CHAPTER 10: HAZARDOUS NONHAZARDOUS WASTE

10–1

Chapter 10: Hazardous and Nonhazardous Waste

Step-by-Step Summary ............................................................................................ 10–3

I. Introduction ......................................................................................................... 10–5

II. Overview of Federal Requirements: Determining if aWaste Is Hazardous Under RCRA ...................................................... 10–5

A. Toxicity .............................................................................................................. 10–6

B. Corrosivity ......................................................................................................... 10–6

C. Ignitability .......................................................................................................... 10–6

D. Reactivity ........................................................................................................... 10–6

E. Listed Wastes ..................................................................................................... 10–6

III. Waste Management Procedures .................................................................. 10–7

A. Interim Control Waste ...................................................................................... 10–7

B. Abatement Waste .............................................................................................. 10–7

C. Categories of Abatement Waste ..................................................................... 10–10

1. Category I— Low Lead Waste ..................................................................... 10–10

2. Category II—Architectural Components .................................................... 10–11

3. Category III— Concentrated Lead Waste ................................................... 10–12

4. Category IV—Other Waste ......................................................................... 10–13

D. Quantity of Hazardous Waste ........................................................................ 10–13

1. Less Than 100 kg of Hazardous Waste ......................................................... 10–13

2. More Than 100 kg of Hazardous Waste ....................................................... 10–13

3. Waste Water ................................................................................................. 10–14

E. Lead-Based Paint Waste From Public Buildings ........................................... 10–14

IV. RCRA Hazardous Waste Management Requirements ...................... 10–14

A. EPA Identification Number (40 CFR 262.12) ............................................ 10–14

B. Pretransport Requirements (40 CFR 262.30 Through 262.34) ................ 10–15

1. Onsite Accumulation of Waste .................................................................... 10–15

2. Waste Minimization Plans ........................................................................... 10–15

3. Packaging ...................................................................................................... 10–15

4. Selecting a Transporter and Waste Management Facility ........................... 10–15

C. Manifesting the Waste (40 CFR Part 262.20 Through 262.22) ................ 10–17

D. Land Disposal Ban Notification and Certification (40 CFR 268.7 and40 CFR 268.9) ................................................................................................ 10–19

CHAPTER 10: HAZARDOUS AND

NONHAZARDOUS WASTE

10–2


E. Recordkeeping (40 CFR 262.40 through 262.44) ...................................... 10–19

1. Biennial Reports ........................................................................................... 10–21

2. Exception Reports ........................................................................................ 10–21

3. Three-Year Retention of Reports, Manifests, and Test Records .................. 10–21

V. Waste Management Case Study ....................................................... 10–21

A. Lead Hazard Control Measures ...................................................................... 10–21

B. Waste Generated and Management Steps Taken .......................................... 10–21

1. Interim Control Waste ................................................................................. 10–21

2. Abatement Waste ......................................................................................... 10–22

10–3

Chapter 10: Hazardous and Nonhazardous WasteStep-by-Step Summary

Managing Hazardous andNonhazardous Waste: How To Do It

This checklist is based on existing Federal requirements. The U.S. Environmental Protection Agency(EPA) is considering changes in the hazardous waste regulations for waste generated by lead-based paintabatement activities. Until changes are formally adopted, however, those individuals producing hazardousand nonhazardous solid waste should comply with the existing regulations outlined in the Resource Con-servation and Recovery Act (RCRA), Subtitles C and D. States should be consulted when determininghow to manage abatement waste in a given locale. Although EPA has the authority to enforce the RCRAregulations, the States are the principal enforcement authorities.

1. Determine if the waste will result from an interim control or an abatement effort. Interim control wastefrom single and multifamily residences may be exempt from hazardous waste regulations, if the waste isgenerated as part of routine residential maintenance. Contact your State to determine whether interimcontrol waste can be handled as household waste. Even if exempt from hazardous waste management re-quirements, interim control waste should be managed carefully in accordance with State regulations andother practices described in this chapter.

2. Waste from abatement activities must be evaluated for the RCRA Toxicity Characteristic. Contact Stateor local agencies to determine whether they have special regulations for abatement waste.

3. To minimize the total quantities of waste generated, conduct abatement efforts that generate reducedquantities of both hazardous and nonhazardous waste for disposal. For example, remove unpainted material(e.g., glass from windows) and unpainted wood, metal, concrete, and bricks from demolition waste, andseparate painted waste that could be recycled. Do not use architectural components coated with lead-based paint as mulch or in any other construction unless lead-based paint has been properly removed.

4. As a preabatement screening step, make a RCRA hazardous waste toxicity characteristic determination(using existing knowledge or waste analysis data) for various components from each of the lead-basedpaint abatement waste categories. Depending on the hazardous waste determination, segregate hazardousabatement waste from nonhazardous waste, and accumulate accordingly in separate containers.

5. Separate abatement waste into the following four categories (described more fully in Table␣10.1).

Category I: Low Lead Waste (typically nonhazardous)Category II: Architectural ComponentsCategory III: Concentrated Lead Waste (typically hazardous)Category IV: Other Waste

6. Determine how much hazardous waste will be produced. If less than 100 kg (approximately 220 pounds or1/2 of a 55-gallon drum) of hazardous waste per month will be generated, it is considered “conditionallyexempt” abatement waste and may be managed as solid nonhazardous waste and delivered to a State-licensed or -permitted solid waste management facility. (HUD recommends that such waste not be incin-erated.) The RCRA hazardous waste manifest is not required when shipping this waste to an offsite disposalfacility.

10–4


7. Do not accumulate more than 1,000 kg of the conditionally exempt abatement waste at any time. Handlethe waste according to the HUD-recommended management practices described in this chapter.

8. If more than 100 kg of hazardous waste per month will be generated, comply with RCRA hazardous wasteregulations. At a minimum, the following Federal requirements must be met:

✦ Obtain a Generator Identification Number before shipping the hazardous waste offsite facility for man-agement, recycling, or disposal.

✦ Accumulate hazardous waste in storage tanks or containers. Label storage units as “hazardous waste,”recording the accumulation start date on the label. Train workers on waste handling and emergencyprocedures.

✦ Maintain storage containers or tanks in compliance with the 40 CFR Part 265, Subpart I or J, standard.

✦ If more than 1,000 kg per month of hazardous waste is generated at the site, do not accumulate hazard-ous waste for longer than 90 days. A hazardous waste storage permit is generally necessary when thewaste must be stored for longer than 90 days. (See accumulation requirements for generators producingmore than 100 kg and less than 1,000 kg of hazardous waste per month explained in Section IV.)

