Household hazardous Waste and RCRA sulfuric waste

BEM 3701, Hazardous Waste Management 1

Course Learning Outcomes for Unit II Upon completion of this unit, students should be able to:

3. Describe various types of hazardous wastes, their impact on the environment, and respective environmental control and public health remedies.

4. Evaluate relevant regulatory compliance requirements in the industrial environment.

6. Describe hazardous waste characteristics, pathways in the environment, and toxicological

impacts.

Reading Assignment Chapter 4: Characterization of Solid Waste, pp. 75-78 Chapter 11: Identification of Hazardous Waste

Unit Lesson Household Hazardous Waste The term hazardous waste conjures images of industrial discharges and barrels full of toxic sludge. However, hazardous waste is generated at the rate of about 1.6 million tons per year in leafy green suburbs, rural areas, and city dwellings across America (North Dakota Solid Waste and Recycling Association, 2013). If you look into most garages, you will find a plethora of hazardous wastes such as old batteries, solvents, used motor oil, and pesticides. Because household hazardous waste (HHW) is not regulated under the Resource Conservation and Recovery Act (RCRA), it is difficult to estimate how much HHW is released into the environment. Many communities have HHW collections on a regular basis so that the materials can be disposed of in a safe manner. However, some HHW is disposed of with other municipal solid waste, and some is dumped on land, poured down drains, or released into water bodies. Lead, cadmium, mercury, and a variety of toxic organic compounds can be found in HHW. Therefore, it is important that individuals and communities take steps to ensure the proper disposal of HHW. There are several ways that the human health and environmental impact of HHW can be reduced.

 First, consumers should read labels and be aware of the chemicals that are in their household products and follow proper storage and usage guidelines.

 Second, consumers should use less toxic products when possible. In many cases, a less toxic product will work just as well, and disposal will be easier, safer, healthier, and more environmentally friendly.

 Lastly, in those cases where a hazardous product is necessary, consumers should take advantage of local HHW collections to ensure proper disposal.

Regulations A brief introduction to the numbering and abbreviations you will see as you read Chapter 11 will help you to better understand how RCRA regulates hazardous waste. You will see 40 CFR frequently in reference to environmental regulations. This stands for Title 40, Code of Federal Regulations. The Code of Federal

UNIT II STUDY GUIDE

Identification of Hazardous Waste and Household Hazardous Waste

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Regulations (CFR) contains all of the federal final regulations. Title 40 is the section of the CFR that deals with the protection of the environment. Under 40 CFR, there are 13 parts, which are listed on page 356, Table 11.1, of your textbook, that deal with the implementation of RCRA. You can find the CFR at http://www.gpo.gov/fdsys/browse/collectionCfr.action?collectionCode=CFR. The optional learning activity in this unit will take you through a few exercises to learn where you can find these regulations in the CFR. Completing the learning activity will help you to become more comfortable with the source of the RCRA information you will read throughout the course. Identification of Hazardous Waste There is a variety of wastes that are generated by industries, and determining which are hazardous can be a complicated endeavor. To be regulated under RCRA as a hazardous waste, a waste must first meet the definition of a solid waste. This definition can be found in 40 CFR 261.2. If the waste is a solid waste, it may still not be regulated under RCRA if it is specifically excluded. The waste is regulated under RCRA if it is a listed waste or is corrosive, reactive, ignitable, or toxic. Some hazardous materials are recycled. In some cases, the recycling process results in a material that is no longer a solid waste and therefore not hazardous under RCRA. The recycled material may still be a solid waste subject to RCRA, but it might be subject to less strict regulatory requirements. There are three ways in which a waste can be recycled that exempts it from the definition of solid waste. First, if waste is used as an ingredient in a process without being reclaimed, then it is not considered a solid waste. A waste is reclaimed when it undergoes a process to remove contaminants and render the material useful again. Second, if the material is substituted for another without being reclaimed, it is also exempt. Lastly, if the waste is reused in a process, it is not considered a solid waste. By allowing these exemptions, RCRA encourages the recycling of waste where possible (Environmental Protection Agency, n.d.). However, there are certain ways of recycling that present risk to human health and the environment, and when these methods are used, the waste is considered a solid waste, and potentially subject to RCRA. First, the waste is considered solid waste if it is used on land in a way that constitutes disposal. For example, as we discussed in Unit I, waste was added to oil and sprayed on the road in Love Canal. This type of use would be regulated under RCRA. Second, if the waste is burned for energy, used to produce fuel, or contained in a fuel, it cannot be exempt. Third, if the material is stored for longer than a year without at least 75% of the material being recycled, the material is being “accumulated speculatively,” according to RCRA. In other words, a facility cannot store a waste for a long period of time just to avoid having to properly dispose of the waste under RCRA. Lastly, if a waste contains dioxin, it is considered “inherently waste-like” and is automatically considered a solid waste, even if it is recycled (Environmental Protection Agency, n.d.). Some wastes are excluded from the definition of hazardous waste under RCRA. There are five main exclusions. The waste can be excluded because it is considered exempt from the definition of solid waste. For example, radioactive waste is not considered a solid waste. It is regulated by the Nuclear Regulatory Commission or the Department of Energy. The waste can also be excluded because it is exempt from the definition of hazardous waste. An example of this exclusion is household hazardous waste. Regulating every household in America would be impossible, so these wastes are not regulated under Subtitle C. There are exclusions for waste generated in raw material, the storage of products, or manufacturing units. There are also exclusions of laboratory samples and waste treatability studies. The last category of exclusions is for dredged material that is regulated under the Marine Protection Research Act or the Clean Water Act. Once it has been concluded that a waste is a solid waste, we must determine whether is also considered hazardous. There are four lists containing materials that are toxic enough to human health and the environment that they are fully regulated under RCRA. The F-list contains wastes from a variety of processes, so they are known as nonspecific wastes. Some examples of F-list wastes are spent solvents and wood preserving wastes. The K-list contains wastes from specific industries, such as pesticide manufacturing and petroleum refining. Finally, the P-list and the U-list both contain chemicals in pure or commercial-grade form that are unused. Once these chemicals are thrown away, they are considered hazardous wastes. Certain pesticides fall into this category. Whether or not the waste is listed, it must also be determined whether or not the waste displays one of the four hazardous characteristics (ignitability, corrosivity, reactivity, and toxicity). If the waste is both listed and displays a hazardous waste characteristic, there may be additional RCRA regulations that apply (Environmental Protection Agency, n.d.).

