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Chaudhari, Narendra

From: Dennen, Mark (DEM) <mark.dennen@dem.ri.gov>

Sent: Tuesday, November 17, 2015 1:36 PM

To: Chaudhari, Narendra

Cc: Kirkland, Kim; Helms, Greg; Youngblood, Charlotte

Subject: RE: Solid Corrosive Hazardous Wastes

Attachments: r004query.xlsx

Here is a data pull on that code.  There are some significant gaps in our manifest data, but this gives you some idea of

how often it was used in our state.

Mark M. Dennen, CPG

RIDEM/Office of Waste Management

235 Promenade St.

Providence, RI 02908

tel. 401.222.2797 ext. 7112

fax 401.222.3812

e-mail: mark.dennen@dem.ri.gov

From: Chaudhari, Narendra [mailto:Chaudhari.Narendra@epa.gov]  

Sent: Tuesday, November 17, 2015 11:25 AM

To: Dennen, Mark (DEM) <mark.dennen@dem.ri.gov>

Cc: Kirkland, Kim <Kirkland.Kim@epa.gov>; Helms, Greg <Helms.Greg@epa.gov>; Youngblood, Charlotte

<Youngblood.Charlotte@epa.gov>

Subject: RE: Solid Corrosive Hazardous Wastes

Thank you for replying to my question so promptly.  The only other questions I have is as follows:  

Did RI track the wastes it determined to be solid corrosive hazardous wastes (R004), and, if the answer is yes, do you

have a database for R004 wastes that you can share with us?

From: Dennen, Mark (DEM) [mailto:mark.dennen@dem.ri.gov]  

Sent: Tuesday, November 17, 2015 10:52 AM

To: Chaudhari, Narendra <Chaudhari.Narendra@epa.gov>

Cc: Carney, Sean (DEM) <sean.carney@dem.ri.gov>; Li, Yan (DEM) <yan.li@dem.ri.gov>

Subject: RE: Solid Corrosive Hazardous Wastes

Thank you for your question.  We had, since the 80’s, had a wide variety of materials as state only hazardous waste.  As

of the last few years, we have been looking at those to see if we really want to regulate them.  Some like “slightly toxic

waste” with LD50>500 mg/kg we never really enforced (and a lot of products meet that definition). We felt like we

wanted to have a more limited group of materials we really enforced the rules on rather than a wider variety of those

subject to enforcement discretion.  Some of these, like PCB’s we felt we wanted to keep, as well as materials that have

certain levels of known or suspected carcinogens and we even added chemotherapy waste.  However, others like flash

point below 200, solid corrosives,  compounds will LD50> 500 mg/kg and “slightly  reactive waste” we asked the

question, both internally and externally‐ “Why are we regulating those?”  We couldn’t come up with a reason and

therefore, to simplify the rules took them out.

Does that answer the question?  Please contact me or Sean if you would like information or if you think there are things

we have not considered.
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Mark M. Dennen, CPG

RIDEM/Office of Waste Management

235 Promenade St.

Providence, RI 02908

tel. 401.222.2797 ext. 7112

fax 401.222.3812

e-mail: mark.dennen@dem.ri.gov

From: Chaudhari, Narendra [mailto:Chaudhari.Narendra@epa.gov]  

Sent: Tuesday, November 17, 2015 10:18 AM

To: Dennen, Mark (DEM) <mark.dennen@dem.ri.gov>

Subject: Solid Corrosive Hazardous Wastes

Hi Mark,

I was referred to you by Jim O’Leary in our division (Materials Recovery and Waste Management Division).  I hope you

can help me with a question I have on RI’s hazardous waste regulations for solid corrosives.  A colleague of mine recently

told me that RI Department of Environmental Management regulated solid corrosives as characteristic hazardous wastes

R004.  However, the R004 was deleted from the 2014 version of the RI’s hazardous waste regulations.  If this is true, I’m

trying to find out what caused RI to delete/not regulate solid corrosives as R004.  I would appreciate any information

you or someone in your department can provide me regarding past and present regulations of solid corrosives as

hazardous wastes.  Thank you.