR Part 261 Subpart D, Section EPA Lists Over 400 Wastes as Hazardous A SW is haz if it appears on ay of 4 lists (FKPU)

Listed Hazardous Wastes
A listed waste is hazardous, not because of the concentration of the constituents, but because it meets a listing description on one of the four lists in the regulations. The primary criterion for applying the listed code to a waste is that you know the process that generated the waste. Appendix VII of Part 40 CFR Part 261 identifies the hazardous constituents contained within each group. Generators determine if they have listed wastes, primarily based on knowledge of the source of waste.

To indicate its reason for listing a waste, EPA assigns a hazard code to each waste listed in the F and K lists with the following explanations: (T) – Toxic Waste; (H) - Acute Hazardous Waste; (I) – Ignitable Waste; (C) – Corrosive Waste; (R) – Reactive Waste; and (E) – Toxicity Characteristic Waste 1st two - apply to listed wastes whose constituents pose an additional threat to human heath and environment Last 4 – apply to wastes that have been listed because they typically exhibit one of the 4 regulatory characteristics of hazardous waste.

There are 29-listed wastes solely because they exhibit the characteristic of Ignitability, corrosivity, and or reactivity (what is referred to as ICR-only listed wastes). At the federal level these 29 F-, K-, P- and U-waste are not hazardous if at the point of generation, they do not exhibit any characteristics.

F Listed Wastes from Non-Specific Sources (40 CFR )

F-Listings (F001-F-039) Contains 28 F coded wastes Manufacturing process wastes produced by a wide variety of industrial processes. Contains solvents commonly used in degreasing, metal treatment baths and sludges, wastewaters from metal plating operations, and dioxin containing chemicals and their precursors.

F-Listings (F001-F039) F001-F005 – Spent solvents F006-F019 – Electroplating or heat-treating operations F020-F023 and F026-F028 – Dioxins and dioxins precursors (very rare) F024 and F025 – Process wastes from production of chlorinated aliphatic hydrocarbons by free-radical catalyzed processes by organic chemical industry

F-Listings (F001-F039) F032, F034, and F035 – Wood preserving industry; F037 and F038 – Primary and secondary sludges primarily at petroleum refineries. These codes cover wastes not otherwise covered by K048-K052; and F039 – Multisource leachate produced at typically by landfills conducting land disposal of more than one listed hazardous waste.

F001-F005 Spent Solvents Initial RCRA regulations included five spent solvent listing because spent solvents were involved with more environmental damage that any other waste type (pure and technical grade). Spent solvents resulting from mixtures of the listed solvents were not regulated until January 1986. The five spent solvent listings each include specific solvents.

F001-F005 Spent Solvents F001 - Halogenated solvents used in large-scale industrial degreasing operations. Includes 5 specific solvents and chlorinated fluorocarbons (CFCs). However; CFCs used for refrigerants are not subject to this listing. F002 - Also halogenated solvents used other than large-scale industrial degreasing. Includes 9 specific solvents. Refer to page 6 in workbook.

F001-F005 Spent Solvents F Non-halogenated solvents listed only because they are ignitable. EPA defended F003 listing on the basis that the solvents are likely to contain other toxic contaminants such as toxic heavy metals or toxic organic compound and must be disposed, reprocessed or reclaimed. F004 - Wastes resulting from cresols, cresylic acid, or nitrobenzene for their solvent properties. These are listed due to their toxicity. F005 – Non-halogenated solvents listed for both toxicity and ignitability. The five spent solvent listings each include specific solvents. (Refer to handout)

F001-F005 Spent Solvents

Examples of common F-listed solvents Benzene, carbon tetrachloride, methylene chloride, tetrachloroethylene, 1,1,1-trichloroethane, acetone, chlorobenzene, CFC’s, cresols, MEK, methanol, xylene and toluene. Acetone, carbon tetrachloride (tetrachloromethane) and Toluene

K Listed Wastes From Industry-Specific Sources (40 CFR §261.32) 181 K - listings

K Listings Manufacturing process waste from specific industry sources make up the K-listed wastes in § This list is further subdivided into group of wastes based on industrial categories. Once the generator has identified his/her industry category, a check is made to see the wastes meet any of the K-listed descriptions. 181 K listings

K Listings Manufacturing process waste from specific industry sources make up the K-listed wastes in § This list is further subdivided into group of wastes based on industrial categories. Once the generator has identified his/her industry category, a check is made to see if the wastes meet any of the K-listed descriptions. The K descriptions are generally very specific and clear.

