15
• Knowledge of products, byproducts, and intermediates produced by the manufacturing
process;
• Chemical or physical characterization of wastes;
• Information on the chemical and physical properties of the chemicals used or produced
by the processor or otherwise contained in the waste;
• Testing that illustrates the properties of the waste; or
• Other reliable and relevant information about the properties of the waste or its
constituents.
Your process knowledge can also account for situations that include startups, shutdowns, upsets,
and malfunctions.
Additionally, RCRA regulations require that some characteristics, such as ignitability, undergo a
specific test. When properly performed and compared with regulatory thresholds, the results of
that test are definitive for determining whether the waste is hazardous. The tests specified by the
regulations are available in EPA’s Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods, EPA Publication SW-846.
Appendix A provides a table of listed solvents that may be characteristically hazardous.
Definition of “Characteristic Hazardous Waste”
A RCRA characteristic hazardous waste is a solid waste that exhibits at least one of four characteristics defined
in 40 CFR 261, subpart C
. These hazardous waste characteristics are:
• Ignitable (EPA Hazardous Waste No. D001) wastes can create fires under certain conditions, can
spontaneously combust, or have a flash point less than 60 °C (140 °F). These wastes can be liquids, solids,
compressed gas, or oxidizers. A waste exhibits the characteristic of ignitability if it is a liquid, other than an
aqueous solution, containing less than 24 percent alcohol by volume and has flash point less than 60 °C (140
°F). An ignitable solid can cause fire through friction, absorption of moisture, or spontaneous chemical
changes. It creates a hazard by burning vigorously and persistently under standard temperature and pressure.
See 40 CFR section 261.21
for a complete set of criteria and lists of applicable test methods.
• Corrosive (EPA Hazardous Waste No. D002) wastes are aqueous-based acids or bases (pH less than or equal
to 2, or greater than or equal to 12.5) and/or liquids that can corrode steel, such as storage tanks, drums, and
barrels, based on a specific test method. Battery acid is an example of a corrosive hazardous waste. See
40
CFR section 261.22 for a complete set of criteria and lists of applicable test methods.
• Reactive (EPA Hazardous Waste No. D003) wastes are normally unstable and readily undergo violent
change without detonating. They react violently or form potentially explosive mixtures with water. When
mixed with water, reactive wastes generate toxic gases, vapors, or fumes that present a danger to human
health or the environment. They are also cyanide- or sulfide-bearing wastes that can generate toxic gases,
vapors, or fumes that present a danger to human health or the environment. These wastes are capable of
detonation or explosive reaction, or are certain forbidden explosives. For more details, see
40 CFR section
261.23. The rules do not currently identify any specific test methods regarding these properties.
• Toxic (EPA Hazardous Waste Nos. D004–D043) wastes are harmful or fatal when ingested or absorbed.
Examples include eight metals (D004–D011); cancelled pesticides (D012–D017); and toxic organics (D018–
D043), including 12 with solvent applications. When toxic wastes are land-disposed, the contaminated
material may leach and pollute ground water. Toxicity is defined through a laboratory procedure called the
Toxicity Characteristic Leaching Procedure (TCLP) Method 1311
. The TCLP helps identify wastes likely to
leach concentrations of contaminants that may be harmful to human health or the environment. For more
details, see
40 CFR section 261.24.