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Hazardous Waste Determination

Hazardous Waste Determination

Background Information

Shepherd University and its generators of hazardous waste are required to make hazardous waste determinations when generating solid waste.  Furthermore, the University is required to keep records of its hazardous waste determinations for three years.  After receiving hazardous waste training, generators should be able to make waste determinations of their waste streams.  The hazardous waste determination process is one of, if not, the most important steps in the hazardous waste management process. Without waste determinations being made or if improper waste determinations are made, generators may not manage their waste appropriately.  Additionally, the University is unable to accurately account for its monthly and total hazardous waste quantities.  This can lead to compliance problems as well as an increased risk to environmental and human health.

Generator Responsibility

Each generator at Shepherd University is required to make hazardous waste determinations of the wastes in which they generate.  Prior to engaging in actions or initiating processes that generate waste, generators are encouraged to decide if their waste stream(s) will generate hazardous waste.  This will enable generators to be better prepared to manage their wastes appropriately.

Hazardous Waste Determination Process

Step 1:  Is It “Solid Waste?”

Step 2:   Is It A Listed Hazardous Waste?

Is the waste specifically listed in RCRA regulations?  Listed hazardous wastes appear on four lists which are as follows:

The listed hazardous wastes (F-, K-, P- and U-Listed) may be found by clicking here.

Step 3:  Is It A Characteristic Hazardous Waste?

Does the waste exhibit one or more characteristics of a hazardous waste?  The characteristics are as follows:

1. Ignitability (D001): Wastes that are hazardous due to the ignitability characteristic include liquids with flash points below 60°C, non-liquids that cause fire through specific conditions, ignitable compressed gases and oxidizers. 

2. Corrosivity (D002): Wastes that are hazardous due to the corrosivity characteristic include aqueous wastes with a pH of less than or equal to 2, a pH greater than or equal to 12.5 or based on the liquids ability to corrode steel.

3. Reactivity (D003): Wastes that are hazardous due to the reactivity characteristic may be unstable under normal conditions, may react with water, may give off toxic gases and may be capable of detonation or explosion under normal conditions or when heated.

4. Toxicity (D004-43): Wastes that are hazardous due to the toxicity characteristic are harmful when ingested or absorbed. Toxic wastes present a concern as they may be able to leach from waste and pollute groundwater. The toxicity of a waste is determined by the Toxicity Characteristic Leaching Procedure (TCLP).

The characteristic hazardous waste codes (Waste Codes D001-43) may be found by clicking here.

Hazardous Waste Determination Sheet

A “Hazardous Waste Determination Sheet” was created to help guide generators through the waste determination process. Furthermore, documentation of the hazardous waste determination can be achieved by completing the sheet. Generators are encourage to complete the Hazardous Waste Determination Sheet for each waste that they generate. Documentation of all hazardous waste determinations made at Shepherd University is required by the US EPA and WV DEP.  Records are to be kept for at least three years. This document will ensure that generators and the University are meeting the hazardous waste determination requirement.  The Campus Environmental Safety Coordinator (CESC) is available to assist generators in completing the Hazardous Waste Determination Sheet.  The CESC will keep records of all completed Hazardous Waste Determination Sheets.

Hazardous Waste Determination Sheet

From May of 2001 to May of 2011, colleges, universities and professional schools accounted for the fourth highest non-compliance rate for hazardous waste determinations in the United States [Environmental Protection Agency. (2013). Hazardous Waste Determination Program Evaluation: Final Report (EPA Publication No. 100-K-12-010)].