✦ Engage the services of a licensed hazardous waste transporter and/or a management facility with properpermits.

✦ Prior to shipment, package hazardous waste and properly label, mark, and placard the packaged wasteaccording to U.S. Department of Transportation regulations.

✦ Complete and sign the Uniform Hazardous Waste Manifest, and get the signature of the transporter onthe manifest when releasing a load of hazardous waste. You must receive a signed manifest back fromthe designated hazardous waste facility within 35 days.

✦ Comply with the RCRA Land Disposal Restrictions including notification and certificationrequirements.

✦ Submit biennial reports describing waste generation and management activity when generating morethan 1,000 kg per month of hazardous waste at each site.

✦ Maintain all waste determination and handling records for at least 3 years.

9. HUD recommends that nonhazardous Category II architectural components be wrapped and sealed in plas-tic, covered during transport, and disposed of in a State-approved solid waste landfill. Such waste should notbe burned in a municipal solid waste incinerator, recycled to produce mulch, or reused unless all lead-basedpaint is removed.

10. Nonhazardous solid waste must be discarded in accordance with State and local requirements.

Step-by-Step Summary (continued)

10–5


Chapter 10: Hazardous andNonhazardous WasteI. Introduction

This chapter describes the Federal requirementsand recommended practices that apply to man-aging waste generated by lead-based paintabatement or interim controls. Owners, abate-ment contractors, transporters, and disposal fa-cilities are responsible for managing their wasteproperly. Improperly managed lead-contami-nated waste can pose serious risks. For example,it can contaminate soil and groundwater. Dis-carded building components that are coatedwith lead-based paint may be inadvertently re-installed in other dwellings. In addition, work-ers may bring leaded dust into their homes iftheir work clothes are not cleaned or disposedof properly. Waste management regulations arestrictly enforced; violators can be fined.

EPA is considering revising the existing hazard-ous waste regulations that govern waste gener-ated from lead-based paint abatement activities.The primary Federal statute governing wastemanagement from generation to disposal is theResource Conservation and Recovery Act(RCRA). RCRA defines the criteria for hazard-ous and nonhazardous waste. While hazardouswaste management must meet Federal stan-dards, most States are authorized by the U.S.Environmental Protection Agency (EPA) toadminister the basic RCRA hazardous wasteprogram. Owners and lead hazard control con-tractors should observe the waste managementpractices described in this chapter and complywith State or local regulations. States and localgovernments may also institute hazardous wasterequirements that are more stringent than Fed-eral standards (EPA, 1990a).

II. Overview of FederalRequirements:Determining if a Waste IsHazardous Under RCRA

RCRA regulates all “solid” waste, which is de-fined broadly to include liquid, solid, and somegaseous waste, except for certain waste that isregulated under other Federal law. Most abate-ment and interim control debris is likely to besolid waste, which can be either hazardous ornonhazardous. Waste water, such as mop andshower water, that is disposed of in a municipalwastewater treatment system, is regulated underthe Clean Water Act and thus is exempt fromRCRA. Local water departments are authorizedto regulate water discharges from lead hazardcontrol sites.

Solid nonhazardous waste is regulated at theFederal, State, and local levels. EPA has estab-lished mandatory minimum requirements forenvironmentally acceptable waste managementfacilities that receive nonhazardous solid waste(40 CFR Parts 257 and 258). States must estab-lish comparable or more stringent standards.

RCRA Subtitle C regulations define a “genera-tor” as any person at a particular facility or loca-tion whose act or process produces a hazardouswaste. Both property owners and contractorsinvolved in abatement/interim control actionscan be considered generators. Generators mustanswer the following questions:

✦ Does the generator have knowledge that thewaste is hazardous under RCRA regulations?

✦ Did a test define the material as a RCRAhazardous waste (“characteristic hazardouswaste”)?

✦ Is the waste exempt from regulation as“hazardous” under RCRA rules?

10–6


✦ Is the waste included on EPA’s list ofhazardous waste?

✦ If the waste is hazardous (or nonhazardous)what Federal, State, or local standards mustbe satisfied?

For most abatement and interim controlprojects, the owner is a generator. Although theowner may designate the contractor to handlepaperwork and hazardous waste management,the owner is ultimately responsible for properwaste disposal. Contractors must have a RCRApermit to transport hazardous waste and maycombine such waste from different owners fortransport only if each owner agrees and only ifpermitted by State and local regulations.

Generators must determine whether their wasteis either listed as or characteristic of hazardouswaste. Generators must test or use their existingknowledge of the waste to determine if it exhib-its hazardous characteristics, unless it is other-wise exempted (see Section IV).

Waste exhibiting one or more of the followingfour characteristics is considered hazardous:

✦ Toxicity.

✦ Corrosivity.

✦ Ignitability.

✦ Reactivity.

A. Toxicity

Waste that exhibits the Toxicity Characteristic(TC) poses a substantial threat to humanhealth and the environment. Waste toxicity ismeasured by using the Toxicity CharacteristicLeaching Procedure (TCLP) (40 CFR 261.24).The TCLP extract is analyzed for lead (or otherconstituents) to determine if it is above or be-low the allowable TC regulatory threshold,which for lead is 5 ppm (milligrams/ liter).

“Leachable” lead analysis differs from “total”lead analysis, which is typically performed onpaint chips during a risk assessment or inspec-tion, in that leachable lead is dependent on thetype of lead compound present and the size ofthe particle (that is, its solubility). Because total

lead analysis does not determine the specificlead compound present, it is difficult, if not im-possible, to predict how much of the lead willbe leachable. Therefore, XRF or paint-chipanalysis (by the usual hot nitric acid digestion/atomic absorption spectroscopy methods) areunlikely to help determine leachability. Thetotal lead levels determined by a paint-chipanalysis are usable in two circumstances:(1) total lead level that is very low (e.g., lessthan 100 ppm), indicates that waste should notexceed the TC regulatory threshold; and(2) total lead levels can be used in combinationwith total waste volume estimates to determinewhether recycling for lead recovery is feasible.

Appendix 10 contains practical questions andanswers about testing abatement waste usingthe TCLP and selecting a laboratory.

