RTI Testing Capabilities
RTI has developed internal methods in conjunction with the applicable referenced testing methods for determining characteristics in waste samples. The laboratory has instrumentation and procedures that have undergone the method validation process and are capable of meeting the guidelines in the reference methods. RTI has processed aqueous and solid samples through the extraction and analytical procedures, performed demonstration of method performance, determined detection limits, quantification limits, assessed the accuracy and precision of the procedures and have developed standard operating procedures for the analysis of characteristics of hazardous waste.
Waste Characterization: Applications for Testing
Unknown waste materials that have not been listed due to their nature must be characterized to determine if that waste will be considered as hazardous or non-hazardous. The classification of the waste will determine the appropriate means for disposal. Costs and effort will be dependent on the nature of the waste and will generally be greater for material classified as hazardous. The concern for adequately determining whether a particular solid waste is hazardous or non-hazardous requires testing procedures capable of accurately determining the characteristics of the waste. Laboratory procedures must be rigorous and capable of adequately determining the characteristics of the waste sample.
Waste Characterization Testing Procedures
With the exception of the characteristic of reactivity the hazardous waste characteristics can be determined in the laboratory by the following procedures. Methods are cited in “Test Methods for Evaluating Solid Waste, Physical/Chemical Methods”, EPA Publication SW-846.
Ignitability – EPA Method 1010A with ASTM Standards D93-79 and D93-80 incorporated by reference.
Corrosivity – EPA Method 9040C and 9045D or EPA Method 1110A
Reactivity – Due to concerns for the unreliability of data, EPA has withdrawn the former testing methods for cyanide and sulfide reactivity. There are currently no laboratory methods cited in the regulations for assessing solid waste for reactivity.
Toxicity – Solid waste is extracted according to the procedures specified in EPA Method 1311. The extract is prepared according to strict adherence with the procedure specified in the method. Toxicity Characteristic Leaching Procedure (TCLP) extracts are analyzed for individual contaminants by methods.
- Metals: EPA 3020A, 6010D or 6020B
- Mercury: EPA 7470A
- Volatile Organic Compounds: EPA 8260B
- Semi-Volatile Organic Compounds: EPA 3510C, 8270D
- Organochlorine Pesticides: EPA 3510C, 8081B
- Chlorinated Herbicides: EPA 8151A
Hazardous Waste Characteristics
A solid waste not specifically listed as a hazardous waste from non-specific or specific sources or otherwise excluded by statute is considered as hazardous if it meets one or more of the following characteristics as defined in 40 CFR Part 261 Subpart C.
- Characteristic of Ignitability
- A defined liquid with a flash point <60oC
- A non-liquid that burns when ignited as defined
- An ignitable compressed gas as defined
- Characteristic of Corrosivity
- Aqueous with a pH <2 or >12.5
- Liquid that corrodes steel at >6.35mm/y
- Characteristic of Reactivity
- Unstable and readily undergoes violent change without detonating
- Reacts violently with water
- Generates toxic gases when mixed with water.
- A cyanide or sulfide waste that on exposure to pH conditions between 2 and 12.5 can generate toxic gases.
- Is capable of detonation or explosive reaction if subjected to a strong initiating source or if heated under confinement.
- Is readily capable of detonation, explosive decomposition or reaction at standard temperature and pressure
- Toxicity Characteristics
- A solid waste when extracted according to procedures defined in EPA SW-846 produces an extract that contains listed contaminants above the Regulatory Level cited in the regulation.
Hazardous Waste Regulation - Resource Conservation and Recovery Act (RCRA)
Background of RCRA
The Resource Conservation and Recovery Act (RCRA) was enacted as federal law in 1976 and constitutes the primary means for regulating waste materials. The intent of the Act was to address the management of municipal and industrial waste and provide authority to the Environmental Protection Agency (EPA) to define and regulate hazardous waste. EPA has published regulations in Title 40 of the Code of Federal Regulations, Parts 239-282. The goals of the RCRA program were designed to:
- Provide regulations for cradle to grave management of hazardous waste by specifying the practices for the storage, transport and disposal of hazardous waste.
- Ensure the protection of human health and the environment.
- Increase energy and resource conservation, reduce the amount of generated waste and prevent the release of hazardous material into the environment.
- Provide recommendations and guidelines for managing non-hazardous waste.
- Regulate Underground Storage Tanks (UST).
Environmental and Health Impacts
Prior to RCRA the unregulated disposal of industrial waste resulted in several instances of potentially severe impacts on the health of both humans and the environment. Toxic chemicals from leaking containers were having deleterious effects on organisms and flora.
Uncontained and inadequately resolved spills of hazardous substances resulted in human exposure and ecological impacts. Scientific data was determining a cause and effect relationship between the anthropogenic release of chemicals into the environment and undesirable consequences. The apparent inadequacy of previous waste management practices resulted in a re-evaluation of the waste management system and eventual passage of RCRA.
Managing and Defining Hazardous Waste
The key tenet of the RCRA program is the cradle-to-grave approach to managing hazardous waste materials. Within the EPA regulations are requirements governing the identification of hazardous waste at the point of generation. Specific waste streams and types of waste are identified in the regulations as inherently hazardous by their nature. Other wastes are assessed according to the definition of the Characteristics of Hazardous Waste. Once identified the generator maintains responsibility for the waste through the entire life of the waste from generation to disposal. The waster generator is responsible for ensuring the waste is properly transported to a certified treatment, storage and disposal facility (TSDF). The management of the waste throughout the process of generation to disposal is documented on Uniform Waste Manifest forms.
EPA has promulgated regulations for identification of hazardous waste, manifest documentation, regulation of TSDF facilities and oversight of the efficacy of disposal.