K Listings Note worthy information: 13 industries generate K listed wastes. If you are uncertain whether a particular K-waste listing applies, it is suggested you read EPA’s listing background document that the agency prepared for every F- and K-waste. Copies can be found online from by entering RCRA for F-listed listed wastes or RCRA for K-listed wastes in the search field.

K Listing Examples Wood preservation, pigment production, chemical production, petroleum refining, iron and steel production, explosive manufacturing, and pesticide manufacturing.

P & U Listed Wastes (40 CFR §261.33)

P (205) & U (411) Listings More mistakes are made by generators in identifying P- and U-wastes than any other type of listed hazardous waste. P-list and U-list wastes contain pure and commercial grade formulas of discarded chemical products, off-spec chemicals, container residues, and residues from chemical spills. P-list and U-list wastes differ in their degree of risk. P-listed wastes are “acutely toxic” meaning they possess extremely hazardous properties that make them lethal in very small quantities.

For a waste to be considered a P- or U-listed waste it must meet the following: The chemical in the waste must be unused; and The chemical must be in the form of a commercial chemical product (CCP).

For a waste to be considered a P- or U-listed waste it must meet the following:

Characteristically Hazardous Wastes
The regulations [§261.3(a)(2)(i)] specify that if a solid waste exhibits a characteristic (physical/chemical properties), it becomes it a hazard to human health or the environment and therefore is a hazardous waste. The four hazardous characteristics are ignitability, corrosivity, reactivity, and toxicity. Evaluating a SW to determine whether it exhibits any 4 of the haz waste characteristics must be answered regardless if it has already been evaluated for haz listed wastes. This is necessary to comply with the LDR (c).

Does the waste meet one of the four characteristics? Ignitable Wastes (D001) Corrosive Wastes (D002) Reactive Wastes (D003) Toxic Wastes (D004 – D043)

Ignitability (D001) A solid waste exhibits the characteristic of ignitability if a representative sample meets any of the following [ (a)]: It is a liquid with a flash point <140°F (excluded are aqueous solutions containing <24% alcohol by volume); It is nonliquid that 1) can ignite under STP (68°F and 1atm) through friction, moisture absorption, or spontaneous chemical changes, AND 2) burn vigorously and persistently after ignition; Courtesy of the alcohol beverage industries.

Ignitability (D001) A solid waste exhibits the characteristic of ignitability if a representative sample meets any of the following [ (a)]: It is an ignitable compressed gas that is 1) flammable when in a mixture of 13% or less of air or 2) has a flammable range with air of more than 12%; It is an oxidizer. These are chemicals that yield oxygen readily and stimulate combustion of organic matter.

Ignitability (D001) Noteworthy Information Liquids with a flash point <140°F make up most ignitable wastes. Flash point testing is only appropriate for liquid samples. Flash points <140°F were determined by EPA to be temperatures commonly encountered during routine storage and transportation conditions Flash point testing is only appropriate for liquid samples. If a solid FLASHES using a modification of the method, it may indicate there is contamination with ignitable volatiles but would still not be definitive for determining ignitability and will not be D001.

Ignitability (D001) Noteworthy Information Continued For liquids with both solid and liquid phase, the Paint Filter Liquids test may be used to determine the presence of free liquid. However the preferred method by EPA is the Pressure Filtration Technique specified in Method 1311 (TCLP). EPA has never finalized this proposal. 1st – Paint filter test dw B and then Pressure filtration.

Ignitability (D001) Noteworthy Information Continued TSD facilities and waste haulers may still require flash point data on certain waste solids that do not contain free liquids as a condition for transporting or accepting wastes. However, the DOO1 code would not have to applied to such solid wastes unless it meets the criteria for a non-liquid [§ (a)(2)] or is an oxidizer described in [§ (a)(2)]. (1) Almost all nonchlorinated solvents have a FP <140.

Ignitability (D001) Noteworthy Information Continued Setaflash Method (1020) is not applicable to liquid with nonfilterable suspended solids. However, the Pensky-Martens Method can be used for liquids that contain nonfilterable suspended solids. There is overlap between ignitable oxidizers (D001) and reactive oxidizers (D003). EPA states that an oxidizer that reacts violently should be considered D003 and mildly, D001.

Corrosivity (D002) A solid waste exhibits the corrosivity characteristic if a representative sample meets one of the following [§261.22(a)(1) and §261.22(a)(2)]: It is aqueous with a pH ≤2 or ≥12.5, as measured in SW-846 Method 9040C; and It is a liquid that corrodes SAE 1020 carbon steel at a rate >0.25 in/yr, as measured by SW-846 Method 1110A. The low-end pH level was set in large part to keep out of RCRA regulation soft drink and fruit drink industry for which the pH of many range from SAE – Society of Automotive Engineer.

