What are P and U Listed Wastes?

The P and U listed wastes are quite a bit different from the K and F lists. These wastes are composed of hazardous pure or commercial grade formulations of certain unused chemicals. To qualify as a P or U listed waste the wastestream must meet these three criteria:

  • The waste must contain one of the chemicals listed on the P or U list.
  • The chemical in the waste must be unused.
  • The chemical in the waste must be in the form of a “commercial chemical product,” as defined by the EPA.

In previous blog posts we have learned that hazardous waste listings are narrative descriptions of specific wastestreams and that the actual chemical composition of the waste is usually irrelevant to whether a listing applies to it. Since the P and U lists only contain the chemical name of a compound known to be dangerous or toxic (and no description) they can seem inconsistent with the aforementioned system. EPA decided on this format because the descriptions of the P and U wastes would all be the same. Because of this the description can be found in the regulatory text that introduces the two lists.

According to the EPA, “The generic P and U list waste description involves two key factors. First, a P or U listing applies only if one of the listed chemicals is discarded unused. In other words, the P and U lists do not apply to manufacturing process wastes, as do the F and K lists. The P and U listings apply to unused chemicals that become wastes. Unused chemicals become wastes for a number of reasons. For example, some unused chemicals are spilled by accident. Others are intentionally discarded because they are off-specification and cannot serve the purpose for which they were originally produced.”

The second key factor goes back to the EPA definition of “commercial chemical product.” In order to qualify as a P or U listed waste the chemical must be discarded in the form of a commercial chemical product. The EPA uses this term to describe a chemical that is in pure form, that is in commercial grade form, or that is the sole active ingredient in a chemical formulation.

The EPA defines a pure chemical form as one consisting of 100 percent of that chemical. The commercial grade form of a chemical is a formulation in which the chemical is almost 100 percent pure, but contains minor impurities. If a chemical in a formulation is the only ingredient serving the purpose of the product it is considered the “sole active ingredient.”

The EPA describes this circumstance with the following example, “a pesticide made for killing insects may contain a poison such as heptachlor as well as various solvent ingredients which act as carriers or lend other desirable properties to the poison. Although all of these chemicals may be capable of killing insects, only the heptachlor serves the primary purpose of the insecticide product. The other chemicals involved are present for other reasons, not because they are poisonous. Therefore, heptachlor is the sole active ingredient in such a formulation even though it may be present in low concentrations.”

The P and U listed wasted round out the 4 different waste listings but it is important to remember that even those wastes which remain unregulated by listings may still be applicable to protective hazardous waste regulation because it meets one of the four characteristics of hazardous waste.

All information for this blog post was gathered from the EPA document, “Introduction to Hazardous Waste Identification.” As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

What are K Listed Wastes?

K listed wastes differ from P listed wastes in that K list wastes come from specific sources. They are similar because they both are manufacturing process wastes. So, K listed wastes come from specific sectors of industry and manufacturing. K listed wastes contain chemicals which have been used for their intended purpose.

In order to determine whether or not a waste qualifies as a K listed waste you must answer two questions. The first is whether the facility that created the waste is within one of the industrial or manufacturing categories on the K list? The second, does the waste match one of the specific K list waste descriptions? There are 13 industries that can generate K listed wastes but it is important to remember that not all wastes produced by these industries are hazardous. It is only those which meet the described details in the K list descriptions that qualify. The 13 industries are:

  • Wood preservation
  • Inorganic pigment manufacturing
  • Organic chemicals manufacturing
  • Inorganic chemicals manufacturing
  • Pesticides manufacturing
  • Explosives manufacturing
  • Petroleum refining
  • Iron and steel production
  • Primary aluminum production
  • Secondary lead processing
  • Veterinary pharmaceuticals manufacturing
  • Ink formulation
  • Coking (processing of coal to produce coke, a material used in iron and steel production)

According to the EPA, “in general, the K listings target much more specific wastestreams than the F listings. For example, EPA added a number of listings to the petroleum refining category of the K list. EPA estimates that one hundred facilities nationwide produce wastestreams covered by these new K listings. In contrast, F-listed spent solvent wastes are commonly generated in thousands of different plants and facilities. You may also notice that industries generating K-listed wastes, such as the wood preserving and petroleum refining industries can also generate F-listed wastes.

Typically, K listings describe more specific wastestreams than F listings applicable to the same industry. For example, K051 and K048 designate as hazardous two very specific types of petroleum refinery wastewater treatment residues: wastewater treatment sludges created in API separators and wastewater treatment float created using dissolved air flotation (DAF) pollution control devices. The F037 and F038 listings complement these two K listings by designating as hazardous all other types of petroleum refinery wastewater treatment sludges and floats. These petroleum refinery listings illustrate that the K listings are typically more specific than the F listings. They also illustrate that the two lists are in many ways very similar.”

All information for this blog post was gathered from the EPA document, “Introduction to Hazardous Waste Identification.” As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

What are the F Listed Wastes?

