FIELD IDENTIFICATION OF HAZARDOUS WASTE

by

Robert Carlson

There are four ways a waste can be hazardous under RCRA, the Resource Conservation & Recovery Act of 1976 (the “Cradle to Grave law”). A waste can be ignitable, corrosive, reactive, or toxic. There are also many “listed” wastes, which are more stringently regulated, but must meet one of the four “characteristics” just mentioned. This exercise will help you field-ID stuff in a quick and dirty way (what better way for a waste?).

First, realize that any residue, contaminated debris and soil, or liquids soaked up with your spill kit are almost certain to be RCRA hazardous; it’s easier and cheaper to treat them as such rather than making the labs rich. But what about stuff still in drums, totes, bags, etc., that were damaged in a spill, chill, or thrill? Most of that can’t be reclaimed and will have to go offsite for disposal. That’s where field ID comes in handy. Let’s look at those 4 characteristics one by one.

IGNITABILITY: Note that this is NOT the same as “flammability” because different flashpoints are used. EPA goes by <140°F (60°C) for liquids only. You won’t have a Pensky-Martens closed-cup flashpoint tester in the field. As one of my favorite TV chefs used to say, “use what you’ve got.” If a label is present, and you’re fairly sure that it accurately represents what’s currently inside the container, then if it says “Flammable” you know it’s less than 100 degrees. If it says “Combustible,” that’s between 100 and 200, so it might or might not be. If you have an MSDS, same thing.

For unknown materials, a reading on your CGI (combustible gas indicator), aka explosimeter or LEL meter, can help. If you get 10% or more, you’ve almost certainly got an ignitable (EPA Waste ID code D001). If anyone was unlucky enough to get a whiff of a spilled material (civilian, FF who hadn’t donned a mask yet) then even odors can indicate volatility and potential ignitability.

Solids which may combust through friction (shock-sensitives), absorption of moisture from the air (like boranes), or spontaneous decomposition, are also “ignitable.” Anything marked “unstable” on an MSDS is likely to meet this category. Also, these are likely to be DOT Hazard Class 4 materials: Spontaneously Combustible, Flammable Solid, or Dangerous When Wet. Class 5 Oxidizers and Organic Peroxides also meet the EPA definition, and Class 4 and 5 materials are also going to be D003 Reactive wastes…multiple characterizations.

CORROSIVITY: EPA & DOT use different criteria here. DOT goes by how fast a substance will eat through human skin (“bring me a stopwatch and the new kid!”) or through specified grades of steel or aluminum. EPA goes by a different grade of steel and a different rate (thanks, guys!), and no aluminum, but mainly goes by pH. If it’s an aqueous liquid (no mention of stuff dissolved in mineral oil), with a pH of less than or equal to (?) 2.0, a strong acid, or greater than or equal to (?) 12.5, a strong base, it’s a D002 corrosive. No guidelines on dry powder, which is as strong as a corrosive can ever get…get some of that on your sweaty skin and you’re running for the shower. Get a corrosive in your EYES, and you’ve got permanent tissue destruction; if you don’t have a bottle of eyewash in your pocket, kiss your peepers goodbye…that’s why splash goggles beat safety glasses, and why a face shield is a nice extra to have on.

PH paper or a pH meter can determine this with good accuracy. Remember that pH paper may be useless if you have color-blindness, and pH meters require rinsing and recalibration between each test. But it can still be done onscene.

REACTIVITY: This one’s a bit more difficult in the field. Anything unstable, or Class 4, or Class 5, will meet this one. Water-reactives (alkali metals sodium, potassium, rubidium, and cesium, other materials such as boranes) fit this description and are marked with the W with the line through it. Air-reactives like white phosphorous or triethyl aluminum go here. Materials which will “polymerize,” i.e. set up from liquid to solid due to age, temperature, or just plain unstable nature, releasing heat, pressure, and potentially toxic vapors are reactive (shown on the MSDS, and in DOT’s Emergency Response Guidebook as an ERG# WITH A “P” after it). For polymerization, think about that jar of honey sitting on your kitchen counter that has crystallized over time, and now you have to melt it in a pan of hot water…that’s slow polymerization.

