DSHW-2024-006638

Hazardous Waste
Determination 2024
Resource Conservation and Recovery Act (RCRA)
Federal Hazardous and Solid
Waste Amendments of 1984
Generator Improvement Rule Pharmaceutical Rule
Generation, transportation, treatment, storage, and disposal of
hazardous waste.
Hazardous waste generators must manage
the waste as hazardous waste until lab
results say otherwise.
Hazardous waste generators must make a
new waste determination if the waste
changes composition.
Hazardous waste generators must include
records explaining knowledge basis for
waste determinations.
Hazardous
Waste
Determination
Must be
accurate
GENERATOR
MUST MAINTAIN
RECORDS
Must be made
at point of
generation
The Hazardous Waste Identification Process
Considered inherently
waste-like
Discarded, abandoned,
disposed of, burned, or
incinerated
Any solid, liquid, semi-solid sludge,
or contained gas that is…
RCRA Solid Waste is…
Used,
reused, or
reclaimed
Excluded from RCRA
See Utah Administrative Code R315-261 -4 for the full list of exclusions
INDUSTRIAL
WASTE
DISCHARGES
SUBJECT TO THE
CLEAN WATER
ACT
RCRA Solid Waste Exclusions
HAZARDOUS
SECONDARY
MATERIAL
RECLAIMED
AND REUSED IN
THE ORIGINAL
PROCESS
DOMESTIC
SEWAGE
HOUSEHOLD
HAZARDOUS
WASTE
IN-SITU MINING,
EXCLUDED SCRAP
METAL, SOLVENT-
CONTAMINATED
WIPES THAT ARE
SENT FOR
CLEANING AND
REUSE ETC.
KNOWLEDGE ANALYSIS
Two ways to conduct a hazardous waste
determination
UNDERSTAND
THE PROCESSTRADE
ASSOCIATION
KNOWLEDGE MUST BE CORRECT AND
DOCUMENTED
SAFETY
DATA SHEET CONCENTRATEDDILUTION CONTAMINANTS
KNOWLEDGE
ANALYSIS MUST BE DOCUMENTED
Toxic
Characteristic
Leaching
Procedure
(TCLP)
ANALYSIS
Total
Metals
Analysis
INDUSTRIAL WASTE PROFILE
Volatiles,
flashpoint,
oil &
grease, pH
Pesticide,
Herbicide,
PCBs etc.
https://www.epa.gov/epcra/consolidated-list-lists
A waste solid or gas that is
capable, under standard
temperature and pressure,
of causing fire through
friction, absorption of
moisture, or chemical
changes and, when ignited
creates a hazard.
KNOWLEDGE MUST BE CORRECT AND
DOCUMENTED
Waste liquid
with a flashpoint
<140 oF
Some
DOT
Oxidizers
Ignitability R315-261 -21
Ignitable
compressed
gas
Waste Code D001
Aqueous with a pH less
than or equal to 2 or
greater than or equal to
12.5
Liquid that corrodes steel
at a rate of greater than
0.25 inches per year
KNOWLEDGE MUST BE CORRECT AND
DOCUMENTED
Corrosivity R315-261 -22
Waste Code D002
Waste material reactive to
water, shock, heat, or
pressure and undergoes a
rapid, chemical reaction, or
generates toxic gases.
Material that is normally
unstable
KNOWLEDGE MUST BE CORRECT AND
DOCUMENTED
Reactivity R315-261 -23
Generates toxic
gases, fumes, or
vapors
Waste Code D003
Pesticides/Herbicides
KNOWLEDGE MUST BE CORRECT AND
DOCUMENTED
Heavy Metals Organic Chemicals
Toxicity R315-261 -24
Waste Codes D004 through D043
Waste
Determination
Exercise
Carbon Tetrachloride in Grease
CAS No. 56-23-5
Is it a solid
waste?
●We are disposing of
it, so we know that it
is spent.
●Even if we can
recycle it, it is still
considered a solid
waste.
●So, is it hazardous?
Is the waste
excluded or
exempt?
●It did not come from
domestic sewage or from a
household.
●It is not an industrial
discharge subject to the
Clean Water Act.
●It is not from mining, not a
scrap metal, and not a rag.
●Conclusion, not excluded or
exempt.
Is the waste
a listed
hazardous
waste?
●Check the regulations
UAC R315-261-30
through R315-261-35.
●UAC R315-261-31(a)
Table 2 F001,
specifically names
carbon tetrachloride as
a spent halogenated
solvent used in
degreasing.
Is the waste a
characteristic
hazardous
waste?
●On the SDS there is no
flashpoint.
Not ignitable.
●It is not corrosive, but there
is 25% carbon tetrachloride,
and we know that from the
process it wasn’t diluted.
Table 1 of R315-262-24
Carbon Tetrachloride is specified
with waste code D019.
You have made an accurate waste
determination. You have appropriately
contained the hazardous waste, stored it,
labeled it, regularly inspected it, and it is
now geing close to the deadline to have
the waste osite.
What now?
Hazardous
Waste Profile
Shipper containment type
Estimated Shipping Frequency
Base
Oil
Paints
SolventS
tSDF
pH
Ignitability
How was it created?
Odors
Get expert help
totAl WASte
AnAlYSIS
RCRAInfo
A national program management
and inventory system of
hazardous waste handlers
Find Treatment, Storage, and
Disposal Facilities
Find compliance and cleanup
activities
hps://rcrainfo.epa.gov
Sally Kaiser
Environmental Engineer
[phone]
[e-mail]