Special Waste

Special waste¹ is a subset category of non-RCRA hazardous wastes.  A special waste classification is not an automatic determination and a generator must apply to DTSC to request a special waste classification on a case-by-case basis. Waste that qualify as special wastes are typically generated in larger volumes and pose less hazards.  Special wastes are eligible to be managed to less stringent standards, but the management is subject to other agency’s approval and not automatic.

1. Criteria and Requirement² – Special wastes must only be hazardous for inorganic chemicals. The constituent concentrations may only exceed their respective STLCs or TTLCs. The WET-soluble concentration (when expressed in mg/kg) cannot exceed its TTLC value.
2. Management³ – Special waste can go into non-Class I landfills⁴, but the landfill must have Waste Discharge Requirements (WDRs) for the special waste issued by the Regional Water Quality Control Board with jurisdiction over the facility, and the landfill operator must have a variance from DTSC which allows the disposal of the special waste at that particular facility.

References

¹ 22 CCR section 66261.120

² 22 CCR section 66261.122

³ 22 CCR section 66261.126

⁴ Class II or Class III landfills

Activity 5b: Hazardous Waste Characteristics and Categories

Scenario:

The Director received a frantic call from a concerned citizen (her neighbor) about Imaginariamine dihydrate. (This fictitious chemical — pronounced as “imaginary-amine dihydrate” — is for us to consider only for the purposes of this activity.) The neighbor says there are two drums of this chemical at his rental house, which he found after his renter left town abruptly. You have been assigned to research Imaginariamine dihydrate and inform the Director about whether this material is regulated by DTSC.

• Research Imaginariamine dihydrate (Safety Data Sheet).
• Research listed wastes:
  • Article 4: RCRA listed wastes
  • Article 4.1: California listed wastes
• Research Appendix X
• Research hazardous waste characteristics:
  • Article 3: Characteristics of hazardous waste
  • STLC and TTLC
  • TCLP

Question 1: For the purposes of this activity, assume that this chemical is a waste and is not exempted or excluded from classification as a hazardous waste.  Where, if anywhere, do you find Imaginariamine dihydrate in 22 CCR?

Question 2: For this question, consider the characteristic of toxicity only as determined by TCLP, STLC, and/or TTLC, as well as the other three hazardous waste characteristics in Article 3.  Which of the following characteristics does the waste exhibit? Select all that apply.

Question 3: We have already decided that Imaginariamine dihydrate is not toxic by the TCLP, STLC, or TTLC. Now let’s use the four acute toxicity criteria per 22 CCR section 66261.24. Does Imaginariamine dihydrate meet the characteristic of toxicity under any of these criteria?

Question 4: What category of hazardous waste does the Imaginariamine dihydrate belong in (select all that apply)?

Choose your selection(s)