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Air Emissions (RCRA)
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Test Methods
Toxicity Characteristic
	11/12/2004	REGULATORY DETERMINATION OF DISCARDED LEATHER PRODUCTS UNDER RCRA	Memo
	Description: There is no data demonstrating that discarded leather products exhibit the toxicity characteristic (TC) for chromium as a result of the tanning process.
	01/20/2004	SEMI-VOLATILE CONSTITUENT ANALYSIS AND ANALYTICAL LEVEL OF DETECTION LIMITATIONS OF THE TOXICITY CHARACTERISTIC LEACHING PROCEDURE (TCLP)	Memo
	Description: A generator may use process knowledge regarding how a waste is generated and scientific knowledge regarding chemical reactions to identify the constituents of concern for analysis. It is not necessary to test for all TCLP consitituents if the waste is determined to be nonhazardous using process knowledge. If a waste is 100% solid as defined by TCLP method 1311, the results of the total constituent analysis may be divided by twenty to convert the total results into the maximum leachable concentration. If it is a filterable liquid, then the concentration of each analyte phase must be determined.
	01/06/2004	WOOD MULCH DERIVED FROM WASTE LUMBER PRESERVED WITH CHROMATED COPPER ARSENATE (CCA)	Memo
	Description: Discarded arsenical-treated wood or wood products that are utilized for their intended end use and are only hazardous for waste codes D004 through D017 are excluded from RCRA regulation in 261.4(b)(9). Intended end uses of arsenical-treated wood products, including CCA-treated wood, are as building materials. CCA-treated wood used to produce wood mulch is not the materials' intended end use. Therefore, wood mulch produced from CCA-treated wood is not excluded in 261.4(b)(9). The Consumer Awareness Program (CAP) and the Consumer Safety Information Sheet for Inorganic Arsenical Pressure-Treated Wood discourage the use of CCA-treated wood as mulch.
	01/01/2004	CONTAMINATED MEDIA AND DEBRIS FROM RESIDENTIAL HEATING OIL TANKS	Memo
	Description: An UST storing heating oil for consumptive use on the premises where stored is not covered under the exclusion for petroleum-contaminated media and debris in 261.4(b)(10). These tanks are excluded from the definition of an UST in 280.12. Contaminated media and debris from a residential UST are household wastes as described in 261.4(b)(1).
	12/16/2003	HAZARDOUS WASTE CHARACTERISTICS SCOPING STUDY	Memo
	Description: The Hazardous Waste Characteristics Scoping Study reviewed the current hazardous waste (HW) characteristics that address the properties of ignitability, corrosivity, reactivity, and toxicity. The study examined the effectiveness of the regulations in identifying HW, whether other waste properties should be used to classify HW, and whether HW characteristics should be expanded. The study found that most nonhazardous waste is managed appropriately when disposed. The study identified the need for investigations on the risk of waste releases to air, on the potential for hazardous constituents to leach from waste, and on the measurement of ignitability, corrosivity, and reactivity. The air studies found no need for additional regulation. Other investigations are underway.
	10/23/2003	TREATMENT STANDARDS FOR MERCURY-CONTAINING DEBRIS	Memo
	Description: D009 mercury wastes have LDR treatment standards for low mercury and high mercury-inorganic subcategories. LDR treatment standards include specified technologies such as RMERC, commonly called retorting. Macroencapsulation and microencapsulation are alternative LDR treatment technologies for D009 debris and do not depend on mercury levels in the debris. If alternative treatment standards are not used, the waste is subject to the non-debris standards in 40 CFR 268.40. The definition of debris is located in 268.2(g). Intact containers of mercury (e.g., thermometers, batteries) are not debris (SEE ALSO: 57 FR 37194, 37225; 8/18/92). Intact containers mixed with debris must be removed and managed separately. Certain mercury-containing items may be universal waste (SEE ALSO: 70 FR 45508; 8/5/05). Mercury-containing CESQG and household hazardous waste is exempt from RCRA regulations. Retorters are capable of accepting mercury-containing debris with certain limitations and exceptions. Source separation involves removing mercury-contaminated material from debris. Macroencapsulation involves mixing waste with reagents and stabilization materials to produce a more stable waste form. Macroencapsulation uses surface coatings or jackets to reduce surface exposure to leaching media.
