The RCRA 8 Metals: What you need to know

RCRA 8 metals (As, Ba, Cd, Cr, Pb, Hg, Se, and Ag) are EPA-regulated to ensure proper waste classification and management.

If your company is a waste generator, RCRA 8 metals compliance is mandatory.

rcra labelled waste barrels in a waste accumulation area
10 NOV 2023 ALS

What are the RCRA 8 metals?

The RCRA 8 metals are:

  • Arsenic (As)
  • Barium (Ba)
  • Cadmium (Cd)
  • Chromium (Cr)
  • Lead (Pb)
  • Mercury (Hg)
  • Selenium (Se)
  • Silver (Ag)

 

Table of Contents:

  1. What are the RCRA 8 metals?
  2. Why are the RCRA 8 metals regulated?
  3. How are the RCRA 8 metals regulated?
  4. Regulatory guidance for RCRA 8 metals
  5. ALS Waste Testing Services
  6. EPA Limits for RCRA 8 Metals
  7. Why is TCLP testing important for RCRA 8 Metals?
  8. Testing considerations for RCRA 8 metals
  9. Get Compliant—Start TCLP Testing for RCRA 8 Metals

 

The Resource Conservation and Recovery Act (RCRA) is a law that regulates the safe management of hazardous waste in the United States. The EPA has considered the RCRA 8 to be particularly hazardous because they are toxic and can have serious health and environmental impacts.

RCRA 8 metals are found in a variety of industrial and commercial products, including batteries, electronics, paints, and pesticides. They can also be found naturally in the environment, but at much lower levels than in these products.

 

Why are the RCRA 8 metals regulated?

The RCRA 8 metals are regulated because they are toxic and can have serious health and environmental impacts. Exposure to these metals can cause a variety of health problems, including cancer, nervous system disorders, and reproductive problems. They can also damage the environment by contaminating soil and water.

 

How are the RCRA 8 metals regulated?

The RCRA 8 metals are regulated under Resource Conservation and Recovery Act (RCRA) by the U.S. Environmental Protection Agency (EPA). The EPA has established regulatory levels for RCRA 8 metals in groundwater surface water wastewater soil The EPA also regulates the disposal of hazardous waste, including RCRA 8 metal waste.

For a guide to understanding RCRA as a whole, check out our article: RCRA Compliance: Everything You Need to Know

 

Regulatory guidance for RCRA 8 metals

The EPA has published a number of documents that provide guidance on the regulation of RCRA 8 metals. These documents include:

  • RCRA 8 Metals Test Methods for Evaluating Solid Waste, SW-846
    This document provides instructions on how to test for RCRA 8 metals in solid waste. This information is useful for determining whether a waste is hazardous and whether it meets the requirements for land disposal.

  • Land Disposal Restrictions (LDR) for Metals
    The LDRs prohibit the land disposal of hazardous wastes that contain RCRA 8 metals above certain levels. Hazardous wastes that contain RCRA 8 metals above the treatment standards must be treated to reduce the concentrations of these metals below the treatment standards before they can be disposed of in a landfill.

  • Human Health Risk Assessment of Hazardous Waste Sites
    A human health risk assessment can be used to evaluate the potential risks posed by exposure to RCRA 8 metals at a contaminated site. This assessment considers the types and concentrations of RCRA 8 metals present at the site, the exposure pathways for people, and the potential health effects of exposure to these metals.

  • Ecological Risk Assessment Guidance for Superfund
    An ecological risk assessment can be used to evaluate the potential risks posed by exposure to RCRA 8 metals to plants and animals at a contaminated site. This assessment considers the types and concentrations of RCRA 8 metals present at the site, the exposure pathways for plants and animals, and the potential ecological effects of exposure to these metals.

These documents provide information on how to test for RCRA 8 metals in waste, how to dispose of RCRA 8 metal waste safely, and how to assess the risks posed by RCRA 8 metal contamination.

 

Why is testing for RCRA 8 metals important?

Testing for RCRA 8 metals helps to ensure that waste is properly classified and managed. For example, if a waste contains RCRA 8 metals at levels above hazardous waste thresholds, it must be disposed of as hazardous waste.

