GLOBAL
ENVIRONMENTAL ASSURANCE INC.

HAZARDOUS WASTE IDENTIFICATION

Characteristic Wastes - see also: Listed WastesWaste with one or more hazardous characteristics, as determined by testing or by generator knowledge:

Ignitability – EPA waste code D001 applies if the waste is:

• Liquid with flashpoint less than 140° F. (60° C), or
• Non-liquid, can cause fire by friction, absorption of moisture or spontaneous chemical changes AND, when ignited burns so vigorously and persistently that it causes a hazard, or
• Flammable gas, or
• Oxidizer (Note : Having the same waste code does not imply chemical compatibility. Oxidizers must never be mixed with other D001 wastes.)

Corrosivity – EPA waste code D002 applies if the waste is:

• Aqueous (water-based) with pH < 2.0 or pH > 12.5, or
• Liquid and corrodes steel at > 0.25 inch / year, at 55 C.

Reactivity – EPA waste code D003 applies if the waste is:

• Unstable and readily undergoes violent change without detonating, or
• Water reactive, reacting violently with water, or
• Capable of forming toxic gases or vapors or explosive mixtures when combined with water, or
• Cyanide or sulfide containing material capable of releasing dangerous amounts of poisonous gas when mixed with corrosives, or
• Capable of detonation or explosive decomposition, or is a D.O.T. “forbidden”, Class A, or Class B explosive.

Toxicity – EPA waste codes D004 – D043, based on TCLP results.

Testing versus Generator Knowledge: Whether or not a waste exhibits a hazardous characteristic is determined by testing, using EPA methods, or by “generator knowledge”, supported by Material Safety Data Sheets, process description and flow diagram, etc. Generator knowledge is more likely to be challenged when asserting the waste is not regulated or that specific waste codes do not apply. A generator is always free to assert that his waste is hazardous.

This summary is offered for the use of GLOBAL customers is intended to answer common questions asked by generators. It does not address all possible regulatory situations and is not meant to constitute legal advice.