	08/01/2002	HAZARDOUS CHARACTERISTIC SCOPING STUDY	Memo
	Description: The Hazardous Waste Characteristics Scoping Study reviewed the effectiveness of the current hazardous waste characteristics regulations to identify whether other waste properties should be used to classify waste as hazardous or if the current characteristics should be expanded. EPA also collected data on toxic chemical releases from landfills. The current regulations ensure that most hazardous waste is addressed properly, but the Scoping Study identified areas that deserve additional investigation, including waste constituent releases to air and identifying supplements to the Toxicity Characteristic Leaching Procedure (TCLP). EPA has set priorities for completion of follow-up studies. Any revision of the TC regulation would have to take into account a number of considerations, including updated groundwater models.
	07/29/2002	RESULTS OF HAZARDOUS CHARACTERISTIC SCOPING STUDY	Memo
	Description: The Hazardous Waste Characteristics Scoping Study did not identify hazards that warrant regulatory changes, but identified areas that deserve additional investigation, including waste constituent releases to air and identifying supplements to the Toxicity Characteristic Leaching Procedure (TCLP). EPA collected data on toxic chemical releases from landfills. The toxicity characteristic (TC) regulation remains an appropriate tool for defining hazardous waste. EPA will continue to examine the hazardous waste characteristics. States may develop regulations that are more inclusive than the federal program.
	06/14/2002	HAZARDOUS CHARACTERISTIC SCOPING STUDY	Memo
	Description: The Hazardous Waste Characteristics Scoping Study reviewed the effectiveness of the current hazardous waste characteristics regulations to identify whether other waste properties should be used to classify waste as hazardous or if the current characteristics should be expanded. EPA also collected data on toxic chemical releases from landfills. The current regulations ensure that most hazardous waste is addressed properly, but the Scoping Study identified areas that deserve additional investigation, including waste constituent releases to air and identifying supplements to the Toxicity Characteristic Leaching Procedure (TCLP). EPA has set priorities for completion of follow-up studies. Any revision of the TC regulation would have to take into account a number of considerations, including updated groundwater models.
	10/11/2001	REGULATORY STATUS OF ANTIMONY OXIDE SLAG	Memo
	Description: Currently antimony oxide slag is not a hazardous waste because a final decision has not been made to list the slag as hazardous (SEE ALSO: 66 FR 58258; 11/20/01). The management of any secondary material, including use in the production of a product, may be subject to state regulations. A waste that is actively managed after the effective date of a listing would be subject to the listing. Slag used as an ingredient in product asphalt prior to the effective date of the listing would not be a hazardous waste when actively managed after the effective date of the listing, unless it exhibited a hazardous waste characteristic. Since the listing does not apply at the time of use, the use would not be subject to RCRA jurisdiction. Any releases from the material to the environment could be considered wastes and addressed under Section 7003 of RCRA.
	05/17/2001	REGULATORY STATUS OF DROP-OUT SLAG GENERATED AT ELECTRIC ARC FURNACES	Memo
	Description: Drop-out box slag (DOBS) generated at electric arc furnaces (EAFs) is not covered by the K061 listing, which includes dust and sludge from EAF emissions. DOBS does not meet the description of dust or sludge as defined in the K061 Listing Background Document. Material in ductwork leading to or collected in air pollution control devices may meet the K061 definition. DOBS may exhibit the toxicity characteristic for various metals, but would not be a solid waste if sent for legitimate recycling.
	12/15/2000	COMBUSTION PROHIBITION AND EXPLOSIVE WASTES	Memo
	Description: Toxicity characteristic (TC) metal wastes are prohibited from dilution by combustion unless one or more of the criteria in 268.3(c) are met. D003 explosive wastes that are also TC metal wastes may be combusted under 268.3(c)(5). Explosive wastes contain hazardous concentrations of organics.
	07/31/2000	REGULATORY STATUS OF WASTE GENERATED BY CONTRACTORS AND RESIDENTS FROM LEAD-BASED PAINT ACTIVITIES CONDUCTED IN HOUSEHOLDS	Memo
	Description: Lead-based paint (LBP) debris generated by contractors in households is excluded household hazardous waste. LBP waste from abatement, renovation, and remodeling in homes and other residences eligible for exclusion. LBP waste from households may be subject to state, local and/or tribal government regulation (SEE ALSO: 63 FR 70233; 12/18/1998).