We’ve talked in previous posts about what hazardous waste listing is and how it came to be. We know that there are four different lists; F, K, P, and U. Today, we are going to take a closer look at what the F listed wastes are, why they are designated as F listed wastes, and what sets them apart from the other three listings.

F listed wastes are those particular wastestreams which come from certain common industrial or manufacturing processes. Generally, these are chemicals which have been used for their intended purpose in an industrial process. Because of this, F list wastes are commonly known as “manufacturing process wastes.” It is important to note that the manner in which a waste is generated often plays a key role in how it is identified.

F listed wastes, depending on what type of manufacturing or industrial process creates them, can be broken down into one of seven different categories. These seven categories are detailed below.

1. Spent Solvent Wastes – These wastes are coded as F001-F005 and apply to wastestreams from the use of certain common organic solvents. Solvents are chemicals which may be used for a number of things. Primarily, however, they are used for cleaning and/or degreasing. Solvents which are covered by the F listings are commonly used in industries ranging from mechanical repair to dry cleaning to electronics manufacturing.

2. Wastes from Electroplating and Other Metal-Finishing Operations – According to the EPA, “The listed hazardous wastes F006 – F012 and F019 are wastes commonly produced during electroplating and other metal finishing operations. Diverse industries use electroplating and other methods to change the surface of metal objects in order to enhance the appearance of the objects, make them more resistant to corrosion, or impart some other desirable property to them. Industries involved in plating and metal finishing range from jewelry manufacture to automobile production.”

3. Dioxin-Bearing Wastes – Dioxins are considered by the EPA to be among the most dangerous known chemical compounds. The dioxin listings (F020-F023 and F026-F028) primarily stem from the manufacturing process wastes generated from the production of specific pesticides or chemicals used in pesticides. That said, the F0027 waste stands out from the rest due to its being the only F or K list waste that has not been used for its intended purpose. F027 actually describes and unused chemical rather than an industrial wastes tream. These dioxin-bearing wastes, with the exception of F028, are all considered acutely hazardous and as such are subject to stricter management standards.

4. Wastes from the Production of Certain Chlorinated Aliphatic Hydrocarbons – The F024 and F025 wastes stand out on the F list (wastes from nonspecific sources) because they come from a very narrow industrial sector. These wastes are produced during the manufacturing of chlorinated aliphatic hydrocarbons. Many other waste streams derived from manufacturing organic chemicals are listed on the K list.

5. Wood Preserving Wastes – “The F032, F034, and F035 listings apply to certain wastes from wood preserving operations. Many types of wood used for construction or other non-fuel applications are chemically treated to slow the deterioration caused by decay and insects. Such chemical treatment is commonly used in telephone poles, railroad ties, and other wood products prepared to withstand the rigors of outdoor use.”

6. Petroleum Refinery Wastewater Treatment Sludges – Petroliam refining tends to produce large amounts of contaminated wastewater. This wastewater must be treated to remove oil, solid materials, and chemical pollutants before it can be discharged into a river or sewer. The excluded pollutants are the F037 and F038 wastes. Time and gravity help to separate the pollutants from the water. Solids and heavier pollutants will sink to the bottom and form a material called “sludge” while the less dense pollutants will rise to the surface of the water and make a material known as “float.” If time is a factor, the gravitational separation process can be quickened via mechanical or chemical means. If left to separate only by gravity, the wastes will be F037, if treated via chemical or physical means they will be F038.

7. Multisource Leachate – The last category of F list wastes applies to multisource leachate.  This is the liquid material that collects at the bottom of a hazardous waste landfill. According to the EPA, “Leaching occurs when liquids such as rainwater filter through soil or buried materials, such as wastes placed in a landfill. When this liquid comes in contact with buried wastes, it leaches or draws chemicals out of those wastes. This liquid (called leachate) can then carry the leached chemical contaminants further into the ground, eventually depositing them elsewhere in the subsurface or in groundwater. The leachate that percolates through landfills, particularly hazardous waste landfills, usually contains high concentrations of chemicals, and is often collected to minimize the potential that it may enter the subsurface environment and contaminate soil or groundwater.” This leachate is designated as F039.

All information for this blog post was gathered from the EPA document, “Introduction to Hazardous Waste Identification.” As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations.

What are Hazardous Waste Listings?

Hazardous waste listings are used to describe wastes that the EPA has deemed dangerous enough to necessitate regulation. Hazardous waste listings describe wastes from various industrial processes, wastes from specific sectors of industry, or wastes in the form of specific chemical formulations.

In order to determine if a hazardous waste listing needs to be created the EPA must thoroughly study a waste stream and the threat it potentially poses to human health and the environment. If the threat is significant enough the EPA will include a specific description of the waste on one of the hazardous waste lists in the regulations. After the initial inclusion, any waste that fits the original listing description is considered hazardous regardless of its chemical composition or any other potential variable.

