Introduction
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The quiz is to help you get a practical grasp on the RCRA definition of acute hazardous waste as it applies to wastes that may show up in higher education. Each of the following may be an acute or non-acute RCRA hazardous waste. Try to guess before you look at the answer.
- Q1. A sealed jar of potassium cyanide
-
Acute hazardous waste (P106). We start with an easy one!
- Q2. A sealed jar of potassium ferrocyanide
-
This is not AHW. In fact it is not a regulated
waste under RCRA rules. The designation
“Cyanides (soluble cyanide salts), not otherwise specified” (P030) applies only to
soluble cyanide compounds that will release hydrogen cyanide gas (HCN) when subjected to acid
conditions or are themselves highly
toxic.[1]
“Acid conditions” include minimum
pH of 2 and do not include elevated temperature. Potassium ferrocyanide doesn’t fall into
this group.[2],
[3]
If you don’t believe this, remember that the pH in your stomach is often
2 or less and the oral toxicity of potassium ferrocyanide is less than one one-thousandth
that of potassium cyanide.
Note: Although not subject to RCRA rules, ferrocyanide and ferricyanide complexes may liberate HCN when subjected to sunlight, thermal decomposition or other conditions outside the range of RCRA test requirements. - Q3. A jar of professional jeweler’s metal polish that contains cyanide, collected from the art department
- It is a mixture of materials with more than one active ingredient, so it is not AHW.[4] In addition, the metal polish does not have the generic name “cyanide” or any other name on the P list.[5] It meets the definition of D003 (reactive) because it will release HCN under acid conditions.
- Q4. Unused cyanide-based silver electroplating solution from the art department
- Like the metal polish, it is a mixture of ingredients and will probably meet the definition of D003. If the material had been used, it would be F007. It is not AHW.
- Q5. Used cyanide-based silver electroplating solution from the art department
- This meets the definition of F007, “Spent cyanide plating baths from electroplating operations.” F007 carries a reactive notation so this waste need not be identified as D003. It is not AHW. Note that the only difference from the preceding example is that the material in this example was used for a purpose.
- Q6. An unused package of gopher poison containing 2 percent zinc phosphide
- The only active ingredient is zinc phosphide and it is unused but the concentration is below the ten percent lower limit specified on the P list. Therefore, it is not AHW.
- Q7. Discarded samples from the electron microscope lab that were fixed with osmium tetroxide
- The material you receive has been used for a purpose. Therefore, it is not AHW.
- Q8. An unused mixture of methyl parathion and toxaphene prepared for use as a broad spectrum pesticide
-
It has more than one active ingredient, so it is not
AHW.[8] However, it will probably be
D015. If it is in a solvent carrier, it may also be D001 (ignitable).
- Q9. An unused mixture of aldrin and dieldrin that has occurred because dieldrin is a decomposition product of aldrin
- In this case, the material started out with the name “aldrin” and the dieldrin was not added. Therefore, this is identified as aldrin and will be listed as P004. It is AHW because of its origin, even though it has become a mixture of active ingredients.[6]
- Q10. A discarded P list pesticide that contains formaldehyde as a preservative and propane as a propellant.
- Preservatives, propellants, solvents and fillers are not considered active ingredients because they have no pesticidal function, therefore, the material is AHW.[7], [8]
- Q11. A new container of methyl hydrazine
- It is AHW (P068).
- Q12. Spill absorbent if the previous container spilled in the laboratory
-
This is also AHW (P068) with the same comments as the previous item. The rule refers to residues
“...resulting from the cleanup of a spill into or on any land or water...” but
EPA has interpreted this to apply to all spills,
wherever they occur.[9]
The good news is that if you know
the original quantity of methyl hydrazine, only that amount applies to your monthly AHW
quantity determination.[10]
If you do not know the exact quantity spilled, but can reasonably argue that the quantity was less
than the one quart threshold for Large Quantity Generator status, you can also avoid
LQG status if the total amount of spill cleanup
material is less than 100
kg.[11]
Document your reasoning in case an inspector challenges the information.
- Q13. Methyl hydrazine that has been used as a solvent, but is still 90 percent pure
- It has been used for a purpose, so it is not AHW.[12] It will almost certainly be D001.
- Q14. Spill cleanup residue if you spill the used methyl hydrazine
- The cleanup residue is not AHW because the original material was not AHW. The cleanup material will be hazardous waste if it shows any characteristic of hazardous waste. D001 is likely for this example.
- Q15. Unused pentachlorophenol formulation for treating wood discarded by the paint shop
- This is AHW (F027). It is one of the six acute hazardous wastes that do not appear on the P list. The others are F020–F023 and F026.
- Q16. A container of thiophenol after all of the contents have been poured into another container
- The container is P014 until it has been triple-rinsed with an appropriate solvent (or equivalent cleaning). After triple-rinsing, the container is empty and no longer subject to RCRA.[13]
- Q17. What about the rinsate from the triple rinse mentioned in the previous example?
- It is AHW because of the mixture rule.[14]
- Q18. What if you give the above container a fourth rinse?
- If you perform additional rinsing beyond a triple rinse, you are rinsing an “empty” container. The additional rinsate is not AHW, regardless of the solvent used, because it has been used for a purpose. However, the additional rinsate will be non-acute RCRA regulated waste if it shows a characteristic of hazardous waste or if the used solvent is a listed hazardous waste.[15] It may fall on the D or F lists respectively. Local sewer disposal rules may also apply.
