Waste Classification Workshop

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Waste Classification Workshop
KEITH WITTER Waste Permits Division
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Texas Waste Codes

• 8 character identification number consisting
  of
• Sequence number
• Form Code
• Classification

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Sequence Number

• Arbitrary and unique 4-digit number from 0001 to
  9999 (no alpha characters)
• SPIL assigned by the Emergency Response Team of
  the Field Operations Division for spill wastes
  regulated under the Emergency Response Program.

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Sequence Numbers Contd.

• OUTS used for wastes generated outside Texas
• CESQ used by municipal hazardous and industrial
  conditionally exempt small-quantity generators
  (CESQGs)

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Sequence Numbers Contd.

• RRCT used by generators under the jurisdiction
  of the Rail Road Commission of Texas
• TSDF (Treatment, Storage and Disposal Facility)
  used by permitted facilities that treat, store
  and/or dispose of waste from multiple generators.

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Form Codes

• 3-digit code found at 30 TAC 335, Subchapter R,
  Appendix G
• Six major categories include lab packs, liquids,
  solids, sludges, gases, and plant trash.

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Classification

• One-digit number or letter that completes the
  Texas Waste Code
• For industrial generators, will be one of the
  following
• H hazardous waste
• 1 Class 1 non hazardous waste
• 2 Class 2 non hazardous waste
• 3 Class 3 non hazardous waste

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EXAMPLE 1 Mikes Industrial Plant

• Plant generates aluminum oxide sandblast waste
  stream from performing preventative maintenance
  of pipelines and pipe racks.
• Pipe and pipe racks constructed from carbonized
  steel from which rust is periodically removed
  prior to painting.

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Ex. 1 - Waste Classification Information

• Process Knowledge
• The waste stream is comprised of aluminum oxide
  blast media, carbonized steel, and dried paint.

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Ex. 1 Process Knowledge Information

• Review of Material Data Safety Sheet (MSDS) for
  carbon and alloy indicates steel also contains
  very small percentages of regulated metals found
  at 40 CFR 261.24 Table 1. Dried paint would not
  have any regulated organic chemicals.

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Ex. 1 Testing Information

• Representative sample of the sand blast waste
  collected and preserved per sampling plan and
  sent to a registered NELAC lab for TCLP metals
  analysis.
• All regulated metals test below class I
  industrial regulatory limit.

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Ex. 1 Coding Assignment

• Sequence number - as the facility has nine
  waste codes on their NOR (ie., 0001-0009), the
  facility chooses 0010 for this sand blast waste
  stream.
• Form Code - for non hazardous sand blast waste
  from Appendix G (30 TAC 335 Subchapter R,
  Appendix 3) is 389.

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Ex. 1 Determination

• Classification test results is below
  hazardous and industrial class I regulatory
  limits, defaults to class II industrial waste
• Waste Code 0010 389 2
• The waste code sequence number, form code and
  waste determination.

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Example 2 Mikes Industrial Plant

• The plant generates 55 gallon plastic drums
  that previously held Hydro Chem Industrial
  Services product Corrosion Inhibitor A224. This
  product is used in the facility cooling tower and
  must periodically be changed. The waste stream to
  be determined are the empty plastic drums.

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Ex. 2 - Waste Classification Information

• Waste stream is comprised of the plastic
  containers and residual Corrosion Inhibitor A224.
  
• Material Safety Data Sheet for Corrosion
  Inhibitor A224 indicates that it contains
  petroleum naphtha, Ethylene Glycol and Pyridine.

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Ex. 2 - Process Knowledge Information

• A check on defined waste at 30 TAC
  335.508(2)(A)(i) finds that empty containers that
  have held hazardous substance, hazardous waste or
  industrial class I waste are defined industrial
  class I waste unless triple rinsed and rendered
  unusable.

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Ex. 2 - Process Knowledge Information Continued

• A check on defined waste at 30 TAC 335.508(6)
  finds that waste streams with total petroleum
  hydrocarbon concentrations gt1,500 ppm are defined
  as industrial Class I waste.

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Ex. 2 - Process Knowledge Information Continued

A check on Class I Constituents Maximum Leachable
Concentrations in Appendix G at 30 TAC 335
Subchapter R Appendix 1 Table I finds that there
is a industrial class I concentration for both
Ethylene glycol and Pyridine.
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Ex. 2 Generator Decision

• As the facility does not wish to generate the
  rinsate waste stream, a decision is made not to
  triple rinse and render the drums unusable.
  Defaults to industrial class I.

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Ex. 2 - Coding Assignment

• Sequence number - as the facility has ten
  waste codes on their NOR (ie., 0001-0010), the
  facility chooses 0011 for this empty drum waste
  stream.
• Form Code - for organic empty fiber or plastic
  containers waste from Appendix G (30 TAC 335
  Subchapter R, Appendix 3) is 406.

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Ex. 2 - Determination

• Classification process knowledge by rule
  defaults to Class I industrial waste
• Waste Code 0011 406 1
• The waste code sequence number, form code and
  waste determination.

