RCRA Hazardous Waste ID in 3 Steps: Trichloroethylene
If you choose the wrong waste codes, your waste may not be treated properly—leading to environmental contamination, EPA civil penalties, liability for cleanup under CERCLA/Superfund, and even negative media attention. For more on the different kinds of RCRA waste codes and when they apply, read Simplify Your Approach to Waste ID.
What Is Trichloroethylene?
Trichloroethylene, or TCE, is a commonly used chemical in US industry. It serves a variety of cleaning, degreasing, and other purposes. When disposed of, TCE is regulated by US EPA as a hazardous waste. Like any other hazardous waste, TCE needs proper waste codes before it can be sent off for disposal. But what RCRA hazardous waste codes are applicable to this material?
We can determine which waste codes to use using 3 simple steps to waste ID. Let’s get started!
The 3 Steps to Hazardous Waste ID
- Gather physical and chemical data about the material.
- Determine or consider how the waste was generated.
- Perform the waste ID process in the RCRA regulations at 40 CFR 262.11.
Step 1: Gather Data About the Hazardous Waste
To properly identify any hazardous waste, you need information about its physical state and chemical properties. Whenever possible, generators should consult more than one source of data to make sure the information is accurate and complete. Places you might look for information about your hazardous waste include:
- Safety Data Sheets (SDSs)
- Chemical Books
- Online searches
- Manufacturers’ specification information
- Laboratory analyses
- Industry/Generator knowledge
Physical properties: Clear Liquid, sweet odor
Flash point: Not available (non-flammable)
pH: Not available
Chemical stability: Stable under normal ambient and anticipated storage and handling conditions of temperature and pressure.
Caution: Swallowing can result in nausea, vomiting, and central nervous system depression.
Step 2: How Did We Generate the Hazardous Waste?
Another factor that affects the assignment of applicable RCRA waste codes is how the material was used. (Note: If a material is disposed of before it’s used, our approach will be a bit different, and we’ll discuss this as part of Step 3.)
Approximately 80% of trichloroethylene is used as a solvent for vapor degreasing of fabricated metal parts and textiles. Another 5% is used as an ingredient to produce organic chemicals and pharmaceuticals. The remainder of the TCE is used as a solvent for dry cleaning and as a refrigerant/heat exchange liquid.
How our TCE was used—or not used, for that matter—will inform how we select waste codes in the next and final step.
Step 3: Follow the Hazardous Waste Determination Method Specified at 40 CFR 262.11
To know what type of hazardous waste we have and apply the right codes, we first must determine if our material is in fact a hazardous waste at all. At 40 CFR 261.4, EPA provides exclusions from the definition of solid/hazardous waste. There are no exclusions specifically for the management of waste TCE.
Next, we must see if our waste exhibits a hazardous waste characteristic described at 40 CFR 261, Subpart C or appears on a list in 40 CFR 261, Subpart D. From a practical perspective, you may do this in either order—but you must do both. Let’s start with the characteristics.
The four RCRA hazardous waste characteristics and the general criteria for each are as follows:
|Waste Code||Characteristic||Generally based on…||40 CFR Reference|
|D002||Corrosivity||pH and corrosion of steel||§261.22|
|D004–D043||Toxicity||Certain levels of 40 specific contaminants||§261.24|
Since TCE does not meet the flash point or pH criteria for ignitability and corrosivity, respectively, and it is stable, it is not a D001, D002, or D003 hazardous waste. Trichloroethylene is, however, one of the toxicity characteristic contaminants and, if our waste contains greater than 0.5 mg/L TCE, it would carry the D040 waste code.
Next, let’s determine if our waste is described on a list. This is where it becomes important to know how the waste was generated.
If the TCE is “used” or “spent” (i.e., it has gone through some sort of process), we will look at the F codes at 40 CFR 261.31 or the K codes at 40 CFR 262.32. Trichloroethylene is listed in two places on the F List and we would look here only if our TCE was used for its solvent properties.
Unused Commercial Chemical Product
- If the TCE was used for its solvent properties in a degreasing process, we would assign it the F001 waste code.
- If the TCE was used for its solvent properties in a process other than degreasing (e.g., dry cleaning), it would carry the F002 waste code.
- If the TCE was used in a process, but not for its solvent properties (e.g., as a heat exchange fluid), it would not be assigned an F code.
P codes apply to commercial chemical products that are acutely hazardous. [40 CFR 261.33(e)] U codes apply to unused products with sole active ingredients, off-spec batches of such products, and residues from storage or cleanup of spills of such products. [40 CFR 261.33(f)] Unused trichloroethylene is listed as a U228.
Lastly, we give our waste all applicable waste codes and keep a detailed waste profile record to substantiate our decisions.
No matter what type(s) of hazardous waste you generate or come across at your site, use the simple three-step process above to identify the waste and make accurate determinations. Assigning the proper waste codes is critical to protect the environment from contamination and shield your business from civil penalties and future liability.
RCRA Training for New and Experienced Pros
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