	07/05/2000	STATE AUTHORIZATION FOR RULEMAKING PETITIONS	Memo
	Description: A facility petition to take advantage of trivalent chrome exclusion is referred to authorized state. States authorized by EPA to implement toxicity characteristic (TC) regulations are also authorized to implement exclusions to TC regulations.
	05/25/2000	TOTAL WASTE ANALYSIS ON POTW BIOSOLIDS AND CERCLA LIABILITY	Memo
	Description: Generator must determine if waste exhibits toxicity characteristic (TC) by testing or applying knowledge. Using total constituent concentrations in waste is one type of generator knowledge. EPA does not presume waste is TC hazardous if 1/20th the total constituent concentrations in waste exceed TC regulation levels. RCRA Online letters do not constitute EPA policy. Domestic sewage exclusion would not exonerate sewage generators from potential liability under CERCLA 107(a)(3) if the generators’ discharges include CERCLA hazardous substances. A generator may be shielded from liability due to federally permitted release statutory provisions in CERCLA 107(j). Placement of biosolids on land may constitute normal application of fertilizer in CERCLA 101(22)(D) and exempt the generator from liability;. To evaluate normal application of fertilizer, EPA would consider, among other things, compliance with Clean Water Act 405(d) and application rates.
	12/09/1999	AGENCY ACTIVITIES IN RESPONSE TO THE 1996 HAZARDOUS WASTE CHARACTERISTICS SCOPING STUDY	Memo
	Description: Hazardous Waste Characteristics Scoping Study identified a number of potential gaps in the hazardous characteristics regulatory program. EPA describes potential gaps and efforts to further address them. Discusses the release of final Air Characteristic Study report; review of TCLP test and concerns regarding alkaline waste and oily waste. Work on replacement guidance for withdrawn sulfide and cyanide reactivity test guidance proceeding at low level of activity due to competing priorities. Discusses development of tools for evaluation of ecological risks from waste.
	10/01/1999	LAND DISPOSAL RESTRICTIONS (LDR) TREATMENT STANDARDS AND DISPOSAL OPTIONS FOR CONTAMINATED SOIL	Question & Answer
	Description: Alternative land disposal restrictions (LDR) soil treatment standards require that all constituents subject to treatment be treated to 90 percent reduction capped at 10 times universal treatment standard (UTS) level. Hazardous contaminated soil that exhibits toxicity characteristic when generated may be disposed in Subtitle D landfill or placed back on the land once soil meets LDR treatment requirements and is decharacterized. Hazardous contaminated soil that exhibits toxicity characteristic when generated that meets LDR treatment requirements but is not decharacterized must be disposed in a Subtitle C landfill.
	07/27/1998	REGULATORY ACTION BASED ON AIR CHARACTERISTIC STUDY	Memo
	Description: Study entitled “Potential Inhalation Risks due to Air Emissions from Certain Waste Management Units” (Air Characteristic Study) completed May 1998. EPA has decided not to pursue initiation of proposal for air characteristic under RCRA to address risks from inhalation.
	04/01/1998	Environmental Fact Sheet: Treatment Standards Set for Toxicity Characteristic (TC) Metal Wastes, Mineral Processing Wastes, and Contaminated Soil	Publication
	Description: Announces EPA's promulgation of treatment standards for metal-bearing wastes, including TC waste with high levels of metal constituents, and waste generated in mineral processing operations. Discusses miscellaneous issues related to mineral processing wastes and the amendment of treatment standards for soil contaminated with solid wastes. Reports on exclusion from regulation of certain waste waters from wood preserving operations.
	02/26/1998	RULEMAKING PETITION FOR TRIVALENT CHROMIUM EXCLUSION	Memo
	Description: Discusses the three part criteria for excluding a chromium waste. Rulemaking petition to take advantage of trivalent chromium exclusion must be submitted to implementing agency (EPA or state) for review and approval. Filter cake from treatment of chrome-bearing wastewater is newly generated waste.