Corrosivity (D002) Noteworthy Information Most corrosive solid wastes are aqueous with a pH ≤2 or ≥12.5. Since pH is a measurement of the dissociated hydrogen ion, a liquid solid waste should be at least 20% of the total volume of waste. This is according to SW-846 Method 9040C. If a sample of waste is mixed with a 1:1 ration of water and the pH is measured to be ≤2 or ≥12.5, it is corrosive at the state level. (Class 1 nonhazardous waste).

Corrosivity (D002) Noteworthy Information There are very few liquids that carry the D002 code because of the second criterion. (i.e., Ferric chloride will pass pH criterion but it can corrode a carbon steel drum at a rate > in/yr. Determining whether a solid waste has a liquid phase is identical to that used for ignitable waste (Paint filter test, and more definitively the pressure filtration technique specified in Method 1311).

Corrosivity (D002) Noteworthy Information There are no corrosive solids at the federal level. For a waste to be D002, it must be a liquid.

Reactivity (DOO3) A solid waste exhibits the reactivity characteristic if a representative sample of the waste meets one of the following [§261.23(a)]: Reacts violently with water; Normally unstable and readily undergoes violently change without detonating; Can form explosive mixtures with water; Produces toxic gas, vapors or fumes when mixed with water sufficient to present dangerous conditions for health and environment; 8 descripitons

Reactivity (D003) Cyanide and sulfide-bearing waste producing toxic gas, vapors or fumes when exposed to pH conditions between 2 and 12.5 in quantities present dangerous conditions for health and the environment; Detonation or explosive reaction if subjected to heat or initiating source; Can detonate or have explosive reaction or decomposition at standard temperature and pressure (STP); and 8. Explosive defined in 49 CFR

Reactivity (D003) Noteworthy Information At federal level no test methods specified as being appropriate for identifying D003 wastes but thresholds were determined (>250 mg of hydrogen cyanide (HCN) per kg or >500 mg of hydrogen sulfide (H2S). Most D003 wastes generated are reactive cyanides. Waste ammunitions up to 0.50 caliber are not considered reactive. Regulations of aerosol cans depends on the management method (i.e., punctured cans that are recycled and not regulated due to the scrap metal exemption.) [§261.1(c)(6)] and §261.6(a)(3)(ii)]. EPA is not concerned because most generators are aware, usually through process knowledge that their wastes has this characteristic and requires special handling. Can punturing

Reactivity (D003) Noteworthy Information Continued Except as specified in §261.6(d) the puncturing step would not be considered hazardous waste treatment requiring a permit if done in 90-day containers that are closed per § (a). If liquids from aerosol cans are recovered for: 1) repackaging and beneficial use or 2) legitimate recycling or reclamation, they are not solid wastes, and not subject to the RCRA Regulations. Additional advice for determining if a waste is reactive or not can be found by contacting EPA’s National Enforcement Investigation Center (NEIC in Denver, Colorado (303)

Toxicity (D004 – D043) A solid waste exhibits the toxicity characteristic if the method leachate from a representative sample (SW TCLP) contains any of the constituents equal to or greater than the concentration in 40 CFR § Table 1 (RG-22 page 6, Table 3-1). Many of these compounds are commonly found in industrial wastes (e.g., lead, mercury, benzene, methyl ethyl ketone, silver and vinyl chloride).

Toxicity (D004 – D043) Forty Toxicity Characteristic (TC) constituents are listed in § Table 1 and include six pesticides, eight heavy metals, and twenty-six solvents and other organic compounds.

Toxicity (D004 – D043) Regulatory Basis Regulatory level concentrations are based on EPA research and modeling (late 1970s) of worse-case hazardous waste mismanagement scenarios: the co-disposal of industrial waste, containing toxic constituents, with municipal solid waste (MSW) in an unlined actively decomposing MSW landfill that produces weak organic acids capable of leaching the toxic constituents from the industrial wastes. The landfill model included homes nearby and an aquifer used as a source of drinking water.

Toxicity (D004 – D043) Regulatory Basis The EPA concluded through modeling that hazardous constituents would be diluted and attenuated by a factor of 100 in the subsurface. This factor of 100 was applied to the groundwater protection standards identified in the National Interim Primary Drinking Water Standards (NIPDWS) promulgated under the Safe Drinking Water Act (SDWA).