Second, testing for RCRA 8 metals helps to identify potential environmental risks. For example, if RCRA 8 metals are leaching from a landfill, they can contaminate groundwater and soil. By testing for RCRA 8 metals, project managers can identify and mitigate these risks.

Here are some specific actions you can take to become compliant with the RCRA 8 metal identification and testing requirements:

  • Determine whether your waste is a hazardous waste.
  • If your waste is a hazardous waste, determine whether it exhibits any of the RCRA 8 metal characteristics.
  • Test your waste for RCRA 8 metals using a recognized test method, such as the TCLP.
  • Use an accredited testing laboratory to conduct the tests.
  • Keep records of your waste identification and testing activities.

 

EPA Limits for RCRA 8 Metals

The EPA has also established regulatory limits for RCRA 8 metals in wastewater and soil. These hazardous waste limits are designed to protect human health and the environment from the hazards of RCRA 8 metals.

The following table shows the EPA regulatory limits for RCRA 8 metals in waste water:

Metal EPA Limit
Arsenic (As) 5.0 ppm (mg/L)
Barium (Ba) 100.0 ppm (mg/L)
Cadmium (Cd) 1.0 ppm (mg/L)
Chromium (Cr) 5.0 ppm (mg/L)
Lead (Pb) 5.0 ppm (mg/L)
Mercury (Hg) 0.2 ppm (mg/L)
Selenium (Se) 1.0 ppm (mg/L)
Silver (Ag) 5.0 ppm (mg/L)

 

The following table shows the EPA regulatory limits for RCRA 8 metals in TCLP Leachates:

Metal TCLP Limit
Arsenic (As) (mg/L)
Barium (Ba) 100 (mg/L)
Cadmium (Cd) (mg/L)
Chromium (Cr) (mg/L)
Lead (Pb) (mg/L)
Mercury (Hg) 0.2 (mg/L)
Selenium (Se) (mg/L)
Silver (Ag) (mg/L)

If the concentration of any RCRA 8 metal in a TCLP extract exceeds the regulatory TCLP limit, the waste is considered to be a hazardous waste and must be managed and disposed of accordingly.

 

Why is TCLP testing important for RCRA 8 Metals?

TCLP (toxicity characteristic leaching procedure) testing is important for RCRA 8 Metals because it simulates the leaching of these metals from soil in a landfill. The leachate is then analyzed to determine if the contaminants of interest are leached out of the contaminated soil and, if so the TCLP results are used to determine whether or not a waste can be land-disposed, or if it must be treated and disposed of as hazardous waste.

 

Testing considerations for RCRA 8 metals

Companies should be aware of the following considerations when planning and implementing RCRA 8 metals testing:

  • Sampling plan: The sampling plan should be designed to collect representative samples of the waste. The number of samples required will depend on the type of waste, the size of the waste pile, and the regulatory requirements.
  • Analytical methods: The analytical methods used to test for RCRA 8 metals must be sensitive and accurate. The EPA has approved a number of analytical methods for RCRA 8 metals testing.
  • Data interpretation: The data from RCRA 8 metals testing must be interpreted correctly in order to make sound decisions about waste management. The EPA's TCLP guidance document provides information on data interpretation.

ALS is an accredited laboratory and can provide guidance on creating a RCRA compliance plan.

 

Get Compliant—Start TCLP Testing for RCRA 8 Metals

ALS is an accredited testing laboratory offering TCLP testing for RCRA 8 metals. TCLP testing is a critical step in ensuring that RCRA 8 metal waste is properly identified and managed. By using an accredited testing laboratory, such as ALS, you can be confident that your TCLP results are accurate and reliable.

 

ALS offers TCLP testing to help you comply with the RCRA 8 metal identification and testing requirements.

  • ALS offers a wide range of testing services, including TCLP testing for RCRA 8 metals.
  • ALS's TCLP testing services are accredited by the National Environmental Laboratory Accreditation Program (NELAP).
  • ALS is a leading global provider of testing, inspection, and certification services.
  • ALS has a network of over 200 laboratories and offices in over 70 countries.

Accurate RCRA 8 metals classification is key to protecting the environment, complying with regulations, and optimizing your waste management practices. Contact ALS today to learn more about our waste testing services and ensure compliance with RCRA regulations.