Flooring Mastic Waste

Question: While my crew was removing floor tile and mastic, we had a visit from the local asbestos enforcement inspector. The inspector told me that my mastic remover residues are a hazardous waste? Is thon right?

Situation

During a floor tile removal project the local asbestos inspector showed up and insisted that the contractor had to dispose of the mastic remover as a hazardous waste. The contractor had never heard of this before and called us for more information; thon supplied an MSDS which showed four major solvent components (listed below) and a flashpoint of 150°F

Recommendations

This material is an Indiana municipal solid waste and can be taken to any permitted MSW landfill (just the same as any other commercial trash).

Analysis

Waste Status of Yourfeel Power Mastic Remover

According to the Yourfeel Power Mastic Remover MSDS and my discussions with the caller, this material is a mixture of solvents which is used to strip resilient floor covering mastic; the residue from the process (which is not liquid but a sticky sludge) is then put into containers for disposal.

Exempt Waste?

___yes _X_no

Indiana exempts construction materials such as road wastes, uncontaminated bricks, concrete, and soil, but this clearly does not fall in that category.

Construction/Demolition Debris?

___yes _X_no

Debris is chunks of material and includes only incidental sludgy materials. This containerized material does not meet the criterion

RCRA Hazardous Waste?

___yes _X_no

To be a hazardous waste, a material must be on one of the four EPA lists (F,K,P, or U) or have the characteristic of a waste (Toxic, Reactive, Ignitable or Corrosive).

  1. Listed: The only waste list that might apply is the K list for process wastes for non-specific wastes; in particular the nonhalogenated spent solvents F003-F005. However, none of the four solvents listed on the MSDS (1,2,4-trimethylbenzene, naphthalene, aromatic petroleum naphtha 150, and 2-butoxyethanol) is listed in F003-F005. Thus, this is not a listed waste.
  2. Characteristic:
    • Toxicity: None of the four components listed on the MSDS appears in the D004-D043 toxics list, so no testing is required.
    • Reactivity: This material is stable, non-explosive, and does not react with water (based on experience and on the information in the MSDS).
    • Ignitability: Since the material is not a liquid, the only question is whether it will ignite at room temperature spontaneously, or by friction, or by reaction with moisture. Again, experience and the MSDS make it clear that such ignition does not occur. By the way, even if it were a liquid it would not be an ignitable hazardous waste since the flashpoint (150°F) is higher than the 140°F maximum for a liquid ignitable hazardous waste.
    • Corrosivity: Their is no acidic or basic component listed on the MSDS, so no testing is required.

Municipal Solid Waste (by default):

_X_yes ___no

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