	07/25/1997	INCORPORATION OF PRETOX 2000 INTO LEADED PAINT STRIPPER	Memo
	Description: Leaded paint scrapings and blasted paint typically fail the toxicity characteristic for lead. Use of additives in paint strippers or blasting grit to mask the leaching of hazardous constituents is not illegal under current regulations, but any masking may only be temporary. Use of such materials does not relieve the generator of CERCLA liability.
	04/25/1997	Environmental Fact Sheet: Treatment Standards Proposed For Toxicity Characteristic (TC) Metal and Mineral Processing Wastes	Publication
	Description: Discusses EPA's proposal of treatment standards for metal-bearing wastes, including TC waste with high levels of metal constituents, and waste generated in mineral processing operations.
	04/11/1997	PAINT RECYCLING	Memo
	Description: Paint or coating remixed and used for its intended purpose is not a solid waste. If paint is discarded, the generator must make a hazardous waste determination. Discarded paints generally are not listed wastes, but they may exhibit characteristics such as ignitability or toxicity. Paint generated by a CESQG is not subject to federal regulation provided the waste is discarded at a facility meeting Section 261.5(f) or (g). Paint collected from households is exempt from regulation, even if the paint is subsequently discarded. Household hazardous waste (HHW) mixed with regulated hazardous waste in a collection program is regulated. Paint cans emptied under the empty container provisions are not subject to regulation because they do not hold regulated residues.
	03/12/1997	RCRA APPLICABILITY TO PAINT REMOVAL WASTES	Memo
	Description: The paint removal process is not subject to regulation in some circumstances. Waste determination under Section 262.11 is made once the combination of paint and surface preparation product is removed from the surface of the structure. Each product user is responsible for waste determination. Nonhazardous waste which subsequently becomes hazardous is subject to regulation. Generators are potentially liable under CERCLA for damage caused by a release. A lead-based paint abatement contractor and building owner are both generators (cogenerators).
	02/07/1997	MANAGEMENT OF SPENT FLUORESCENT LAMPS	Memo
	Description: EPA is currently completing an analysis of estimated mercury emissions associated with managing spent fluorescent lamps. EPA will use the analysis in conjunction with comments on the proposed lamp rule (59 FR 38288; July 24, 1994) to determine how to proceed with a final regulatory decision on lamps (SEE ALSO: 64 FR 36466; 7/6/99).
	11/07/1996	REGULATORY STATUS OF CHOPLINE RESIDUE	Memo
	Description: Chopline residues are spent materials and therefore solid wastes when reclaimed or recycled. It is considered spent because it can no longer be used for the original purpose without reprocessing or reclamation. Hazardous waste management requirements apply up to the point of resale as product. Residue generated from the recycling process may be hazardous if characteristic.
	07/12/1996	MANAGEMENT AND DISPOSAL OF WASTE VINYL MINI BLINDS	Memo
	Description: Toxicity characteristic (D008) lead-containing mini blinds are not solid waste if they are returned to the manufacturer for resale in a reverse distribution system. Blinds from homes, apartments, and hotels are exempt household hazardous waste (HHW). Waste from hospitals, offices, day care centers, and non-residential buildings at military bases are not HHW. HHW and non-HHW must be segregated. A generator can test waste or apply knowledge. The most conservative approach assumes that the blinds are hazardous waste (HW). The generator is vulnerable for enforcement for an incorrect determination if subsequent EPA testing reveals that the waste is HW.
	03/25/1996	EPA'S ASSESSMENT OF WHETHER AN UNUSED CHEMICAL AND THE RESULTING SPENT MATERIAL ARE HAZARDOUS WASTE AND/OR MIXED WASTE	Memo
	Description: Potassium hexacyanocobalt (II) - ferrate (II) that is used as an ion exchange medium to remove cesium from a wastestream is not a listed hazardous waste before or after use. Media are unlikely to exhibit a characteristic before use. If media exhibit a characteristic after use, they would be radioactive mixed wastes.
	03/07/1996	INDUSTRIAL WIPERS AND THE HAZARDOUS WASTE IDENTIFICATION RULE	Memo
	Description: Discusses possible factors to consider in a future rulemaking on disposable and reusable rags and wipers contaminated with solvents (SEE ALSO: RPC# 10/27/94-01 and RPC# 2/14/94-01).
