Table 1. TCLP regulatory limits.

1 40 em june material into the surrounding applies to both liquid and solid wastes, as well asmixed wastes. Any mixture involving characteristic wastes isa hazardous waste if the mixture exhibits one of the fourcharacteristics noted above. Additionally, for the purposesof applying the toxicity characteristic to such mixtures, themixture is also defined as hazardous if it exceeds the maxi-mum concentration for any contaminant that would not havebeen exceeded if mixing had not occurred or if the wastecontinues to exceed the maximum concentration for anycontaminant prior to METALSI ncluded in Table 1 are eight metals, commonly referred toas the RCRA metals. These metals are naturally occurring,at various concentrations, in the environment.

2 However,because of their uses in manufactured material, they areemwaste 101 Last month s column looked at currentdevelopments in the definition of solid waste. This month,we switch back to the topic of what can cause solid waste tobe classified as hazardous waste specifically, wastes that aredetermined to be hazardous because they possess uniqueand measurable properties or characteristics . Four hazardouswaste characteristics are specified under the Environmen-tal Protection Agency s (EPA) Resource Conservation andRecovery Act (RCRA), Subpart C: ignitability, corrosivity, toxicity , and reactivity. A brief overview of characteristic wasteswas presented in February s Waste 101 column and the charac-teristics of ignitability and corrosivity were addressed in Marchand April, respectively.

3 This month, we focus on defined in 40 CFR , a solid waste except manu-factured gas plant waste exhibits the characteristic of toxic -ity if, using EPA s toxicity Characteristic Leaching Procedure( tclp ) Test Method 1311, the extract from a representativesample of the waste contains any of the contaminants listed inTable 1 at the concentration equal to or greater than the re-spective value given in that Table . Where the waste contains lessthan filterable solids, the waste itself, after filtering usingthe methodology outlined in Method 1311, is considered to bethe extract. It is important to note that the toxic level valueshown in Table 1 is not the concentration of the substance inthe sampled material, but the concentration after the sampleis extracted, as specified in the tclp procedure.

4 The tclp test is designed to replicate conditions that could be presentin a landfill and, thus, lead to constituents leaching from theTable 1. tclp regulatory CodeCAS NumberToxic Level(mg/L) CresolsaD026 , , , , , (and its epoxide) Ethyl ,4,5-Trichlorophenol ,4,6-Trichlorophenol ,4,5-TP (Silvex) o-, m-, and p-cresols cannot be individually measured, the regulatory level fortotal cresols is used. Tip: EPA identifies solid wastes exhibiting thecharacteristic of toxicity with a specific D code,ranging from D004 2006 Air & Waste Management 2006 em 41emsometimes found at sufficient levels that when the materialor product becomes a waste and is subjected to the tclp test, it results in a hazardous waste eight RCRA metals and their common uses arelisted below.

5 Arsenic has been used as a medicinal agent, apigment, a pesticide, and an agent of criminalintent. Arsenic is primarily used in the productionof glass and semiconductors. It is also found incertain water supplies and seafood. Arsenic isreleased into the environment by the smeltingprocess of copper, zinc, and lead, as well asthrough chemicals manufacturing. Other sourcesare paints and wood preservatives. Barium compounds are used in small quantities inpaints and in glassmaking. Cadmium is used in plating metals and is soluble in acidic foods like fruit juicesand vinegar. Chromium is used in steel-making, electroplating,leather tanning, and as a radiator anti-rust inhibitor. Lead is found in storage batteries, pottery glaze,rubber, brass alloys, plastic beads coated with lead,ashes and fumes from burning old painted wood,newspapers, magazines, and artists paint pig-ments.

6 Lead is also used for cable coverings,plumbing, ammunition, and fuel additives. Otheruses are in plastics, X-ray shielding, crystal glassproduction, pencils, and pesticides. Mercury is used in the manufacture of thermom-eters, felt, paints, explosives, lamps, electricalapparatus, and batteries. Diethyl and dimethylmercury compounds are used in treating seeds. Selenium is primarily used in the electronicsindustry, but it is also used as a nutritional supple-ment. It is used in the glass industry; as a compo-nent of pigments in plastics, paints, enamels, inks,and rubber; in the preparation of pharmaceuti-cals; as a nutritional feed additive for poultry andlivestock; in pesticide formulations; in rubberproduction; as an ingredient in antidandruffshampoos; and as a constituent of fungicides.

7 Silver is used in jewelry, coins, and recent years, discarded electronic devices often referredto as e-wastes have emerged as a major source of toxicwaste because of the increasing volume of waste that theyrepresent and the fact that a significant portion of this wastestream is classified as hazardous because of the presence ofreadily leachable RCRA metals. Recent studies have shownthat several electronic components would be classified ashazardous because they exceed tclp toxicity of a chemical substance is a measure of itsability to cause injury to a biologic tissue. For many chemi-cal substances, the toxic effects observed from a singleexposure may be quite different from that of repeatedexposure.

8 To help prevent and minimize this exposure, a solidwaste that exhibits the characteristic of toxicity should alwaysbe managed properly as a hazardous waste, as required byEPA. Be sure to also check your state and local laws becausethey may be different from the federal requirements. Remem-ber, the primary objective of hazardous waste regulation isthe protection of human health and the month s column will round out the discussion oncharacteristic wastes with a look at month s column is contributed by Kim Stoker,environmental manager, CPS Energy, San Antonio, TX, andDan Mueller, founding partner, The Mueller ConsultingGroup, Plano, TX. E-mail: of E-Wastes Exceeding tclp Limits 100% of laptop computers 100% of remote controls 90% of video cassette recorders (VCRs) 78% of smoke detectors 77% of cell phones 70% of color cathode ray tubes (CRTs) 56% of printersReform School:Understanding the Changing Worldof New Source Review (NSR) Updated Workshop SeriesVisit for more rules are evolving, and so is one of A&WMA's most popular Fundamentals of NSR Workshop Series is getting a facelift.

9 With theeverchanging world of NSR being one of the most complex issues today,and reform being the subject that you want to know about please joinus for a highly interactive two-day event. This workshop will: Show where each version of the rule applies; Explain the basics of the major NSR permit requirements (BACT, LAER, etc.); Discuss the applicability criteria for each version of the rule, allowingyou to determine whether major NSR applies to a project; Update you on the latest enforcement initiatives, settlement agreements,and court decisions; and Provide an idea of what's in store for NSR rules and programs in thenear you are involved in NSR permitting, this is the training you need to keepabreast of the latest , FL September 21-22, 2006 Copyright 2006 Air & Waste Management Associatio