Hazardous under RCRA

TSCA controls on the manufacture and use of certain chemical substances also reduce the amount of waste that needs to be managed as hazardous under RCRA... 

A waste stream may be defined as hazardous under RCRA if it meets certain criteria for ignitability, corrosivity, reactivity, or toxicity, or if the waste stream is specifically identified by EPA as a hazardous waste. An individual waste stream is subject to being classified as hazardous (listed) if it contains any one of approximately 375 chemicals identified by EPA as hazardous constituents. These designated chemicals are frequently referred to as Appendix Vlll compounds because of where they are listed in the published regulation. 

All wastes classified as hazardous under RCRA, including properly treated toxic waste that is still considered hazardous, are intended for disposal in near-surface facilities regulated under Subtitle C of RCRA. EPA has developed detailed technical requirements on waste treatment and the siting, design, operation, and closure of disposal facilities. Thus, when viewed in relation to intended disposal technologies, there is basically only one class of hazardous chemical waste, regardless of the amounts of hazardous substances present i.e., a waste either is hazardous or it is not. 

Technical requirements on treatment and disposal of spent fuel, high-level waste, and transuranic waste established under AEA should be largely unaffected by the presence of waste classified as hazardous under RCRA Some of these wastes meet technology-based treatment standards for hazardous chemical waste established by EPA (e.gvitrified high-level waste is an acceptable waste form under RCRA). Alternatively, a finding that disposal of the radioactive component of the waste complies with applicable environmental standards established by EPA under AEA can serve to exempt the disposal facility from prohibitions on disposal of restricted hazardous chemical wastes under RCRA [e.g., disposal of mixed transuranic waste at the Waste Isolation Pilot Plant (WIPP)]. 

Issues of dual regulation also arise in management and disposal of waste that contains NAEM and waste classified as hazardous under RCRA. This type of waste is subject to dual regulation essentially because the definition of hazardous waste developed by EPA under RCRA (EPA, 1980b) does not include NARM waste (Section 4.2.1.2). Waste that contains NARM can be regulated under RCRA only if it is specifically included in the definition of hazardous waste, even though the exemption of radioactive materials defined in AEA from regulation under RCRA does not apply to NARM. 

In many respects, the system for classifying and managing hazardous chemical waste under RCRA makes no distinction between highly hazardous waste and virtually innocuous waste that contains very low levels of hazardous substances. Furthermore, many wastes that contain hazardous chemicals, as well as radionuclides not regulated under AEA, are excluded from the definition of hazardous waste based on the source of the waste, even though the excluded wastes can be just as hazardous as other wastes that are deemed hazardous under RCRA. 

The most commonly used action levels for determining whether a waste stream exhibits toxicity characteristic and therefore is hazardous under RCRA are the Toxicity Characteristics Leaching Procedure (TCLP) concentrations for 24 organic compounds, 6 pesticides, 2 herbicides, and 8 metals as described in 40 CFR Part 302. Appendix 3 presents a list of these compounds and their maximum TCLP concentrations, which are frequently referred to in project work. 

Permit required for underground injection of 2,3,7,8-TCDD containing wastes designated hazardous under RCRA Yes 40 CFR 144.1 EPA 1983a... 

Solid wastes are defined as hazardous under RCRA when they are included in one of the following lists (commonly referred to as listed wastes) ... 

Wastes defined as hazardous under RCRA include characteristic and listed wastes. An RCRA-defined hazardous waste is a waste that appears on one of four lists (F list, K list, U list, or P list) or exhibits at least one of four characteristics (ignitability, corrosivity, reactivity, or toxicity). Criteria for identifying characteristic hazardous wastes are included in Title 40, CFR part 261, subpart C. Listed wastes from industrial sources are itemized in 40 CFR part 261, subpart D. Other regulations that are relevant to the technology include the requirement to characterize the waste for a hazardous waste generator (40 CFR part 262.11), the requirement to determine if the hazardous waste is restricted from land disposal [40 CFR 268.7(a)], requirements for on-site storage of waste for up to 90 days [40 CFR 262.34(a)], or 40 CFR 264.553 for storage of waste in a temporary unit for up to 1 year prior to disposal. 

Metals-impacted soils Lead- and arsenic-impacted soils are the most commonly encountered metal-impacted soils. Leachabihty testing determines if a soil is considered hazardous under RCRA. By their nature, metals do not lend themselves to either thermal treatment or aeration, but they can be readily bound up in asphalt and concrete. Discussed below are various treatment technologies that have enabled the reuse of contaminated soils. 

If a waste is a listed hazardous waste, waste streams derived from treatment of that waste may also be deemed hazardous under RCRA s derived from rule. This is important because if CW agents treated in the EDS are listed hazardous wastes in a given state, then both neutralents and rinsates, which are derived from the treatment of the agents, may also be deemed hazardous wastes. In some states, regulations or permit language may, however, be structured so as to classify some derived-from waste as nonhsted. ... 

Hazardous wastes are either listed wastes (40 CFR 261.30-.33) or characteristic wastes (40 CFR 261.21-.24). The U.S. EPA defines four characteristics for hazardous waste ignitability (40 CFR 260.21) corrosivity (40 CFR 260.22) reactivity (40 CFR 260.23) and toxicity (40 CFR 260.24). Any waste that exhibits one or more of these characteristics is classified as hazardous under RCRA. The ignitability definition includes a liquid that has a flash point less than 60 C (140 F) the EPA included ignitability to identify wastes that could cause fires during transport, storage, or disposal (e.g., used solvents). All of the solvents in Table 14.10.5 have flashpoints less than 60 C, so all could be a RCRA ignitability waste. 

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