	02/15/1996	EPA'S NON-OBJECTION TO IMPORTS OF COBALT OXIDE-MOLYBDIC OXIDE SPENT CATALYSTS INTO THE U.S. FOR RECOVERY	Memo
	Description: Cobalt oxide-molybdic oxide spent catalysts are usually nonhazardous, but can exhibit the toxicity characteristic for benzene and arsenic. EPA does not have the authority to object to imports of nonhazardous waste. In order for Basel parties to export covered waste to non-Basel parties, the two parties must have a bilateral agreement in place. Presents a list of countries that are parties to Basel as of January 10, 1996.
	01/30/1996	BARIUM IN HAZARDOUS WASTE	Memo
	Description: Reexamination of the regulatory levels for barium in hazardous waste and other media is not currently an Agency priority. EPA also has regulatory levels for barium in drinking water and would have to coordinate any scientific review of established levels with the EPA office responsible for these standards.
	01/26/1996	LAND DISPOSAL RESTRICTIONS; PHASE IV SUPPLEMENTAL PROPOSAL ON MINERAL PROCESSING WASTES	Memo
	Description: The Phase IV Bevill proposal (61 FR 2338; 1/25/96) would clarify the distinction between in-process materials and wastes in the Bevill exemption for mining and mineral processing wastes. The notice proposes retaining the TCLP and the classification of several wastes, including five smelting wastes that were previously lifted, iron chloride waste acid, and wastes from lightweight aggregate production. The notice proposes to exclude processed scrap metal and shredded circuit boards that are destined for metal recovery and managed in containers. The notice proposes to significantly reduce the land disposal restrictions (LDR) paperwork requirements that apply to hazardous waste generally (SEE ALSO: Phase IV Final Rule, 63 FR 28556; 5/26/98).
	08/10/1995	GENERATOR STATUS OF CONTRACTORS WHO REMOVE LEAD-BASED PAINT	Memo
	Description: During typical lead-based paint abatement, both the property owner and contractor may qualify as generators responsible for compliance. The cogenerator policy applies to cases other than those specified in the 10/30/80 Federal Register (45 FR 72024), where waste is generated by more than one party.
	07/13/1995	REGULATORY STATUS OF SPENT ANTIFREEZE	Memo
	Description: Spent antifreeze from radiator flushes may be characteristic. Studies indicate spent antifreeze may be hazardous, primarily due to lead. EPA has not determined the point of generation for like wastes of similar composition when commingled after being produced. Discusses the status of commingling hazardous and nonhazardous antifreeze. If the commingled mixture is no longer hazardous and meets treatment standards, the generator must comply with the Section 268.9 notification requirement. Residues and still bottoms from antifreeze recycling are a newly generated waste. Metal-bearing, high-BTU still bottoms could be burned in a BIF under the dilution prohibition.
	07/01/1995	Guidance for the Sampling and Analysis of Municipal Waste Combustion Ash for the Toxicity Characteristic	Publication
	Description: This document contains guidance to assist generators of ash from municipal waste combustion facilities in determining whether the ash is hazardous because it exhibits the toxicity characteristic. It also discusses typical concerns during ash sampling, analysis using the TCLP, the importance of quality assurance and quality control, and criteria for evaluating data. There is also a listing of resources for designing a sampling and analysis plan and an appendix of definitions used in the guidance.
	06/22/1995	DETERMINATION ON WHETHER A GENERATOR'S FLUORESCENT TUBES ARE NONHAZARDOUS	Memo
	Description: A generator is responsible for determining if a waste exhibits a characteristic. Testing one spent fluorescent mercury lamp tube to determine if all waste lamps exhibit the characteristic is not representative sampling. Selection of randomly chosen bulbs is more appropriate (see Chapter 9, SW-846). States authorized for the universal waste (UW) rule may add lamps to the state UW list and set management standards (SEE ALSO: 64 FR 36466; 7/6/99). The UW rule streamlines regulations for hazardous waste batteries (battery), pesticides, and mercury thermostats (SEE ALSO: 70 FR 45508; 8/5/05).