There are both advantages and disadvantages to using listings when defining hazardous wastes. For example, listing makes the hazardous waste identification process easy for industrial waste handlers since only knowledge of the wastes origin is needed to determine whether or not it is listed. This means there is no need for laboratory analysis. All one must do to determine if a waste is hazardous is to compare it to the narrative listing descriptions.

All that said, there are still some disadvantages. For instance, when initially determining whether or not a waste should be listed extensive study and resources are demanded of the EPA. Since resources are limited the listings can’t adequately address every dangerous waste. Additionally, hazardous waste listings are very firm. Each listing designates a waste as hazardous if it falls within a particular category or class meaning that the actual composition of the material need not be considered as long as the criteria for listing are met. Because of these weaknesses, hazardous waste characteristics are utilized to help address the shortcomings.

The EPA has studied and listed hundreds of different waste streams. These are all broken down into one of 4 different list types.

  • The F list – According to the EPA, “the F list designates particular solid wastes, from certain common industrial or manufacturing processes, as hazardous. Because the processes producing these wastes can occur in different sectors of industry, the F list wastes are known as wastes from nonspecific sources.”
  • The K list – EPA defines K listed wastes as solid wastes from certain specific industries. K listed wastes are known as waste streams from specific sources.
  • The P and U lists – The last two categories are generally lumped together due to their similarities. Both of these list pure or commercial grade formulations of certain specific unused chemicals as hazardous.

These individual lists may contain designations of anywhere from 30 to a few hundred different types of hazardous waste. Each different waste is assigned a waste code which consists of the list letter and a three digit number. So numbers may appear as, F001, K004, P007, etc. These codes play an important role in the managing of hazardous waste and as such it is vital to assign the correct code to your waste stream.

All information for this blog post was gathered from the EPA document, “Introduction to Hazardous Waste Identification.” As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full, up-to-date, rules and regulations. 

What is a Solid Waste?

When you hear the term “solid waste” you probably think it means exactly what it sounds like, a waste that is solid as opposed to liquid or gas. Interestingly enough though that is not what it means at all. The legal definition of “solid waste” actually has nothing to do with physical form. Rather, it deals with whether or not the material is a “waste.”

RCRA §1004(27) defines a solid waste as, “any garbage, refuse, sludge from a wastewater treatment plant, water supply treatment plant, or air pollution control facility, and other discarded material, including solid, liquid, semisolid, or contained gaseous material, resulting from industrial, commercial, mining, and agricultural operations and from community activities.”

The definition found in 40 CFR §261.2 is a little less extensive. §261.2 defines a solid waste as any material that is discarded by being abandoned, inherently waste-like, recycled, or a military munition identified as a solid waste. These four categories are explained further below.

What is an “abandoned waste?”

As you might have guessed, an abandoned material is simply one which has been discarded or thrown away. Under §261.2 a material is considered abandoned if it is disposed of, burned, or incinerated. Additionally, any material that is stored before or in place of disposal, burning, or incineration is considered abandoned.

What does it mean for a material to be “inherently waste-like?”

Regardless of whether or not they are recycled in some way, there are some materials that are always considered solid wastes under §261.2. Because the materials may still pose danger to human health or the environment after recycling, they are considered inherently waste-like and do not qualify for any type of recycling exemptions. According to the EPA, “examples of inherently waste-like materials are the dioxin-containing listed wastes F020, F022, F023, F026 and F028.”

What kinds of materials are recycled?

The EPA has three categories for a “recycled material.” According to §261.1 a material is recycled if it is used, reused, or reclaimed. Each of the three categories has a specific regulatory definition. So, a material is reclaimed if it is processed to recover a usable product or if it is regenerated. An example would be regeneration of spent solvents. A material is used or reused if it is either used as an ingredient in an industrial process to make a product, such as distillation bottoms from one process being used as feedstock in another process, or if it is employed as an effective substitute for a commercial product. For example, spent pickle liquor can be used as a sludge conditioner in wastewater treatment.

How and when do military munitions become solid waste?

RCRA in relation to military munitions was a somewhat controversial topic until February 12, 1997, when the EPA finalized a rule that specified when unused and used military munitions are considered discarded and become solid wastes (62 FR 6622). It was decided that unused military munitions would be considered solid wastes once they were removed from storage for disposal or treatment, when they were leaking or in any way deteriorated so they could not be recycled or reused, or when they were declared a solid waste by an authorized military official.

Unused munitions that are repaired, recycled, or reclaimed, are not considered solid wastes, nor are they considered solid wastes while in storage in demilitarization accounts (e.g., scheduled for treatment or disposal). Only when these munitions are finally removed from storage for the purposes of disposal do they become solid wastes.

Used military munitions become solid wastes when they are buried or landfilled onsite, or when they are removed from their landing spot for subsequent management (storage, reclamation, treatment, or disposal) off-range.

All information for this blog post was gathered from the EPA Document, Definition of Solid Waste and Hazardous Waste Recycling. As always, this blog post is not intended to be comprehensive and it is always best to check with the EPA and local government for full rules and regulations.