B. Corrosivity

Corrosive waste has a pH that is either less thanor equal to 2 (highly acidic) or greater than orequal to 12.5 (highly basic), or which can cor-rode steel at a certain rate (40 CFR 261.22).Unneutralized caustic paint strippers and acidicpaint strippers (including the resulting sludge)may be corrosive.

C. Ignitability

Ignitable waste generally includes liquids withflash points below 140°F (60°C), flammablesolids and compressed gases, and oxidizers (40CFR 261.21). Certain solvents from paint strip-pers (e.g., xylene) and the resulting sludge orslurry waste may be ignitable.

D. Reactivity

Lead-based paint hazard control projects areunlikely to produce reactive waste. Reactivewaste includes substances that are capable ofeasily generating explosive or toxic gases, espe-cially when mixed with water (40 CFR 261.23).These also include waste that is unstable andundergoes violent change without detonating.

E. Listed Wastes

Waste may also be hazardous under RCRA ifincluded on EPA’s list of hazardous waste.

10–7


Lead-based paint hazard control jobs are ex-tremely unlikely to generate “listed” waste.EPA’s current list, which can be found in 40CFR 261.31 through 33, includes specific sourcewaste (waste from specific industries), genericwaste (waste from common manufacturing andindustrial processes, such as solvents), and dis-carded or “out-of-spec” commercial chemicalproducts (such as creosote and some pesticides).

III. Waste ManagementProcedures

Waste management procedures are summarizedin Figure 10.1.

A. Interim Control Waste

The waste from interim controls may be exemptfrom RCRA hazardous waste regulations, underthe exclusion for household waste (see 40 CFR261.4(b)(1)). To be excluded, household wasteshould meet two criteria. First, the waste mustbe generated by individuals on the premises of ahousehold, and second, the waste must be com-posed primarily of materials found in the wastegenerated by consumers in their homes. Solidwaste generated as part of routine residentialmaintenance by a homeowner, resident, or con-tractor would generally be part of the “typical”household waste stream, and thus would be ex-empted from hazardous waste regulations underthe RCRA household waste exclusion. Genera-tors should contact State RCRA authorities forassistance in determining the limitations of thehousehold waste exclusion for waste from in-terim controls at specific sites.

The State may determine that waste from in-terim controls is hazardous waste. In this case, ifthe waste is produced in small quantities (i.e.,less than 100 kg of hazardous waste per month), itcould be excluded as “conditionally exempt”under the small quantity generator exemption.(See Section III.D). Even if interim controlswaste is exempted, waste with a high concentra-tion of lead (e.g., high efficiency particle air(HEPA) vacuum debris and filters, sludges fromfiltering waste water, paint chips) should behandled carefully (i.e., contained in drums or

wrapped in plastic with taped seams, and cov-ered during transport).

Waste water from mopping or cleaning opera-tions, upon filtration, could be poured down thetoilet provided that local authorities approve ofsuch a practice. Waste water can be filtered ef-fectively by using a 20 µm pore size filter, al-though a pump may be necessary to force thewater through the filter. A coarse screen orcheesecloth is often used as a prefilter.

If significant quantities (10 gallons or more) ofwater are produced, owners should contact thelocal waste water treatment facility before dis-charging the liquid to determine if there are anyspecific pretreatment standards to be imple-mented, and inform the facility of the quantityof water to be discharged and its probability ofcontaining phosphates or other cleaning agents.

B. Abatement Waste

Under RCRA, abatement waste is classifiedseparately. The distinction primarily lies in thedifference between routine maintenance andpermanent control. Even though abatementwaste may be similar to waste created from in-terim controls, it is typically generated from aone-time activity as opposed to temporary, rou-tine maintenance. Abatement waste may alsobe stored until either work is complete orenough waste has been generated to make up ashipment load. Abatement waste, therefore, isnot covered under the RCRA household wasteexclusion.

Waste from abatement activities may be similarto waste from construction, demolition, andrenovation. Waste generated from construction,demolition, and renovation do not meet theroutine maintenance criteria (discussed in Sec-tion III.A). In 1984, EPA determined that thelatter category of waste is not household waste(49 FR 44998, November 13, 1984). SomeStates may have special management standardsfor abatement wastes. Contact your State todetermine the status of abatement waste underState regulations.

10

–8

Ch

apter 1

0: H

azardous an

d N

on

hazard

ous W

aste

Figure 10.1 Waste Management Procedures.

Interim Controls

Category I Low-Lead Waste

Category II Architectural Components

Category IV Other Waste

Category III Concentrated Lead Waste

Determine if exempted under RCRA as a household waste

(contact State)

Identify Hazard Control Measures

Abatement

Determine Lead-Based Paint Waste Category

Make RCRA hazardous waste determination

(use knowledge or test data and contact State)

Manage as nonhazardous waste in accordance with

Federal and State regulations and HUD-recommended practices

Nonhazardous Waste

Hazardous Waste

Manage as conditionally exempt RCRA waste as

allowed under State regulations

<100kg (<220 lbs) per month

>100kg (>220 lbs) per month

Manage as hazardous waste per

Federal and State

regulations

10–9


The type of abatement waste managementimplemented depends upon the quantity andtype of waste material. Some types of waste willalways contain a high concentration of leachablelead, while others will differ by physical compo-

nent, depending on the abatement methodsused at each job site. Waste should be physicallyseparated into categories of “like materials.”This practice prevents the contamination ofnonhazardous waste with hazardous waste. A

Category Description Examples of Wastes

Filtered personal and commercial wash water.

Disposable personal protective clothing that has beenHEPA vacuumed before disposal.

Plastic sheeting cleaned prior to disposal (misted andwiped) and carpeting.

Any waste that is determined to be nonhazardous byTCLP testing and is not an EPA-listed hazardous waste.

Painted finish carpentry items, for example:

✦ Doors.

✦ Windows.

✦ Window trim and sills.

✦ Baseboards.

✦ Railing.

✦ Moldings.

Other painted building components, for example:

✦ Metal railings.

✦ Radiators.

✦ Walls.

✦ Stone or brick.

Sludge from paint stripping.

Lead-based paint chips and dust.

HEPA vacuum debris and filter.

Unfiltered wash water.

Hazardous waste.

Any waste included on EPA’s list of hazardous waste.

Material that cannot be determined, using knowledge ofthe waste, to be either hazardous or nonhazardousmust be tested using the TCLP.

I Low Lead Waste

III Concentrated Lead W aste

IV Other Waste

II Architectural Components

Table 10.1 Categories of Abatement Waste

10–10


reduction in the amount of hazardous waste re-duces disposal costs. Abatement waste shouldbe segregated into several categories, as shownin Table 10.1 (EPA, March 1993).