	06/05/1995	GUIDANCE FROM THE U.S. EPA ON THE CRUSHING OF MERCURY-CONTAINING LAMPS	Memo
	Description: Crushing mercury lamps can be part of an exempt legitimate recycling process. The recycling exemption can apply even if portions of recycling are performed at different sites. A crusher carries the burden to ensure bulbs are actually recycled (SUPERSEDED: lamp crushing by universal waste handlers prohibited; see 64 FR 36466, 36477-36478; 7/6/99). EPA is still weighing options proposed in the 7/27/94 Federal Register (59 FR 38288) for streamlining fluorescent lamp regulation. The universal waste rule streamlines the regulations for hazardous waste batteries (battery), pesticides, and mercury thermostats (SEE ALSO: 70 FR 45508; 8/5/05). States may add additional wastes (e.g., fluorescent lamps) to the state universal waste list and establish management standards.
	01/26/1995	CHARACTERIZATION OF WASTE STREAMS FROM POLYMERIC COATING OPERATIONS	Memo
	Description: Manufacturing process units may include distillation columns, flotation units, or discharge trays or screens. Rags and wipers can only be defined as listed if they contain a hazardous waste. If a rag or wiper contains a listed waste, it is a hazardous waste via the contained-in policy or it is considered mixed with a listed hazardous waste (SEE ALSO: 2/14/94-01). The final regulatory determination for wipers should be made by the State or Regional office. No test method has been promulgated for spontaneous combustion. A generator is responsible for comparing properties of his/her waste with the narrative definition. The Paint Filter Liquids test is the current test to determine whether a material contains a liquid for the characteristic of ignitability (D001).
	11/01/1994	Environmental Fact Sheet: EPA Releases RCRA Hazardous Waste Minimization National Plan	Publication
	Description: This fact sheet announces the release of EPA's final Hazardous Waste Minimization National Plan. The Plan sets national goals for reducing constituents in hazardous waste that are persistent, bioaccumulative, and toxic. The Plan consists of five national objectives: (1) development of a framework for setting national priorities; (2) promotion of multimedia environmental benefits and prevention of cross media transfers; (3) demonstration of a strong preference for source reduction; (4) clear definition and tracking of progress, promoting accountability for EPA, states, and industry; and (5) involvement of citizens in waste minimization implementation decisions.
	10/07/1994	PROCESSING LEAD ABATEMENT DEBRIS TO MEET HAZARDOUS WASTE RECYCLER'S SPECIFICATIONS IS NOT ""TREATMENT"" AS DEFINED IN 40 CFR 260.10	Memo
	Description: Processing (cutting, chopping, shredding, or grinding) of lead-based paint (LBP) waste is treatment, but it is not subject to regulation if it is part of legitimate recycling. The storage of hazardous waste lead-based paint before or after exempt processing is regulated. Recycling is an exempt form of hazardous waste treatment.
	07/14/1994	MANAGEMENT OPTIONS FOR MERCURY-CONTAINING LAMPS	Memo
	Description: Fluorescent and high-intensity discharge lamps generally exhibit the toxicity characteristic for mercury. A summary of two regulatory options for spent mercury-containing lamps as proposed in the 7/24/94 Federal Register (59 FR 38288) is provided (SEE ALSO: 64 FR 36466; 7/6/99).
	07/14/1994	TREATMENT STANDARD FOR K106 (LOW MERCURY SUBCATEGORY) NON-WASTEWATER RESIDUES FROM RETORTING/ROASTING (RMERC) UNITS	Memo
	Description: K106 low mercury subcategory residues from retorting/roasting units will need further treatment if the residues exceed the mercury TCLP level.
	06/03/1994	DEFINITION OF RCRA WASTE K050	Memo
	Description: A sludge from a double-pipe heat exchange unit is not K050. Inside the tube of a double-pipe unit is not a bundle. A sludge may exhibit the toxicity characteristic for benzene and other heavy organics.
