About Jenyfer Johnson Expertise I can answer your questions concerning RCRA hazardous waste regulations, their interpretation and application, hazardous waste management, including shipments off-site. I can also dicuss military munitions questions you may have in the RCRA area.
Experience I've worked civil service for the Navy (3-4 yrs environmental) and Air Force (11+ years environmental) running the day-to-day hazardous waste management program. I oversee disposal and management contracts, shipping of wastes, spill responses, military munitions, operating under Part A/Part B RCRA permits and even a Subpart X permit. I've written management plans, give training on site-specific RCRA practices, done base assessments at my own and other bases and oversee much of the hazardous materials program as well.
Organizations American Federation of Government Employees union
Awards and Honors Woman of the Year 2004 at my Air Force base; Red Cross Disaster Co-Chair, Disaster Instructor and Shelter Manager; asked to participate as a Hazardous Waste Assessor at two Air Force bases in 2005; responded to an F-16 jet crash in April 2005; as to testify as an expert for the federal government in a contract case concerning wastestream disposal for the Navy.
Expert: Jenyfer Johnson Date: 8/11/2006 Subject: hazardus waste
Question how to define the hazardus waste and what is the lab nanlysis could be used on an unknown material to know if it's hazardus or not?
Answer Hazardous waste is defined in 40 Code of Federal Regulations (CFR) Part 261.2, as first being a solid waste; that is a material that is basically waste-like, discarded, abandoned, served it's intended purpose, a military munition, used in a manner constituting disposal, applied to the land in a manner constituting disposal and so on. You can go to the actual regulation for the specific verbiage.
Once you have a solid waste, then you look to see if it is excluded from Resource Conservation and Recovery Act (RCRA, or hazardous waste) regulations), which is in 40 CFR 261.4. Examples of exclusions are household hazardous wastes, wastes managed under a Clean Water Act system, used oil that is recycled and so on. There are about 14 exclusions.
At this point if you are not excluded and you do have a solid waste, you would then turn to the hazardous waste lists to see if you have a listed hazardous waste. These can be found in 40 CFR 261.30 and are known as the P-list and the U-list. If your material is not on either list, then you have to look and see if it might be a characteristic waste and that is when you may need to turn to analysis to make that determination.
There are 4 types of characteristic hazardous waste; ignitable, corrosive, toxic and reactive. The regulatory reference is found in 40 CFR 261.20. Ignitable wastes are liquid wastes with flashpoints < or = 140 degrees F or oxidizers, or spontaneously conbustible materials. Corrosive wastes are liquids that can corrode steel at a rate greater than .25 inches per year or aqueous solutions with a pH of < or = 2 or > or = 12.5. Reactive wastes are a more lengthy list but include your Class A and B explosives and water reactive chemicals, among others (there is no test for reactive wastes). Toxic wastes are wastes that exhibit a toxicity characteristic of a particular organic, inorganic, pesticide, etc that is found on a list in the regulations, examples of which are chromium, lead, silver, mercury, cadmium, barium, selenium, MEK, ethylbenzene and arsenic to name a few.
If you have an unknown waste and wanted to determine what it was for disposal purposes you would make some educated determinations to order your analysis. Corrosives are only for aqueous or liquids, so you wouldn't order a pH test if your unknown was a solid. There is no test for reactivity so there is nothing to order as far as that is concerned. Toxic wastes are determined by a test called Toxicity Characteristic Leaching Procedure (TCLP) and since you have an unknown you would want to run a FULL TCLP on your unknown material to try and find out what was in it. Again, if it was a liquid only, you would want to run a flashpoint test to determine if it was Ignitable, but not if it was solid. I would also want to know if there was a possibility of solvents in my unknown, depending on what it was (like if it appeared to be contaminated rags, or soil, or paint, or maybe used solvent from a vat) and might want to run a Volatiles and Semi-Volatiles test on my unknown; but I would have a look at what the waste looked like first and try to make an educated guess at what it was and where it might have come from on my facility.
I hope this helps you out with your question.
Jenyfer