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There are a few additional regulatory conventions that should be considered when evaluating a waste. RCRA contains a mixture rule. One situation in which this rule applies is when a facility produces a mixture of a nonhazardous solid waste and a listed hazardous waste. Such a mixture, with any proportion of a listed hazardous waste, must be regulated as if it were the listed waste (unless the facility goes through a process to delist the waste). Another situation in which the mixture rule would apply is a mixture of a nonhazardous solid waste and a characteristic waste. In this case, the mixture is only considered hazardous if the mixture exhibits a characteristic itself (Pichtel, 2014). As you can see, the process of determining if a material is regulated as a hazardous waste under RCRA can be fairly complex. In one of your Unit II Assessments, you will use a helpful tool that the EPA provides to clarify the process.

References

Environmental Protection Agency. (n.d.). Hazardous waste identification. Retrieved from http://www.epa.gov/solidwaste/inforesources/pubs/orientat/rom31.pdf

North Dakota Solid Waste and Recycling Association. (2013). Household hazardous waste definition.

Retrieved from http://www.ndswra.org/dnn/HouseholdHazardousWaste/DefinitionofHouseholdHazardousWaste.aspx

Pichtel, J. (2014). Waste management practices: Municipal, hazardous, and industrial (2nd ed.). Boca Raton,

FL: CRC Press.

Suggested Reading Explore this site to learn more about how to determine what is a hazardous waste. Environmental Protection Agency. (n.d.). Hazardous waste identification. Retrieved from

http://www.epa.gov/solidwaste/inforesources/pubs/orientat/rom31.pdf

Learning Activities (Non-Graded) In order for you to see the connection between the text discussion of the regulations and where you can find the actual regulations, navigate to http://www.gpo.gov/fdsys/browse/collectionCfr.action?collectionCode=CFR and perform the following steps:

1. Select the year from the dropdown list. 2. Locate Title 40 – Protection of Environment. If you do not see it in the list, go back one year. There is

an update schedule and Title 40 is revised (if there were changes made to Title 40) and listed for the year on July 1st of every year.

3. After you have found Title 40 – Protection of Environment, click it to expand. 4. Then click Chapter 1 – Environmental Protection Agency (Continued) (Parts 1-1099) to expand the

list. You will see the parts indicated in parentheses at the end of each subchapter. You can choose any part from Table 11.1 and find that regulation in the CFR.

5. Although the number of parts and subparts can seem overwhelming, spend some time exploring the origin of the parts covered in your textbook.

Non-graded learning activities are provided to aid students in their course of study. You do not have to submit them. If you have questions, review your reading materials or contact your instructor for further guidance and information.