	05/24/1994	STATUS OF WASTES GENERATED FROM ABATEMENT OF LEAD-BASED PAINT	Memo
	Description: Lead-based paint (LBP) abatement wastes are not household hazardous waste (HHW) if generated in construction, demolition, or renovation, but are exempt HHW if generated in routine residential maintenance (SUPERSEDED: See 63 FR 70233, 70241; 12/18/98). EPA does not distinguish between wastes generated by homeowners and contractors (SEE ALSO: RPC# 3/7/95-01). Unless it is HHW, LBP abatement waste exhibiting the toxicity characteristic for lead (D008) is currently regulated under Subtitle C. EPA may amend RCRA Subtitle C rules to remove the disincentives to abate LBP.
	05/01/1994	Draft RCRA Hazardous Waste Minimization National Plan	Publication
	Description: Outlines EPA's plan for reducing the amount and toxicity of hazardous waste generated nationally, placing an initial focus on metal-bearing and halogenated combustible wastes. Sets forth the Agency's goals regarding waste minimization. Discusses specific mechanisms under consideration for achieving the goal of pollution prevention.
	03/10/1994	ISSUES CONCERNING THE COMPARISON OF SFE EXTRACTION RESULTS TO THOSE OBTAINED USING SONICATION(3550) RATHER THAN SOXHLET(3540,3541)	Memo
	Description: Target analyte recoveries using Method 3550 are lower than those obtained using Soxhlet extraction, Methods 3540 or 3541. Validation OF NEW EXTRACTION PROCEDURES should be done with the comparison of results to the Soxhlet extraction.
	03/01/1994	CLARIFICATION OF LAND DISPOSAL RESTRICTIONS (LDR) REQUIREMENTS	Memo
	Description: If a waste is ignitable (D001, high total organic carbon (TOC)) and exhibits the toxicity characteristic for lead (D008), then blending and combustion as a hazardous waste fuel is not impermissible dilution, since the treatment standard for high TOC D001 requires burning. Fuel substitution alone is not sufficient. Ash from burning such metal-bearing wastes must meet the treatment standards for metals. A waste must meet treatment standards for all applicable waste codes before land disposal (SEE ALSO: 268.9(b)). The F001-F005 treatment standards apply only to the constituents used for solvent properties and which triggered the listing. Solvent constituents picked up through use are not subject to the F001-F005 treatment standards. The F005 treatment standard addresses the characteristic of ignitability and so operates in lieu of D001 treatment standard (USE WITH CAUTION: see RPC# 9/28/94 -04). The alternative debris treatment standards may be used even if the debris is contaminated with a waste code whose treatment standard is a specified technology.
	01/21/1994	REGULATORY STATUS OF SPENT ANTIFREEZE	Memo
	Description: Spent antifreeze is a hazardous waste only if it exhibits a characteristic.
	01/03/1994	REGULATORY STATUS OF METAL CASINGS CONTAINING SPENT POWDERED METALLIC OXIDE CATALYST	Memo
	Description: Metal casting containing spent powdered metallic oxide catalyst (i.e., manganese dioxide and copper oxide) is not a listed waste, but could exhibit a characteristic, most likely ignitability (D001) or reactivity (D003). Manganese dioxide is a strong oxidizer and poses a human health hazard through inhalation.
	01/01/1994	USE OF TOTAL WASTE ANALYSIS IN TOXICITY CHARACTERISTIC DETERMINATIONS	Question & Answer
	Description: The maximum theoretical leachate concentration limits for the TCLP can be calculated from the results of a total waste analysis using a specific formula. Discusses the use of a total waste analysis for liquid wastes, solid wastes, and dual-phase wastes. Discusses maximum theoretical extract concentration (MTEC).
	12/22/1993	REGULATORY STATUS OF BATTERIES	Memo
	Description: Lithium-sulfur dioxide batteries (battery) that have been fully discharged to zero volts do not exhibit the characteristic of reactivity (D003). Other lithium batteries may exhibit the toxicity characteristic for constituents such as lead (lead-acid batteries), cadmium (nickel-cadmium rechargeable batteries), and mercury (mercuric oxide, and some alkaline batteries), or they may be hazardous due to other characteristic properties.
	12/07/1993	INAPPROPRIATE USE OF METHOD 1311 (TCLP) AS AN ALTERNATIVE EXTRACTION PROCEDURE	Memo
	Description: Method 1311 (TCLP) is the leaching procedure, not extraction procedure (EP). The TCLP is not an appropriate sample preparation procedure for extractable total petroleum hydrocarbons (TPH) or for volatile TPH fractions (e.g., gasoline). Discusses suggested methods for preparation of extractable TPH in soil.