Toxicity (D004 – D043) Regulatory Basis For example: the health-based SDWA level for lead is mg/L. If lead leaches out of an industrial waste and its concentration is greater than 5.0 mg/L, the concentration of lead in an underlying aquifer will exceed the SDWA standard (including factoring in the dilution and attenuation effects of subsurface as lead passed through it), and the water would not be safe to drink.

Toxicity (D004 – D043) (TCLP) SW-846 Method 1311 A 100-gram representative sample (after lab separates any liquid (> 0.5 % filterable solids) is extracted (leached) by adding acetic acid in an amount equal to 20 times as much, by weight, as the weight of the solids portion of the sample. The extraction vessel holding the solids and acid is tumbled for 18-hours, followed by filtration to collect the leachate. If compatible this is mixed with the liquid initially separated. The leachate is ready to be analyzed for concentration of the 40 constituents.

Toxicity (D004 – D043) Rule-of-20 - Total Waste Analysis in Lieu of TCLP Results A generator can alternatively use total waste analyses to determine that a waste does not exhibit the TC. Each total constituent concentration is divided by 20, which is the 20 – 1 weight ratio of extraction fluid to solid in the TCLP. In other words, the totals value must be less than 20x the TCLP regulatory value for the solid not to exhibit the toxicity characteristic. A generator can alternatively use total waste analyses to determine that a waste does not exhibit TC.

Toxicity (D004 – D043) Rule-of-20 - Total Waste Analysis in Lieu of TCLP Results The Rule-of-20 can be used to prove that a material is not a TC hazardous waste but cannot definitively say that it is hazardous waste, and therefore is useful as a screen to determine when the TCLP is necessary.

Toxicity (D004 – D043) TCLP Testing Rule of 20 For example – the TCLP limit for lead is 5.0 ppm. If a total analysis is conducted on a solid sample and the test result is less that 100 ppm, then the sample cannot be hazardous for TCLP lead. If the sample result if greater than 100 ppm, the TCLP test must be run, or the waste must be managed as a hazardous waste.

Toxicity (D004 – D043) Noteworthy Information A generator cannot always rely on chemical composition data on safety data sheets (SDSs) alone for determining whether a waste exhibits the toxicity characteristic. OSHA regulations generally require manufacturers to identify constituents present in the material at concentrations ≥1% (10,000 ppm) for noncarcinogens or ≥ 0.1% (1,000 ppm) for carcinogenic constituents. In other words, the material may contain TC constituents above RCRA regulatory levels even though they are not identified on the SDSs. What is SDS VS. MSDS? The SDS is the international form of the MSDS and is published in only 1 format. The main purpose of the switch from MSDS to SDS is to create a simpler and more effective way to communicate the hazards of a chemical. OSHA criteria 2012

Toxicity (D004 – D043) Noteworthy Information Continued Exemptions – These wastes will fail TC but may not be subject to hazardous waste regulations: Trivalent chromium only - applies to leather tanning and finishing industry and wastewater treatment sludge from a titanium tank. [§261.4(b)(6)]; Petroleum-contaminated media and debris resulting from cleanup of petroleum underground storage tanks (USTs). [§261.4(b)(10)];

Toxicity (D004 – D043) Noteworthy Information Continued Exemptions Continued – These wastes will fail TC but may not be subject to hazardous waste regulations: Used chlorofluorocarbon refrigerants only if the CFCs (includes HCFCs but not hydrofluorocarbons) will be reclaimed for reuse. [§261.4(b)(12)]; Scrap metal that is recycled. [§261.4(a)(3)(ii)]; and Polychlorinated byphenyls (PCBs) dielectric fluids and the electrical equipment. [(§261.8)].

Topic 3: Industrial Wastes

Industrial Wastes Industrial Waste Categories See Laminated Handout
Texas has created categories of industrial wastes (Class 1, 2, and 3), with Class 1 considered to be potentially threatening to human heath and the environment. Industrial wastes, by definition, are nonhazardous.