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Example 3 Miguels Industrial Plant

• Mikes Industrial Plant has a sister plant in
  Acuna, Mexico. The plant generates supplemental
  plant production refuse. Miguels Industrial
  Plant wishes to dispose of this waste stream in a
  permitted Municipal Solid Waste landfill in
  Texas.

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Ex. 3 - Waste Classification Information

• Miguels supplemental plant production refuse
  includes used metal pump parts, cardboard
  styrofoam packaging materials and broken unusable
  wooden pallets.

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Ex. 3 - Process Knowledge Information

• Per 30 TAC 335.508(3)(b),waste streams with
  metal pump parts, cardboard styrofoam packaging
  materials and broken unusable wooden pallets are
  defined industrial Class II waste.

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Ex. 3 - Generator Decision

• As the facility wishes to bring an out of state
  industrial Class II waste into Texas, it is
  required to apply for a Special Waste
  Authorization under 30 TAC 330.3(148)(Q)(i).

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Ex. 3 - Coding Assignment

• Sequence number - as the facility has no NOR,
  the facility chooses OUTS for this waste stream.
• Form Code - for Supplemental Plant Production
  Refuse from Appendix G (30 TAC 335 Subchapter
  R, Appendix 3) is 902.

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Ex. 3 - Determination

• Classification process knowledge by rule
  defaults to defaults to Class II industrial waste
• Waste Code OUTS 902 2
• The waste code sequence number, form code and
  waste determination.

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EXAMPLE 4 Mikes Industrial Plant

• The plant generates a wastewater sludge from
  sumps attached to their formaldehyde product
  tank. These sumps collect wash down water,
  transfer spills, pipe leaks and solids that
  settled in the product tank during cleaning.

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Ex. 4 - Waste Classification Information

• The waste stream is comprised of dirt/silt,
  water and formaldehyde. The Material Safety Data
  Sheet for formaldehyde CAS 50-00-0 indicates
  that it is a listed waste U122 and has the
  characteristic hazards D001 D002.

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Ex. 4 - Process Knowledge Information

• A check on U Listings finds that they only
  apply to unused chemical products as per 40 CFR
  261.33(a)(f).

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Ex. 4 - Generator Decision

• A check on the mixture/derived from rule found
  at 40 CFR 261.3(c)(d) specifies any sludge
  waste stream derived from a Listed waste carries
  the applicable listing(s) as well.

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Ex. 4 - Coding Assignment

• Sequence number - as the facility has eleven
  waste codes on their NOR (ie., 0001-0011), the
  facility chooses 0012 for this wastewater sludge
  waste stream.
• Form Code - for sludge with organic
  contaminants from Appendix G (30 TAC 335
  Subchapter R, Appendix 3) is 609.

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Ex. 4 - Determination

• Classification process knowledge by rule
  defaults to hazardous
• Waste Code 0012 609 H
• The waste code sequence number, form code and
  waste determination.

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EXAMPLE 5 Mikes Oil Gas Exploration

• Mikes Oil Gas Exploration Company is a
  Division of Mikes Industrial Plant. They are an
  oil field service company offering drilling
  services for oil and gas development. They are
  regulated in Texas by the Railroad Commission of
  Texas.

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Ex. 5 - Waste Classification Information

• The waste stream is comprised of drill
  cuttings consisting of native soil, crude oil,
  bentonite clay, and drilling fluid.

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Ex. 5 - Process Knowledge Information

• Exclusion under 40 CFR Part 261.4(b)(5)
  states that
• drilling fluids, produced water and other
  wastes associated with the exploration,
  development or production of crude oil, natural
  gas or geothermal energy are solid waste but not
  hazardous waste.

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Ex. 5 - Generator Decision

• No analysis is needed if the generator wants to
  dispose of the waste stream in a TCEQ permitted
  landfill with an industrial Class I trench or
  cell.
• 13 of the MSW landfills in Texas have an
  industrial Class I trench or cell.
• There are 2 IHW permitted Commercial Industrial
  Non-hazardous Waste Landfills in Texas.

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Ex. 5 - Coding Assignment

• Mikes Oil Gas Exploration Company is under
  the jurisdiction of the Rail Road Commission of
  Texas, they have no TCEQ registration.
• Sequence number - the sequence code RRCT is
  chosen.
• Form Code - for oily drill cuttings from
  Appendix G (30 TAC 335 Subchapter R, Appendix
  3) is 489.

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Ex. 5 - Determination

• Classification process knowledge by rule
  defaults to industrial Class I
• Waste Code RRCT 489 1
• The waste code sequence number, form code, and
  waste determination.

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How to Reach UsTCEQWaste Permits
DivisionTechnical Analysis Group, MC-130P.O.
Box 13087Austin, TX 78711-3087Phone
512-239-6412Fax [phone]www.tceq.texas.gov
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Questions

• Keith Witter
• Chemist
• Industrial Hazardous Waste
• Waste Permits Division
• [phone]