If a dwelling is being partially or completelyrenovated or demolished as part of the lead haz-ard control work, these categories are not appli-cable. In this instance, the demolition debriscould be segregated into painted and unpaintedwaste material so that the latter category ofwaste could be recycled, if appropriate. The re-maining lead-based paint demolition debrisshould be managed as one waste stream andevaluated to determine if it is hazardous.

C. Categories of AbatementWaste

RCRA rules and HUD recommended manage-ment practices are summarized in Table 10.1.The categories are based on EPA’s study to de-termine which waste materials from abatementactivities are likely to exhibit the hazardouswaste characteristic of toxicity for lead (EPA,1993). However, the study results were limitedand inconclusive for some types of waste, andEPA concluded that additional confirmatoryanalysis would be needed. In lieu of testing, thegenerator may use the limited data from thisstudy, or other studies, in making their hazard-ous waste determinations. However, the genera-tor is ultimately liable for any improper disposal.All generators should retain documentation tosubstantiate their waste determinations.

1. Category I—Low Lead Waste

Contents

This waste category typically passes the TCLPbecause it exhibits concentrations of leachablelead below 5 ppm. It includes filtered personalwash water and mop water, disposable personalprotective clothing that has been HEPA vacu-umed before disposal, plastic sheeting that hasbeen misted and cleaned before disposal, carpet-ing, and nonhazardous waste (EPA, 1993).Wash water does not include unfiltered spentstripper solutions, stripper sludges, or any otherliquid paint removal products, all of which areCategory III waste. In lieu of testing, generatorsmay use the EPA report test results to supple-

ment their knowledge of the waste in makingtheir hazardous waste determinations.

The EPA report acknowledges the existence oflimited data on plastic if certain abatementmethods were used. However, according to con-tractors, if plastic is thoroughly cleaned (mistedand swept or wiped to remove lead-based paintand dust), it will typically pass the TCLP(Aulson, 1992).

The ultimate responsibility for making theproper waste determination still rests with thegenerator. Generators should test any CategoryI waste that they believe might fail the TCLP.

RCRA Waste Management Rules

Category I waste should be disposed of in accor-dance with the applicable Federal requirements(40 CFR Part 257 or 258), in accordance withRCRA Subtitle D regulations and State andlocal solid waste requirements.

HUD Recommended Practices

HUD recommends that generators follow thefollowing practices for nonhazardous abatementwastes.

✦ The waste should be wrapped in suitableplastic (6-mil polyethylene or equivalent),and all seams should be sealed with tapeduring storage and transport to the disposalfacility. (Some disposal facilities do not ac-cept waste wrapped in plastic. In this case,the waste should be covered in plastic dur-ing storage and transport only.)

✦ The waste should be stored in a designatedsecure (locked) area.

✦ Liquid waste water should be disposed of inthe toilet after applicable pretreatment steps(e.g., filtering, gravitational separation), ifany, have been satisfied. Waste water shouldnot be poured into storm drains or onto theground.

✦ Dumpsters should have lids and be pad-locked. Wrapping and sealing in plastic maynot be necessary if a covered transport ve-hicle is used and if plastic is used to linewalkways to the vehicle during loading.

10–11


Wrapping and sealing waste materials inplastic, however, will minimize final cleanupand dust generation from abrasion of loosecomponents coated with lead-based paint.

2. Category II—Architectural Components

Contents

This category includes waste defined as intact,discarded architectural components exceeding60 mm (2.5 inches) in either width or length,which are often referred to as finish carpentry orpainted building components. (The 60 mm cut-off is consistent with EPA’s existing definitionof hazardous debris in 57 FR 37223, August 18,1992.)

Such components include painted doors, doortrim, windows, window trim or sills, baseboards,soffits, facia, columns, railings, moldings, radia-tors, walls, and stone or brick. Paint chips thatare removed or fall off these components arelikely to be hazardous waste and are not in-cluded in this category. Category II does notinclude lead sheeting.


EPA may revise the regulations that apply toarchitectural components. Until that time con-tractors and property owners must follow exist-ing RCRA, State, and local requirements. Un-der current RCRA regulations, such material(as well as other solid waste) must be evaluatedusing knowledge of the waste or results from theTCLP. (See Appendix 10 for suggestions on se-lecting a laboratory to conduct the TCLP andminimizing the volume of architectural compo-nents that fail.)

Generators should contact State agencies forany information or data on the characteristicsof lead abatement wastes in their area. In allcases, States must be consulted when generatorsare determining how to manage lead abatementwastes, since they are the principal enforcementauthorities for the applicable regulations.

EPA waste-study results for lead-based paintarchitectural components are inconclusive, andEPA is currently gathering additional data on

Figure 10.2 Seal Abatement Debris in Plastic BeforeTransporting Offsite.

this type of waste in support of anticipated regu-latory changes. Until these changes becomefinal, current regulations require that the gen-erator evaluate architectural components fortheir potential to be characteristic hazardouswaste under RCRA.

Under RCRA (40 CFR 262.11(c)), generatorsmay use their knowledge of the waste, in lieuof testing, to identify characteristic hazardouswaste. When using knowledge or relevantinformation, the generator is responsible forsupporting the claim that the waste is nonhaz-ardous. In the case of architectural components,a variety of site-specific factors may affect theTCLP results of architectural components. Fac-tors include the age of the building, thickness ofthe paint, sampling protocol, etc. For example,if certain types of painted components from sev-eral single-family houses (or several units ofmultifamily housing from a given period of con-struction (e.g., 1950–1960) in a given neighbor-hood are found to pass the TCLP, it may be rea-sonable to assume that such components inother houses or units of the same period andneighborhood would also pass.


Even if classified as nonhazardous wastes,HUD recommends the following procedurefor handling architectural components:

10–12


✦ Once components are removed from thecontained work area, the cutting or break-ing of painted materials or any action that islikely to generate leaded dust should beprohibited.

✦ Separate glass from windows for recycling.

✦ While it is still inside the work area, wasteshould be wrapped in 6-mil polyethyleneplastic (or equivalent) and all seams shouldbe taped shut. It should be confirmed in ad-vance whether the selected disposal facilitywill accept waste wrapped in plastic. If not,the waste should be covered with plasticduring storage and transport only.

