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Waste Classification Workshop

Waste Classification Workshop. TCEQ Environmental Trade Fair Austin Convention Center May 6, 2014 Keith Witter Waste Permits Division. Texas Waste Codes. 8-character identification number consisting of: Sequence number Form Code Classification. Sequence Number.

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Waste Classification Workshop

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  1. Waste Classification Workshop TCEQ Environmental Trade FairAustin Convention Center May 6, 2014 Keith Witter Waste Permits Division

  2. Texas Waste Codes • 8-character identification number consisting of: • Sequence number • Form Code • Classification

  3. 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

  4. Sequence Numbers Cont’d. • “OUTS” used for wastes generated outside Texas • “CESQ” used by municipal hazardous and industrial conditionally exempt small-quantity generators (CESQGs)

  5. Sequence Numbers Cont’d. • “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

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

  7. Classification • 1-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

  8. EXAMPLE: 1 Mike’s 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.

  9. Ex. 1 - Waste Classification Information • Process Knowledge: • The waste stream is comprised of aluminum oxide blast media, carbonized steel, and dried paint.

  10. 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 in 40 CFR 261.24, Table 1. The dried paint does not include any regulated organic chemicals.

  11. Ex. 1 – Testing Information • A representative sample of the sand blast waste was collected and preserved per sampling plan and was sent to a registered National Environmental Laboratory Accreditation Certification(NELAC) lab for TCLP metals analysis. • All regulated metals test below the class I industrial regulatory limit.

  12. Ex. 1 – Coding Assignment • Sequence number - as the facility has nine waste codes on their NOR (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.

  13. 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 includes: sequence number, form code and waste determination.

  14. Example: 2 Amy’s 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.

  15. 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.

  16. Ex. 2 - Process Knowledge Information • 30 TAC § 335.508(2)(A)(i) indicates 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.

  17. Ex. 2 - Process Knowledge Information Continued • 30 TAC § 335.508(6) indicates that waste streams with total petroleum hydrocarbon concentrations >1,500 ppm are defined as industrial Class I waste.

  18. Ex. 2 - Process Knowledge Information Continued Class I Constituents Maximum Leachable Concentrations in Appendix G at 30 TAC § 335 Subchapter R, Appendix 1, Table I, indicates that there is an industrial class I concentration for both Ethylene glycol and Pyridine.

  19. 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.

  20. Ex. 2 - Coding Assignment • Sequence number - the facility has 10 codes on their NOR (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.

  21. Ex. 2 - Determination • Classification – process knowledge by rule defaults to Class I Industrial Waste • Waste Code – 0011 406 1 • The waste code includes: sequence number, form code and waste determination.

  22. Example: 3 Bill’s Industrial Plant • Bill’s Industrial Plant has a sister plant in Acuna, Mexico. The plant generates supplemental plant production refuse. Bill’s Industrial Plant wishes to dispose of this waste stream in a permitted Municipal Solid Waste landfill in Texas.

  23. Ex. 3 - Waste Classification Information • Bill’s supplemental plant production refuse includes used metal pump parts, cardboard & styrofoam packaging materials and broken unusable wooden pallets.

  24. Ex. 3 - Process Knowledge Information • 30 TAC § 335.508(3)(b), waste streams with metal pump parts, cardboard and styrofoam packaging materials and broken unusable wooden pallets are defined as Class II Industrial Waste.

  25. Ex. 3 - Generator Decision • The facility plans to bring an out of state Class II Industrial Waste into Texas. • They are required to apply for a Special Waste Authorization under 30 TAC § 330.3(148)(Q)(i).

  26. Ex. 3 - Coding Assignment • Sequence number - the facility does not have an NOR. The facility chooses OUTS for the waste stream. • Form Code - Supplemental Plant Production Refuse from Appendix G (30 TAC § 335 Subchapter R, Appendix 3) is 902.

  27. Ex. 3 - Determination • Classification – process knowledge by rule defaults to Class II Industrial Waste • Waste Code – OUTS 902 2 • The waste code includes: sequence number, form code and waste determination.

  28. EXAMPLE: 4 Susan’s Industrial Plant • The plant generates wastewater sludge from sumps attached to their formaldehyde product tank. The sumps collect wash down water, transfer spills, pipe leaks and solids that settled in the product tank during cleaning.

  29. 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.

  30. Ex. 4 - Process Knowledge Information • U Listings only apply to unused chemical products as per 40 CFR § 261.33(a)(f).

  31. Ex. 4 - Generator Decision • The mixture/derived from rule found in 40 CFR § 261.3(c)(d) specifies any sludge waste stream derived from a Listed waste carries the applicable listing(s) as well.

  32. Ex. 4 - Coding Assignment • Sequence number - the facility has 11 waste codes on their NOR (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.

  33. Ex. 4 - Determination • Classification – process knowledge by rule defaults to hazardous. • Waste Code – 0012 609 H • The waste code includes: sequence number, form code and waste determination.

  34. EXAMPLE: 5 Scott’s Oil & Gas Exploration • Scott’s Oil & Gas Exploration Company is a Division of Mike’s Industrial Plant. They are an oil field service company offering drilling services for oil and gas development. They are regulated by the Railroad Commission of Texas.

  35. Ex. 5 - Waste Classification Information • The waste stream is comprised of drill cuttings consisting of native soil, crude oil, bentonite clay, and drilling fluid.

  36. Ex. 5 - Process Knowledge Information • Exclusion under 40 CFR Part § 261.4(b)(5) indicates 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.

  37. 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.

  38. Ex. 5 - Coding Assignment • Scott’s Oil & Gas Exploration Company is regulated by the Railroad 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.

  39. Ex. 5 - Determination • Classification – process knowledge by rule defaults to Industrial Class I • Waste Code – RRCT 489 1 • The waste code includes: sequence number, form code, and waste determination.

  40. EXAMPLE: 6 Todd’s Oil & Gas Exploration • Todd’s Oil & Gas Exploration Company has a equipment yard with a wash bay for their heavy equipment. Over the years the wash bay has leaked into adjacent soil. Todd has decided to excavate the leaking wash bay and remove the effected soils.

  41. Ex. 6 - Waste Classification Information • From a site investigation, it is estimated that 250 cubic yards of oil impacted excavation soils will be generated • The waste stream is comprised of native soil contaminated with low levels of crude oil constituents.

  42. Ex. 6 - Process Knowledge Information • Exclusion under 40 CFR Part § 261.4(b)(5) indicates 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. • .

  43. Ex. 6 - Generator Decision • The initial site investigation indicates the waste has minimal contaminants of concern therefore Todd’s Oil & Gas has decided to do representative sampling of the excavation spoils. The test results do not exceed values found on Appendix 1, Table 1, of Subchapter R or exceed1,500 ppm TPH.

  44. Ex. 6 - Coding Assignment • Todd’s Oil & Gas Exploration Company is regulated by Railroad 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.

  45. Ex. 6 - Determination • Classification – process knowledge by rule defaults to industrial Class I, with analytical testing a Class II determination is made. • Waste Code – RRCT 489 2 • The waste code includes: sequence number, form code, and waste determination.

  46. How to Reach UsTCEQWaste Permits DivisionTechnical Analysis Group, MC-130P.O. Box 13087Austin, TX 78711-3087Phone: 512-239-6412Fax: 512-239-6383www.tceq.texas.gov

  47. Questions • Keith Witter • Chemist • Industrial & Hazardous Waste • Waste Permits Division • (512) 239-6863

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