Wastes which contain cyanides or sulfides fall under this category if they will release toxic vapors even at non-corrosive pH levels. Think about hydrogen cyanide (prussic acid in your Rust-Fix car body spray, gas chamber gas), or H2S, hydrogen sulfide found in landfills, sewage, etc. These materials should NEVER be stored anywhere near acids, so that’s staging step 1.

Also, DOT “forbidden,” Class A, or Class B explosives are D003 reactive hazardous wastes, even though DOT doesn’t really use those terms anymore…Class 1 Division 1.1 is Class A, 1.3 is Class B, and 1.2 can be either one.

Also be especially cognizant of the existence of shock-sensitive materials. We all know about nitroglycerin, but there are certain organic acids (picric is a favorite, or any picrate compound) which are stable when in liquid form, i.e. dissolved in water (aqueous) or sometimes, as stated above, in mineral oil because it doesn’t evaporate as readily, but extremely unstable when dried out. (See the photo of the picric explosion aftermath in my albums.) Anything in mineral oil can also be an air-reactive…that’s how they store white phosphorous.

Any container: drum, box, bag, with crystalline material on the outside or around a bung or other opening or seal is potentially shock sensitive and can result in a BFK. These are candidates for the use of remote puncturing devices, whether custom-made remote-controlled devices with bronze (non-sparking) spikes, or just using a .22 from upwind.

TOXICITY: There are many wastes EPA considers toxic, but most appear on one of the four “lists” of HW…we’ll get to that in a bit. The most common, though, appear here under this characteristic. There are three groups of chemicals here: the toxic heavy metals, the banned pesticides, and weak concentrations of industrial solvents, as in wastewater. It all has to do with how readily these materials will “leach” or dissolve and potentially contaminate water sources.

The metals are: arsenic, barium, cadmium, chromium, lead, mercury, selenium and silver. Welders get “metal fume fever” from working on painted steel surfaces…Ba, Cd, Cr, and Pb. Cadmium can exhibit delayed health effects and is especially nasty. Lead paint is everywhere. Silver is nice in jewelry but not in your bloodstream…there are companies that specialize in recycling the silver from X-ray equipment, the silver nitrate solutions and the Ag in scrap film. Metals, like cyanides, sulfides, and pesticides, do not like acids!! Keep them apart. My favorite industry to inspect, which had metals, acids, and cyanides all present, was electroplating shops. Think about that next time you look at your kid’s soccer trophy on the mantelpiece, in terms of what went into making it.

The banned pesticides are mostly cleaned up by now, but I still hear about containers showing up in someone’s garden shed at a place they just rented, or in grandma’s basement when she dies and the grandkids have to clean out the place. DDT isn’t even shown on the toxicity characteristic since it was banned 5 years before RCRA was passed, but we had a 55-gallon drum of it show up at a 1988 household hazardous waste collection!

The solvents are more importantly found in concentrated form at many facilities with paint booths, furniture refinishers, anyone with degreasers…everybody uses ‘em. But there you’re looking at F-listed wastes, and I’ll save the lists for another document. Suffice it to say that solvents are either ignitable, or when they aren’t, like the chlorinated ones (TCE, 111-TCA, methylene chloride, etc.) they’re very toxic. Mainly you’ll figure out if you’re dealing with TC wastes D004-D043 through type of business, processes, labels, paperwork, and from facility representatives. There are field test strips from manufacturers like JV that can test for metals, chlorine and other halogens, and petroleum distillates, among other materials…I’ll be posting a product review.

One place you may encounter banned pesticides (along with anything else, including “mystery materials” which may be unlabeled, in small containers, and very dangerous) is at laboratories, esp. ones out of business and abandoned. That’s a “lab-pack” job, and you want to work those with someone very experienced.