✦ Waste should be stored in a designated andsecure area separate from the work area. Ifmaterial is stored or handled outside, 6-milplastic sheeting should be placed under-neath and on top of the material to preventsoil contamination. Plywood or other du-rable material should be placed on top ofthe plastic to prevent puncture of the plasticby nails or other fasteners.

✦ Waste should be transported in coveredvehicles to minimize lead dispersal into theenvironment.

✦ Waste should not be disposed of in a solidwaste incinerator and it should not be reusedor recycled for mulch.

✦ Nonhazardous solid waste should be dis-posed of only in State-licensed or -permittedsolid-waste landfills.

3. Category III—Concentrated Lead Waste

Contents

This category consists of “listed” hazardouswaste, and any other waste exhibiting hazardouscharacteristics and likely to leach lead above 5ppm and thereby fail the TCLP. Category IIIwaste frequently includes paint strippings, leadpaint chips and dust, HEPA vacuum debris andfilter, and any other hazardous waste. TCLPresults for these materials typically surpass the

allowable regulatory level for lead (5 ppm). Al-though the EPA report on waste disposal in thiscategory included rags, sponges, mops, andscrapers, these materials may not contain sig-nificant levels of leachable lead if they are prop-erly cleaned prior to disposal.

Although it is extremely difficult to anticipateTCLP results for lead-contaminated soil usinglead concentration, anecdotal evidence indi-cates that if lead in soil exceeds 5,000 ppm,such soil is likely to fail the TCLP and thus beconsidered hazardous waste (Spitler, 1994). Theconverse, however, is not necessarily true be-cause total lead is not easily correlated withleachable lead.


Category III abatement waste usually exhibitslead toxicity characteristics. In the absence ofsite-specific testing data to the contrary, Cat-egory III waste should be considered hazardous(EPA, 1993).

In lieu of relying on EPA data, generators maytest the waste to make a site-specific determina-tion. If the site-specific testing indicates thatthe waste passes the toxicity test, then thewaste is not considered hazardous. For liabilitypurposes, test records should be maintained forat least 10 years.

Some hazardous waste transporters and manage-ment facilities will require their own TCLPtesting before accepting waste.

Waste management standards vary dependingupon the quantity of hazardous waste produced.Under RCRA, generators producing less than100 kg/month (about 220 pounds/month) ofhazardous waste qualify as “conditionally ex-empt,” small-quantity generators and mayhandle such waste as nonhazardous, as de-scribed earlier in this section and also inSection IV.


Even if the abatement waste is exempt fromhazardous waste regulations under the smallquantity exemption, HUD recommends the

10–13


following procedures for handling Category IIIwaste:

✦ Wrap in plastic with seams sealed shut (ifdisposal facility allows).

✦ Cover during transport.

✦ Prohibit from being treated at a solid wasteincinerator.

✦ Dispose only in a State-permitted or-licensed solid waste landfill.

4. Category IV—Other WasteCategory IV includes all waste that does not fallinto one of the other three categories, such asexcavated lead-contaminated soil. Category IVwaste should be tested to determine if it exhib-its any of the RCRA hazardous characteristicsunless the generator has knowledge indicatingthat the waste should not be hazardous. (SeeAppendix 10 for guidance in selecting a labora-tory to conduct the TCLP.) If the waste is deter-mined to be hazardous, it should be handled asCategory III waste; if nonhazardous, as CategoryI solid waste. For liability purposes, all test re-sults should be retained for at least 10 years.Contact your State to determine whether any ofthe wastes belonging to this category are auto-matically, or could be determined to be, hazardous.

D. Quantity of Hazardous Waste

When determining the hazardous waste genera-tor status (e.g., less than 100 kg per month orgreater than 100 kg per month), generatorsmust account for all hazardous waste generatedon site, including nonabatement waste that maybe hazardous. (See Section IV regarding stepsthat can be taken to minimize the quantity ofwaste.)

1. Less Than 100 kg of HazardousWasteUnder RCRA, if less than 100 kg/month (ap-proximately 220 pounds/month or 25 gallonsof liquid) of hazardous abatement waste isproduced (e.g., from small abatement jobs atsingle-family dwellings), then the generators

automatically qualify as “conditionally exempt,small-quantity generators.” Such waste, at aminimum, must be disposed of in State-licensedor -permitted solid waste management facilitiesor hazardous waste disposal facilities.

In addition, no more than 1,000 kg (approxi-mately 2,200 pounds) of hazardous waste maybe stored onsite at any one time. Generatorsshould contact State waste management au-thorities for guidance in determining the appli-cability of the small quantity generator exemp-tion under State regulations.

2. More Than 100 kg of HazardousWasteIf more than 100 kg per month of hazardouswaste is likely to be produced by abatement ac-tions for a single owner at a single site, a hazard-ous waste manifest must be completed beforethe waste is shipped offsite (see Section IV for adiscussion of the RCRA hazardous waste man-agement requirements). Hazardous waste from asingle-family dwelling may or may not exceedthe 100 kg per month limit. The hazardouswaste generated from a multifamily housingabatement project will most likely exceed the100 kg per month generator limit and the gen-erator will therefore be subject to applicableRCRA hazardous waste management require-ments (e.g., accumulation time limit, packagingand shipping requirements, land disposal restric-tions, and recordkeeping requirements from 40CFR Part 262.)

TCLP tests can be performed on debris frompilot projects or debris generated by identicalabatement procedures in identical structures toindicate whether the waste will be consideredhazardous (see Appendix 10).

Generators producing more than 100 kg/monthof hazardous waste must apply for and obtain anEPA identification (ID) number (from the ap-propriate agency) prior to shipping the hazard-ous waste offsite. Since the application processis lengthy, it is advisable to apply for the IDnumber several weeks prior to the start of a job.In most cases, the State waste management au-thority will issue EPA ID numbers to generators,and, for short-term abatement jobs, some States

10–14


may provide temporary ID numbers. Additionalwaste handling and disposal requirements arediscussed in Section IV below.

Before work begins, it is important to contractwith a hazardous waste management companythat has an EPA identification number for thetransportation and management of hazardouswaste and to secure cost estimates for wastetransportation, treatment to meet land disposalrestrictions (discussed in Section IV below),storage, and disposal.

3. Waste WaterIf significant quantities of waste water (greaterthan 100 gallons) will be produced, the localwaste water treatment facility should be con-tacted to determine if special measures shouldbe taken before the waste water is poured downthe toilet. The treatment facility should be in-formed if phosphate detergent or other cleanerswere used during cleaning. The water shouldnot be discharged until the proper area author-ity has granted permission to do so. Waste watershould never be poured onto the ground orpavement.

