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Are corrosive solids hazardous wastes?
Under the federal regulations, wastes must be “aqueous” or liquid to exhibit the corrosivity characteristic. [§261.22(a)] Although the regulations do not define “aqueous,” EPA has issued guidance that
an aqueous waste must be able to be tested for pH using Method 9040C. [SW-846] This test method specifies that it should be used only when “the aqueous phase constitutes at least 20% of the total volume of the ‘waste.’ Therefore, any waste for which this method is applicable must contain at least 20% free water by volume.” [RO 11738] This means that corrosive solids (e.g., sodium hydroxide pellets) are not regulated as corrosive waste at the federal level.
Some states have closed this gap by requiring corrosive solids to be mixed with a specified amount of water (usually 1:1 on a mass basis) and then tested for pH. If the mixture exhibits the corrosivity characteristic, the corrosive solids are regulated as state corrosive wastes. So check to see how your state regulated corrosive solids. Find more compliance morsels on our website.
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McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with any guidance provided above. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which such guidance may conflict. Any guidance above is general in nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with environmental regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.
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