Does RadTech have any information on the proper disposition of 100% solids UV/EB waste?

I’m sure it probably needs to be incinerated or something, but I’m looking for a document or something “official” to show the powers that be at my company.

By definition, EPA determined that some specific wastes are hazardous. These wastes are incorporated into lists published by the Agency and are organized into three categories:

1. The F-list (non-specific source wastes). This list identifies wastes from common manufacturing and industrial processes, such as solvents that have been used in cleaning or degreasing operations. Because the processes producing these wastes can occur in different sectors of industry, the F-listed wastes are known as wastes from non-specific sources. Wastes included on the F-list can be found in the regulations at 40 CFR §261.31 .
2. The K-list (source-specific wastes). This list includes certain wastes from specific industries, such as petroleum refining or pesticide manufacturing. Certain sludges and wastewaters from treatment and production processes in these industries are examples of source-specific wastes. Wastes included on the K-list can be found in the regulations at 40 CFR §261.32 .
3. The P-list and the U-list (discarded commercial chemical products). These lists include specific commercial chemical products in an unused form. Some pesticides and some pharmaceutical products become hazardous waste when discarded. Wastes included on the P- and U-lists can be found in the regulations at 40 CFR §261.33 .

Waste that have not been specifically listed may still be considered a hazardous waste if exhibits one of the four characteristics defined in 40 CFR Part 261 Subpart C - ignitability (D001), corrosivity (D002), reactivity (D003), and toxicity (D004 - D043).

1. Ignitability - Ignitable wastes can create fires under certain conditions, are spontaneously combustible, or have a flash point less than 60 °C (140 °F). Examples include waste oils and used solvents. For more details, see 40 CFR §261.21 . Test methods that may be used to determine ignitability include the Pensky-Martens Closed-Cup Method for Determining Ignitability (Method 1010A) (PDF) (1 pg, 19K) , the Setaflash Closed-Cup Method for Determining Ignitability (Method 1020B) (PDF) (1 pg, 17K) , and the Ignitability of Solids (Method 1030) (PDF) (13 pp, 116K) .

2. Corrosivity - Corrosive wastes are acids or bases (pH less than or equal to 2, or greater than or equal to 12.5) that are capable of corroding metal containers, such as storage tanks, drums, and barrels. Battery acid is an example. For more details, see 40 CFR §261.22 . The test method that may be used to determine corrosivity is the Corrosivity Towards Steel (Method 1110A) (PDF) (6 pp, 37K) .

3. Reactivity - Reactive wastes are unstable under "normal" conditions. They can cause explosions, toxic fumes, gases, or vapors when heated, compressed, or mixed with water. Examples include lithium-sulfur batteries and explosives. For more details, see 40 CFR §261.23 . There are currently no test methods available.

4. Toxicity - Toxic wastes are harmful or fatal when ingested or absorbed (e.g., containing mercury, lead, etc.). When toxic wastes are land disposed, contaminated liquid may leach from the waste and pollute ground water. Toxicity is defined through a laboratory procedure called the Toxicity Characteristic Leaching Procedure (TCLP) (Method 1311) (PDF) (35 pp, 288K) . The TCLP helps identify wastes likely to leach concentrations of contaminants that may be harmful to human health or the environment. For more details, see 40 CFR §261.24 .

Unless the UV/EB curing formulation is diluted with solvents, it typically does not meet the “ignitability” characteristic. UV/EB curing formulations also typically do not exhibit the EPA “corrosivity” criteria. UV/EB curing materials generally do not meet the “toxicity” characteristic, but formulations that contain toxic components, such as certain solvents or heavy metal pigments, may be identifiable as “toxic”.

Most UV/EB formulations do not meet the “reactivity” characteristic, but a few that comprise or contain mostly highly functional acrylates, such as PETA, DiPETA, DiTMPTA etc., have been known to react with the evolution of heat and fumes. These should be evaluated to determine whether they meet the “reactivity” criteria. If in doubt, they should be disposed of as potentially “reactive” wastes.

The waste generator has responsibility for determining if a waste is a RCRA hazardous waste. (See: 40 CFR 262.11). Four questions must be considered to determine whether the waste is hazardous:

1. Is the material a solid waste? (See: 40 CFR Part 261.2)2. Is the waste specifically excluded form RCRA? (See: 40 CFR Part 261.4)3. Is the waste a listed hazardous waste? (See: 40 CFR Part 261.30) 4. Does the waste exhibit a characteristic of hazardous waste? (See: 40 CFR Part 261.20)

If a UV/EB curing formulation, or UV/EB curing oligomers or monomers or photoinitiators, or clean-up wastes, or contaminated filters, wipes etc. meet any of these criteria, they must be disposed of in full compliance withy all applicable federal, state and local hazardous waste regulations.

If these wastes are not listed hazardous wastes or do not meet any of the hazardous waste characteristics, they may be disposed of as non-hazardous wastes in full compliance with all state and local regulations that apply to similar paints and coatings materials. This may require solidification or other treatment before disposal in a municipal land fill, so disposal as a hazardous waste may be a preferred alternative.