• Elk Environmental Services

Determining the type of waste your facility generates is tedious, but necessary to implement an efficient waste management process. It starts with determining if the waste generated is a solid waste. This may seem like an easy step, but the waste must first meet the Resource Conservation and Recovery Act’s (RCRA) definition of a solid waste. If it does, then it may be regulated by RCRA and classified as a hazardous waste. The next step is determining if the solid waste is a hazardous waste as defined by Environmental Protection Agency’s (EPA) regulations.

The EPA developed two ways of identifying solid wastes as hazardous wastes under RCRA. A solid waste is a hazardous waste if it is specifically listed as a known hazardous waste or if it exhibits a characteristic of a hazardous waste. Listed wastes are wastes from common manufacturing and industrial processes, specific industries and can be generated from discarded commercial products. Characteristic wastes are wastes that exhibit any one or more of the following characteristic properties: ignitability, corrosivity, reactivity or toxicity. In this blog, we will focus on the hazardous waste characteristic of corrosivity.

The corrosivity (D002) characteristic is one of the four hazardous waste characteristics that identifies a waste within given pH ranges and for liquids that corrode steel faster than a quarter of an inch per year under specified test conditions. Pursuant to 40 CFR 261.22, a solid waste exhibits the characteristic of corrosivity if a representative sample of the waste has either of the following properties:

  1. It is aqueous and has a pH less than or equal to 2 or greater than or equal to 12.5, as determined by a pH meter using Method 9040C in “Test Methods for Evaluating Solid Waste, Physical/Chemical Methods,” EPA Publication SW-846, as incorporated by reference in §260.11.
  2. It is a liquid and corrodes steel (SAE 1020) at a rate greater than 6.35 mm (0.250 inch) per year at a test temperature of 55° C (130° F) as determined by Method 1110A in “Test Methods for Evaluating Solid Waste, Physical/Chemical Methods,” EPA Publication SW-846, and as incorporated by reference in §260.11.

Non-aqueous liquids need only be tested using the steel corrosion test, whereas aqueous liquids are subject to both the steel corrosion test and the pH limits. For the purposes of 40 CFR 261.22 characteristic of corrosivity, aqueous waste is defined as a waste that is amenable to pH measurement (Memo, Bussard to Parsons; January 7, 1993 (RCRA Online #11719)).

Recognizing Corrosive Solids as Hazardous Waste

What’s interesting about the corrosivity characteristic is that the EPA doesn’t recognize physically solid forms of corrosive materials as a characteristic hazardous waste unless and until the EPA promulgates a definition of corrosivity for solids. The EPA’s characteristic of corrosivity presently applies only to aqueous and liquid wastes (Memo, Straus to Rookstool; August 18, 1987 (RCRA Online #11278)). The May 19, 1980, preamble, 45 FR 33109 states:

“…there is no demonstrated need to address corrosive solids at this time. EPA will, however, continue to seek information on the dangers presented by these wastes and will consider specific regulator measures if the need for more control becomes apparent.”

Yet, some states (e.g., California) do recognize corrosive solids as a type of hazardous waste per their own specific regulations (e.g., 22 CCR 66261.22).

Examples of corrosive hazardous waste include:

  • Hydrochloric Acid
  • Nitric Acid
  • Waste Sulfuric Acid from Lead-Acid Batteries
  • Rust Removers
  • Alkaline Cleaning Fluids

Elk has over 30 years of experience and expertise in transporting and disposing of corrosive hazardous waste to appropriate facilities. We also provide drums and totes for storage and transport. Contact us today to learn how our waste management services can benefit your facility!