E. Lead-Based Paint WasteFrom Public Buildings

For nonresidential public buildings (e.g.,schools, libraries), all waste from lead hazardcontrol efforts should be managed according tothe procedures described earlier for abatementwaste. Such waste may be similar to residentialabatement waste in many respects; however,since these buildings are not “households,” thehousehold waste exemption for interim controlwaste does not apply. EPA is considering thiswaste along with residential abatement wastefor possible regulatory changes.

IV. RCRA Hazardous WasteManagement Requirements

The requirements for generators producingmore than 100 kg/month of hazardous wasteare set forth in 40 CFR Part 262. Generators

producing quantities between 100 and 1,000 kg/month are referred to as “small-quantity genera-tors,” but are considered conditionally exempt.Those producing amounts more than 1,000␣kg/month are “large-quantity generators.” In someinstances, the requirements differ for small- andlarge-quantity generators. The regulations forhazardous waste generators require:

✦ Obtaining an EPA identification number.

✦ Meeting specified pretransportationstandards.

✦ Completing hazardous waste manifest forms.

✦ Complying with land disposal restrictionnotification and certification.

✦ Maintaining records.

A. EPA Identification Number(40 CFR 262.12)

Generators must apply for an EPA generatorID number for each abatement site. The 12-character number is used by EPA and the Statesto maintain a nationwide tracking system onhazardous waste activity. All hazardous wastegenerators; transporters; and treatment, storage,and disposal facilities must have EPA ID num-bers. One number per worksite is required; mul-tifamily housing units may not require separatenumbers, if the housing project is a contiguousproperty (see the definition of “onsite” in 40CFR 260.10).

To obtain an ID number, generators should callor write the State hazardous waste managementagency or the nearest EPA regional office, andrequest EPA Form 8700–12, “Notification ofHazardous Waste Activity,” or the appropriateState form. The form should be completed andsubmitted to the State hazardous waste contactlisted in the accompanying information bookletbefore work begins.

10–15


B. Pretransport Requirements(40 CFR 262.30 Through262.34)

1. Onsite Accumulation of WasteUnder certain conditions, small-quantity gen-erators may accumulate up to 6,000 kg (ap-proximately 13,200 pounds) of hazardous wasteonsite for 180 days, or 270 days if the treatment,storage, or disposal site is more than 200 milesaway. Large-quantity generators may store suchwaste onsite for only 90 days. Under temporary,unforeseen, and uncontrollable circumstances,the generator may seek an accumulation periodextension of a maximum of 30 days from EPA(or an authorized State agency), if such exten-sion is obtained prior to expiration of the 90-day storage period. Generators storing hazardouswaste longer than these allowable time periodscan be fined for violations, and will be consid-ered storage facilities requiring RCRA regulation.

Generators storing hazardous waste onsite mustmeet certain requirements.

✦ Proper Storage: Both small- and large-quantity generators must label stored haz-ardous waste properly and indicate the accu-mulation start date (see Figure 10.3).

✦ Emergency Plan: Small-quantity generatorsmust have in their possession basic safetyinformation to be used during an emergency.Large-quantity generators must have a writ-ten emergency plan (see Figure 10.4).

✦ Personnel Training: Small-quantity genera-tors must ensure that their employees arefamiliar with emergency spill and accidentprocedures. Large-quantity generators musthave an established training program thatincludes the identification or availability of:

✦ Waste handling procedures.

✦ Emergency responseactions/contingency plans.

✦ Emergency contacts and equipment.

✦ Medical treatment and supplies.

✦ An emergency coordinator.

2. Waste Minimization PlansSection 3002(b) of RCRA requires small- andlarge-quantity hazardous waste generators todevelop written waste minimization plans.Since Federal regulatory requirements do notexist for these plans and existing EPA guidanceis geared toward industry, HUD recommendsthat contractors develop a short written plandescribing procedures to:

✦ Recycle, or otherwise dispose of, windowglass and other unpainted solid waste asappropriate.

✦ Clean plastic sheeting used for containmentby removing lead paint and dust.

✦ Avoid mixing hazardous and nonhazardouswaste.

✦ Recycle lead-based hazardous waste at anRCRA Part B-permitted lead smelter whenappropriate.

✦ Seek a waste management contractor withexperience in waste minimization.

✦ Consolidate paint chips.

✦ Remove unpainted components from thehazardous waste stream.

3. PackagingEPA has adopted the U.S. Department ofTransportation’s (DOT’s) hazardous materialstransport packing methods to prevent leakage ofwaste or release of dust during transport, and tomandate proper marking (or placarding) of thepackaged waste to identify associated character-istics and dangers. Hazardous waste transportersor disposal facilities can provide advice on ap-propriate packaging methods.

4. Selecting a Transporter and WasteManagement FacilitySince generators are liable for improper wastehandling, it is critical to select a hazardouswaste transporter and a management facilitythat have the proper EPA ID numbers andnecessary permits.

10

–16

Ch

apter 1

0: H

azardous an

d N

on

hazard

ous W

aste

Waste Management Practices Category I: Category II: Architectural Category III: Category IV:Low Lead Components1 Concentrated Lead Other WasteWaste Waste

Table 10.2 Management of Abatement Waste

Manage asnonhazard-ous solidwaste.

Depending upon knowledge orTCLP testing results, manageas solid hazardous or nonhaz-ardous waste.

Applicable if knowledge orTCLP testing indicates that it isnonhazardous.

X X X X

X X X X

X X X X

X X X X

X X X X

X X If appropriate X

RCRA Requirements


✦ Wrapped in plastic; seal all seamswith tape (if acceptable to the dis-posal facility).

✦ Stored in designated, securearea.

✦ Covered during transport.

✦ Prohibit cutting/breaking outsidework area.

✦ Cover ground with 6-mil plastic ifhandling outside.

✦ Prohibit disposal in solid wasteincinerators and reuse recyclingfor mulch.

✦ Recommend disposal in State-licensed/permitted solid wastelandfill.

X X X X

Applicable

If more than 100␣kg/month manage as haz-ardous waste. If lessthan 100 kg/monthmanage as solid waste.

Applicable if less than100 kg/month otherwisesubject to full RCRAregulations.

Use TCLP todetermine if waste isconsideredhazardous.

Only applicable ifTCLP testing showswaste is nonhazard-ous.