Industrial Wastes Class 1
Wastes that leach Class 1 toxic constituents at or above the levels listed in Table 1, Appendix 1 of 30 TAC Chapter 335 Subchapter R when subjected to TCLP. Class 1 Toxic Constituents Maximum Leachable Concentrations are in Appendix C of RG-022. Liquids with a flash point ≥ 140 °F and less than 150°F. Contains polychlorobyphenyls (PCBs) >50 ppm; RG-22 page 33 (metals added are antimony (1ppm), beryllium (0.08ppm) and nickel (70ppm)

Industrial Wastes Class 1 Continued
Contain total petroleum hydrocarbons (TPH) > 1,500 ppm; Regulated asbestos containing materials (RACM); Solids or semi-solids that when mixed with an equivalent amount of ASTM water, produce a solution with a pH ≤ 2.0 or ≥ 12.5. RACM, as defined in 40 CFR Part 61

Any industrial waste that is neither hazardous, Class 1, or Class 3 industrial waste. Empty containers ≤ 5 gallons; Empty containers > 5 gallons, all residues removed (RCRA empty) and rendered unusable; Waste contaminated with < 50 ppm PCBs Waste contaminated with < 1,500 ppm TPH Liquid waste with a flash point > 65.6° (150°F).

Industrial Wastes Class 3 Not a hazardous or Class 1 waste
Chemically inert Cannot be a liquid Does not decompose Essentially insoluble [See 30 TAC § (4)]

7-Day Distilled Water Leaching Test 30 TAC Chapter 335 Subchapter R Appendix 4 RG-022 Appendix F 1 liter of deionized/distilled water added to 250 gram solid sample in flask. 7 days later, filtered leachate may be tested by appropriate analysis.

Topic 4: Process Knowledge, Testing, and Documentation

Process Knowledge, Testing, and Documentation
Now That You Know How to Classify Your Waste, What’s Next? You will need to compile supporting documentation. Regulations on document requirements found in 30 TAC Sections §§335.9 – , and You must keep the documentation for at least 3-years after the waste is no longer generated, stored or recycled...

Compiling Supporting Documentation Process Knowledge Title 30 TAC § provides for the use of process knowledge to classify a generator’s waste.

Compiling Supporting Documentation Process Knowledge A full description of the generator’s manufacturing process, and comprehensive list of chemicals involved in the process. Material Safety Sheets (MSDS). Manufacturer’s literature about the chemicals used in industry processes. Identification of potential contaminants.

Process Knowledge, Testing and Documentation
Compiling Supporting Documentation Analytical Testing Criteria: TCEQ Accredited laboratory (TNI) Standards; Chain-of-Custody – quantity; preservation, dates of sample collection etc.; Detection limits and/or quantitation limits; and Known and acceptable quality of data to support classification.

Compiling Supporting Documentation Analytical Testing Criteria Continued Sampling Plan - number, type and location for a representative sample Description of site and/or unit from which samples was taken Chain-of-Custody – quantity, preservation, dates of sample collection etc.

TCEQ Quarterly Audits Common Deficiencies Not analyzing for 3 Class 1 metals (antimony, beryllium and nickel) No chain-of-custody Missing quality assurance/quality control data Material in contact with TPH, but no TPH analysis.

Accreditation Questions? Laboratories are assessed against the provisions of The NELAC INSTITUTE (TNI) Standards Rules found in 30 TAC Chapter 25 (Environmental Laboratory Accreditation and Certification Monitoring Division – Laboratory and Quality Assurance Section: Laboratory Accreditation, Frank Jamison (512)

Section II Exercises

Listed Waste Exercises

Municipal, F002, No

No – can only have one active ingredient

Characteristic Waste Exercises
1. Municipal, 2. yes (see laminated handout) chromium (D007) (see slide 83), 3. No CESQG 4. No. limit.

1. Industrial 2. Yes, Cadmium (D006), Chromium (D007) and lead D Yes, not enough information. 4. Yes days

1. Industrial 2. A No, B Yes, yes for Ignitability D A would be Class 1 4. Yes 5. Haz yes 6. A no limit, B 180 days (maybe 270)

1. Municipal 2. Yes D No, no corrosive solids at EPA level. 4. No, but still could be corrosive for steel, not enough information 5. only the hazardous waste

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How to Contact Us Texas Commission on Environmental Quality Industrial & Hazardous Waste Permits Section MC-130 * P. O. Box * Austin, TX Phone: (Queue) Fax: In conclusion, we provide the following contact information: mail should be sent to TCEQ, Industrial and Hazardous Waste Permits Section, mail code 130, P.O. Box 13087, Austin, Texas Thank you.

Technical Analysis Group (TAG)
The End! Scott Green, Tess Johnston, Jesse Boltinghouse & Sheila Meyers Technical Analysis Group (TAG) Industrial & Hazardous Waste Permits Section Waste Permits Division All questions from today’s presentation may be addressed by contacting me.

Waste Classification Session 1 Texas Commission On

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