SESSION 10
RCRA HAZARDOUS WASTE
IDENTIFICATION:
Special Regulatory Conventions
1
Introduction
Derived-from Rule
Contained-in Policy
Review
Agenda: Special Regulatory Conventions
Mixture Rule
As-generated Wastes
2
(HWID) process
Derived-from rule
As-generated wastes listed solely for
ignitability, corrosivity, and reactivity
(I, C, R)
Contained-in policy
There are special regulatory conventions to
consider in the hazardous waste identification
Mixture rule
Introduction
• This Session addresses:
»
how mixtures effect a wastes status as hazardous,
»
the status of residues of treated hazardous waste,
» as-generated wastes listed solely for the ignitability, corrosivity, and
reactivity characteristics, and
»
the “contained-in” policy.
3
Introduction
Without special regulatory conventions some
wastes might get out of regulation
Questions often arise if hazardous waste really is
hazardous, for example:
– Is waste identified as hazardous always hazardous?
– Can hazardous waste be mixed with other wastes and
become nonhazardous?
– If the waste is treated to modify its chemical composition, is it
still regulated as hazardous?
• Every facility has elaborate processes and steps to produce their product that
causes different wastes to be generated along the way.
• As these wastes are generated, industries may collect them in various
fashions, sometimes:
» These methods can cause different wastes to be mixed;
» Residuals may be generated during the management or treatment of
waste.
• The regulated community needed to know how to look at their waste as they
are managed throughout the process.
• These types of issues would leave “loopholes” in the regulations, that the
regulated community in trying to cut waste management costs may try to
take advantage of to “get their waste out” of RCRA regulation...
4
Introduction
Two important regulatory conventions are the
mixture and derived-from rules
The mixture rule governs mixtures of hazardous