3. Reactivity, or
The second way to tell if a waste is hazardous is if it is included on a specific list of wastes EPA has determined are hazardous. These “listed wastes” are placed on a list because EPA finds them to pose substantial present or potential hazards to human health or the environment.
In order to identify solid wastes as either “characteristic hazardous waste” or “listed hazardous waste,” EPA conducts a more specific assessment of a particular waste or category of wastes. The Agency will categorize a solid waste as hazardous if it meets criteria set out in the regulations.
For example, EPA may determine that a solid waste is hazardous if the waste:
- Exhibits any of the hazardous waste characteristics, i.e., ignitability, corrosivity, reactivity, or toxicity;
- Is “acutely” hazardous (e.g., if it is fatal to humans or animals at low doses, 40 CFR 261.11(a)(2)); or
- Contains any of the toxic constituents listed in 40 CFR part 261, Appendix VIII and, after consideration of various factors described in the regulation, is capable of posing a “substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed” (40 CFR 261.11(a)(3)).
EPA will place a substance on the list of hazardous constituents in Appendix VIII if scientific studies have shown the substance has toxic effects on humans or other life forms.
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4 Lists of Hazardous Wastes
There are four different lists of hazardous wastes in the regulations:
- The F list (non-specific source wastes) – The F list designates as hazardous particular solid wastes from certain industrial or manufacturing processes. Because the processes producing these wastes can occur in different sectors of industry, the F list wastes are known as wastes from nonspecific sources. Wastes included on the F list are found in the regulations at 40 CFR 261.31.
- The K list (source-specific wastes) – The K list designates particular solid wastes from certain specific industries as hazardous. Wastes included on the K list are found in the regulations at 40 CFR 261.32.
- The P list and the U list (discarded commercial chemical products) – These two lists are similar in that both list as hazardous certain commercial chemical products when they are discarded or intended to be discarded. These listings consist of commercial chemical products having the generic names listed, off-specification species, container residues, and spill residues. The difference is that the chemicals on the P list are identified as acute hazardous wastes and those on the U list are identified as toxic wastes. Some chemicals on both lists may also be designated to have other properties. Wastes included on the P and U lists can be found in the regulations at 40 CFR 261.33.
These four lists each designate anywhere from 30 to a few hundred wastestreams as hazardous. Each waste on the lists is assigned a waste code consisting of the letter associated with the list followed by three numbers. For example, the wastes on the F list are assigned the waste codes F001, F002, and so on. These waste codes are an important part of the RCRA regulatory system. Assigning the correct waste code to a waste has important implications for the management standards that apply to the waste.
The wastes on the F and K lists can be divided further into subgroups.
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F Waste Groupings
It may be helpful to consider that the wastes on the F list are divided into seven subgroups, generally depending on the type of manufacturing or industrial operation that creates them. The seven general subgroups of F-listed wastes are:
- Spent solvent wastes (F001 – F005)
- Wastes from electroplating and other metal finishing operations (F006 – F012, and
- Dioxin bearing wastes (F020 – F023 and F026 – F028)
- Wastes from production of certain chlorinated aliphatic hydrocarbons (F024 and
- Wastes from wood preserving (F032, F034, and F035)
- Petroleum refinery wastewater treatment sludges (F037 and F038)
- Multisource leachate (F039)
K Waste Groupings
The wastes on the K list are divided into 13 subgroups of wastes from specific sources. The 13 subgroups of K-listed wastes are:
- Wood preservation (K001)
- Inorganic pigment manufacturing (K002 – K008)
- Organic chemicals manufacturing (K009 – K011, K013 – K030, K083, K085, K093 – K096, K103 – K105, K107 – K118, K136, K149 – K151, K156 – K159, K161, K174 – K175, and K181)
- Inorganic chemicals manufacturing (K071, K073, K106, and K176 – K178)
- Pesticides manufacturing (K031 – K043, K097 – K099, K123 – K126, and K131 – K132)
- Explosives manufacturing (K044 – K047)
- Petroleum refining (K048 – K052, and K169 – K172)
- Iron and steel production (K061 and K062)
- Primary aluminum production (K088)
- Secondary lead processing (K069 and K100)
- Veterinary pharmaceuticals manufacturing (K084 and K101 – K102)
- Ink formulation (K086)
- Coking (K060, K141 – K145, and K147 – K148)
See tomorrow’s Advisor for some frequently asked questions about listed wastes.