10–17


Generators should investigate the answers tothe following questions about facilities underconsideration:

✦ Do they have an EPA ID number?

✦ Have they successfully completed similarjobs?

✦ Can they supply references? How do thereferences describe their service?

✦ How long have they been in business?

✦ Has the firm been cited by EPA or Stateagencies for any environmental violations?

✦ How much waste are they capable of han-dling over a given period of time?

✦ Can they handle both solid and hazardouswastes?

✦ Are they willing and able to perform specialmanagement actions (such as covering ve-hicles during transport)?

✦ Do they have experience dealing withRCRA land disposal restrictions?

✦ Do they have insurance?

Generators should also check with other gen-erators, trade associations, the Better BusinessBureau, and the Chamber of Commerce regard-ing the firm’s qualifications. Written contractswith transporters and management facilities, ata minimum, should provide for the followingitems:

✦ Scope of work and schedule, includingwaste-segregation procedures.

✦ Testing and analysis of waste.

✦ Emergency procedures.

✦ Cost estimates and the handling ofoverruns.

✦ Payment procedures.

✦ Liability and responsibility for claims.

✦ Quality assurance plan.

Figure 10.3 Hazardous Waste Container Label WithAccumulation Start Date.

Property owners may want to consult with legalexperts on RCRA before signing contracts.

C. Manifesting the Waste (40CFR Part 262.20 Through262.22)

A hazardous waste manifest must accompany allhazardous waste shipments (unless the waste is

10–18


generated by a conditionally exempt, small-quantity generator). The manifest is a multicopyform that tracks the waste from generator to finaldisposal. The generator, transporter, and a repre-sentative of the designated management facilitymust each sign this document and retain a copy.

The generator’s signature certifies that (1) themanifest is complete and accurately describes theshipment, (2) the shipment is ready for transport,and (3) reasonable efforts have been made tominimize the amount and toxicity of the wastegenerated.

The designated waste management facility mustreturn a signed copy of the form to the genera-tor to confirm that the waste reached itsdestination. If this copy is not received by thegenerator within 35 days of shipment, the gen-erator must contact the transporter and/or theowner or operator of the disposal facility to de-termine the status of the shipment. If the signedmanifest copy is not received within 45 days ofshipment, the generator must send an exceptionreport to the EPA Regional Administrator (orauthorized State official). The exception report

Figure 10.4 Sample Emergency Plan.

The emergency coordinator is _________________. If not at the site, he/she can be reached at______________ 24 hours/day. The backup coordinator is _______________.

Emergency Procedures

In the event of a fire , call the local fire department immediately. Evacuate occupants and workers from thebuilding to a safe location.

If liquid hazardous waste spills onto soil or surfaces , contain the spill and attempt to clean it up, while takingprecautions to protect yourself.

If large quantities of liquid hazardous waste spill directly into a stream or other surface water , contact theNational Response Center to report the spill.

Emergency Phone Numbers (Post these numbers near a telephone. If no phone is available onsite, post thenumbers in a visible location and identify the nearest phone.)

Fire Department:Police Department:Local Emergency Response Coordinator:Backup Local Emergency Response Coordinator:National Response Center: 1–800–424–8802

Emergency Equipment

Have the following equipment onsite:

✦ Fire extinguisher.

✦ First aid supplies.

✦ Extra protective clothing and respirators.

✦ Material to contain and clean up spills.

Be sure all workers know where to locate these emergency supplies.

10–19


must include an explanation of the generator’seffort to ascertain the whereabouts of the wasteand the results of those efforts, as well as a copyof the signed manifest. The EPA or authorizedState will then initiate the process to locate themissing waste. This regulation is strictly enforced.

The manifest form is often provided to the gen-erator by the transporter or waste managementfacility. Blank manifest forms may also be ob-tained from the State hazardous waste agency(see Figure 10.5)

D. Land Disposal Ban Notifica-tion and Certification (40 CFR268.7 and 40 CFR 268.9)

RCRA requires that all hazardous waste meetcertain restrictions before it can be land dis-posed. Generators of more than 100 kg of haz-ardous waste per month must meet land disposalrestrictions (LDRs). In general, these restric-tions require that the waste be treated using aparticular method, or that it be treated to meeta specific numerical standard, before being land-disposed. The hazardous waste transporter ormanagement facility will assist in satisfying landdisposal restrictions, including completing ap-plicable paperwork.

Abatement projects producing hazardous leadwaste containing particles that will pass througha 60 mm (approximately 2.5 inches) sieve mustmeet land disposal restrictions for RCRA haz-ardous waste code D008. Such waste includespaint chips, dust, sludges, and filter cake. Tomeet the concentration-based extract standardfor lead, which is 5 ppm (see 40 CFR 268.42),land disposal restrictions require that D008waste be treated before it is sent to a hazardouswaste landfill (57 FR 37194, August 18, 1992).No technology is specified for treatment tomeet this standard. On September 14, 1993 (58FR 48092), EPA proposed alternative treatmentstandards for hazardous soil. When finalized, thesestandards would apply to any excavated soil that isconsidered hazardous.

Abatement projects that produce hazardouslead waste containing particles that will not

pass through a 60 mm sieve must meet thetreatment standards for hazardous debris. Suchdebris includes painted bricks, concrete, woodand woodwork, metal, plaster board, uncleanedplastic covering, and vacuum and respirator fil-ters. The land disposal restriction standards forhazardous debris provide two treatment alternatives:

✦ The waste may be “stabilized” to meet thepredisposal treatment standard for lead (40CFR 261.41 through 268.43) and then sentto a hazardous waste landfill (57 FR 37194,August␣18, 1992).

✦ The waste may be treated using several dif-ferent treatment methods: physical extrac-tion, chemical extraction, thermal extrac-tion, destruction, and immobilization (see40 CFR 268.45 Table 1, 57 FR 37278, Au-gust 18, 1992). If one of these methods isused, the treated wood or metal debris is nolonger considered hazardous and can be dis-posed of in a solid waste landfill. However,the residue from the treatment process mustbe treated to meet the concentration-basedstandard for lead (40 CFR 268.45(d), 57 FR37278, August 18, 1992).

Prohibitions on storage of “restricted” hazardouswaste (40 CFR 268.50) and requirements fortreating “restricted” waste in onsite tanks orcontainers are applicable to hazardous leadwaste (40 CFR 268.7).

