Waste Knowledge

DOE-HDBK-1129-99

addition of new streams or changes to existing streams. In addition, the regulations must be

monitored to address promulgated and proposed changes that affect current or future

characterization programs.

The Resource Conservation and Recovery Act (RCRA), an amendment to the Solid Waste

Disposal Act, was enacted in 1976 to address the management of municipal and industrial wastes.

RCRA includes a number of subtitles. Subtitle C of RCRA directs the management of hazardous

waste. This subtitle imposes administrative provisions to ensure accountability for hazardous

waste management, as well as substantive requirements designed to protect human health and

the environment from the effects of improper management of hazardous waste. Under the RCRA

implementing regulations, hazardous waste is defined as any solid waste exhibiting one or more of

the characteristics of hazardous waste -- ignitability, corrosivity, reactivity, and metal or organic

compound toxicity [40 CFR 261.20 - .24]; or is included on one of three lists of hazardous wastes

[40 CFR 261.30 - .33]. These lists include hazardous wastes generated by nonspecific (F-listed

wastes) and specific sources (K-listed wastes), in addition to commercial chemical products (P-

and U-listed wastes). RCRA was amended significantly in 1984 by the Hazardous and Solid

Waste Amendments (HSWA), which expanded the scope and requirements of RCRA. Among

other things, HSWA required EPA to evaluate all listed and characteristic hazardous wastes, and

to develop requirements (i.e., treatment standards) that must be achieved prior to land disposal of

these wastes. The implementing regulations for accomplishing this statutory requirement are

established within the Land Disposal Restrictions (LDR) program [40 CFR 268].

In conjunction with the hazardous waste and LDR-related waste determinations, additional

physical and chemical information may be required depending on the treatment or disposal options

being considered. These parameters may include, but are not limited to, the assessment of the

waste for free liquids, headspace gases, chelating agents, anions/cations, PCBs, particulate,

explosives, pyrophorics, and waste matrix composition.

8.2.1 Waste Knowledge

Waste knowledge or acceptable knowledge refers to information used to support waste

characterization activities. In recent regulatory preambles and guidance, EPA uses the terms

"waste knowledge" or "acceptable knowledge" in place of the term "process knowledge." The

terms "waste knowledge" or "acceptable knowledge" are broader terms that include process

knowledge, waste analysis data obtained from generators, and existing records of analysis, or a

combination of this information supplemented with chemical analysis. Process knowledge is the

common terminology for the RCRA regulatory language "applying knowledge of the hazard

characteristic of the waste in light of the materials or the processes used." [40 CFR 262.11(c)(2)]

EPA has defined process knowledge to include detailed information on the wastes obtained from

existing published or documented waste analysis data or studies conducted on hazardous wastes

generated by similar processes [see Joint NRC/EPA Guidance on Testing Requirements for Mixed

Radioactive and Hazardous Waste, November 20, 1997 (62 FR 62079); and Waste Analysis at

Facilities that Generate, Treat, Store, and Dispose of Hazardous Wastes: A Guidance Manual,

OSWER 9938.4-03, April 1994]. Process knowledge includes any documentation that describes or

verifies a facility's history, mission, and operations, in addition to waste stream-specific information

used to define generating process, matrix, contaminants, and physical properties. Waste-

generating facilities should maintain and utilize waste knowledge to characterize waste streams

(i.e., in lieu of sampling and analyzing the waste), whenever possible, to avoid unnecessary

exposures to radioactivity and eliminate needless or redundant waste testing. This requires the

generator to maintain auditable records that document the composition of the waste, including

waste matrix and contaminants.