The generator must either notify the hazardouswaste treatment/disposal facility that the wastedoes not meet the land-disposal treatment stan-dards or certify that the waste does meet thestandards. All notifications and certificationsmust identify the restricted waste, applicabletreatment standards, manifest number for thewaste shipment, and any available waste analy-sis data. The treatment standards are listed in40 CFR 268.41 through 268.43.

E. Recordkeeping (40 CFR262.40 through 262.44)

Generators must maintain three categoriesof records, which are described below.

10–20


Figure 10.5 Sample Waste Manifest.

10–21


1. Biennial ReportsLarge-quantity generators must submit a reportevery 2 years to the State hazardous wasteagency or EPA regional office that details thegenerator’s activities. Such reports are usuallynot required for abatement jobs of less than 2years’ duration.

2. Exception ReportsGenerators must retain copies of all exceptionreports identifying instances when a signedmanifest copy was not returned by the wastemanagement facility designated to receive thewaste shipment, and describing their efforts tolocate lost shipments. The generator is respon-sible for notifying EPA or the appropriate Stateagency of lost shipments.

3. Three-Year Retention of Reports,Manifests, and Test RecordsGenerators are required to retain all manifests,results of hazardous waste testing, and land-disposal notifications/certifications for 3 years.However, for liability reasons, records should bekept for at least 10 years.

The following types of information should beretained.

✦ Type of waste.

✦ Weight of shipments.

✦ Number of drums or containers shipped.

✦ TCLP results.

✦ Laboratory name.

✦ Identity of person conducting TCLPsampling.

✦ Location of samples.

✦ Hazardous waste storage locations.

✦ Type of storage containers.

✦ Abatement method.

✦ Name of property owner and contractor.

✦ Name of project designer (if applicable).

V. Waste ManagementCase Study

The following is a case study of typical wastemanagement practices in a lead hazard controljob. A single-family dwelling has undergone arisk assessment. The home is a single-storybuilding of approximately 1,500 square feet thatcontains three bedrooms and one bathroom.The risk assessor identified interim controls asan option for some surfaces and abatement asthe only option for others. The owner decidedto undertake a combination of interim controland abatement actions.

A. Lead Hazard ControlMeasures

Interim control measures consisted of cleaningand applying polyurethane to the woodenkitchen floor, replacing carpet in one bedroom,repainting certain areas, and treating frictionsurfaces on one door.

Abatement measures consisted of replacingselected woodwork (e.g., facia, exterior trimboard); replacing 17 windows and 1 exteriordoor; and wet scraping deteriorated paint frombathroom and kitchen walls and enclosing these ar-eas with gypsum board and melamine, as appropriate.

B. Waste Generated andManagement Steps Taken

Before work began, the owner and contractorheld a meeting and agreed in writing that thecontractor would handle all RCRA and otherState waste management requirements. Theowner agreed to sign the manifests prepared bythe contractor.

1. Interim Control WasteInterim control debris that was determined bythe State to be a household waste was managedas solid nonhazardous waste and sent to a solidwaste landfill. This waste included one HEPAvacuum filter, two respirator filters, cleanedplastic sheeting that had been used to containthe work area, discarded and rinsed tools,paint chips from limited scraping, discarded

10–22


carpeting, aluminum scraps left over from treat-ing friction surfaces, and waste water filters.

Approximately 20 gallons of liquid waste fromcleaning operations were produced. This wastewater contained potentially high levels of leadand phosphate. The water was filtered and thesolid material was disposed of as specified above.Filtered waste water was poured into the toiletafter permission was granted by the local waterauthority.

2. Abatement WasteIn anticipation of the work, the contractor de-veloped a waste minimization plan and con-ducted limited TCLP testing on the windowsand exterior trim that were slated for removal.This information was used to estimate wastedisposal costs, establish waste segregation proce-dures, and determine the necessity of obtainingan EPA ID Number. The contractor hired alaboratory to conduct TCLP testing (see Ap-pendix 10 for guidance in selecting labs); thelab agreed to fax test results to the contractorwithin 36 hours of receiving samples. The con-tractor also identified a hazardous waste con-tractor to handle such waste, if necessary.

After having removed all loose paint, the con-tractor provided the laboratory with two coresamples (core samples may be obtained using ahole saw) from the window and one exteriortrim sample in a 9.5 mm square. The test resultsindicated that none of the samples leached leadin excess of 5 ppm and thus both the windowsand exterior trim could be considered nonhaz-ardous waste. The contractor estimated thatCategory III and IV waste was unlikely to ex-ceed 220 pounds, and thus did not apply for anEPA ID Number. The contractor and propertyowner retained test results to document thewaste characterization decisions and handlingprocedures.

The contractor also developed waste-minimization specifications for workers,directing them to sort the waste into threecategories (after separating glass for recy-

cling): solid waste/architectural components,hazardous waste, and waste requiring TCLPtesting. Each category was managed separately.

RCRA solid nonhazardous waste (includingarchitectural components) consisted of 15 setsof personal protective clothing that was HEPAvacuumed prior to its removal, windows (onepile stacked approximately 10 feet high, 6 feetlong, and 5 feet wide), approximately 500 linearfeet of window trim, one exterior door, cleanedplastic sheeting, and rinsed rags and mops.

Glass was removed from the windows and sentto a local permitted glass recycling facility. Theremaining solid material was placed in 6-milplastic or heavy-duty plastic bags and sealedshut with tape. The material was stored in aseparate location and disposed of at a State-permitted solid waste landfill.

Filtered waste water was disposed of in thetoilet.

RCRA hazardous waste was stored in a 55-gallon drum in a garage, separate from the otherwastes. Hazardous waste included two HEPAfilters, dust/debris from the HEPA vacuum, tworespirator filters, and a small amount of paintchips. Total waste weighed less than 220 pounds(100 kg) and thus was managed as solid non-hazardous waste. The waste was disposed at aState-permitted landfill that met Federal designstandards (40 CFR 258).

Wastes requiring TCLP testing included unrinsedrags and mops, samples of which were cut intosmall pieces and sent to the laboratory. TCLPtesting results were as follows: sample leachablelead (ppm)—Rag 1=10.20, Mop 1=8.60.

These materials were added to the Category IIIRCRA hazardous waste. Because the total haz-ardous waste amount did not exceed 220pounds, it was sent to a State-permitted solidwaste landfill. The property owner and contrac-tor retained the TCLP test results to documentwaste characterization and handling decisions.

Documents

CHAPTER 10: HAZARDOUS NONHAZARDOUS WASTE