	11/22/1993	RCRA HAZARDOUS WASTE DETERMINATION OF SPENT NUCLEAR REACTOR FUELS	Memo
	Description: The Naval Nuclear Propulsion Program’s (NNPP) spent reactor fuel does not exhibit any characteristics of hazardous waste. Discusses the application of the TCLP to radioactive mixed waste.
	10/20/1993	RESPONSE TO SPECIFIC QUESTIONS REGARDING HAZARDOUS WASTE IDENTIFICATION AND GENERATOR REGULATIONS	Memo
	Description: The absence of free liquids precludes applicability of the ignitability characteristic (D001) as defined in 261.21(a)(1). The proposed rule change (58 FR 46052; 8/31/93) suggests using the pressure filtration step from TCLP (Method 1311) as a definitive demonstration for the absence of free liquids for D001 and D002.
	09/23/1993	LEAD CONTAMINATION RESULTING FROM SKEET SHOOTING	Memo
	Description: EPA encourages the use of substitute materials for lead in ammunition on firing ranges. The U.S. Court of Appeals for the Second District affirmed that lead ammunition deposited in Long Island Sound is “hazardous solid waste,” and a citizen may bring a RCRA 7002 lawsuit for imminent and substantial endangerment (SEE ALSO: 62 FR 6622; February 12, 1997).
	09/14/1993	REGULATORY STATUS OF BRASS PARTICLES GENERATED IN THE BELTING AND BUFFING OF BRASS CASTINGS	Memo
	Description: Scrap metal that fails the toxicity characteristic for lead is excluded from RCRA Subtitle C regulation when it is recycled. The determination whether brass particles from the belting/buffing of brass castings are scrap metal is made by the state or Regional office (SEE ALSO: 261.4(a)(13) exclusion for processed scrap metal).
	07/14/1993	RESPONSE TO REQUEST FOR OPINION ON SECTION 21 PETITION ON BATTERY DEPOSITS	Memo
	Description: The toxicity characteristic (TC) is designed to identify wastes that may pose a risk to human health and the environment under a reasonable worst-case mismanagement scenario. Some spent batteries (battery) would fail the toxicity characteristic for lead (D008), cadmium (D006), and mercury (D009). Batteries may be eligible for the universal waste regulations. Batteries generated by households and conditionally exempt small quantity generators (CESQGs) are generally exempt from Subtitle C regulation.
	06/01/1993	SAMPLE HOLDING TIMES AND VALIDITY OF ANALYTICAL RESULTS	Question & Answer
	Description: Discusses the use of the TCLP analytical results when sample holding times are exceeded.
	05/06/1993	WASTE MANAGEMENT OPTIONS FOR ZINC-CARBON BATTERIES	Memo
	Description: Zinc-carbon batteries that contain cadmium are subject to land disposal restrictions (LDR) only if they fail the TCLP and extraction procedure (EP) (SUPERSEDED: see 63 FR 28556; May 26, 1998). Zinc-carbon batteries are not subject to the cadmium battery recycling standard. The applicable D006 treatment standard is based on stabilization (SEE ALSO: Part 273).
	04/02/1993	REVISIONS TO THE TCLP	Memo
	Description: Discusses the use of the method of standard additions (MSA) in metallic contaminants in TCLP wastes.
	03/11/1993	CLARIFICATION OF METHOD 8260 CALIBRATION STANDARDS AND ""WASTE TYPE""	Memo
	Description: The calibration criteria for method 8260 were established for 5 ml samples. Contains guidance on running 25 ml samples. The “waste type” in the QA/QC step of the TCLP refers to materials which have significant differences in chemical constituents or physical properties. Discusses frequency of matrix spiking.
	03/05/1993	U.S. WASTE MANAGEMENT PRACTICES FOR AUTOMOBILES AND AUTO SHREDDER RESIDUE	Memo
	Description: Automobile shredder residue (ASR or fluff) and shredded appliances have the potential to exhibit characteristics, and may also contain PCBs above levels of regulatory concern. It is the generator's responsibility to determine whether ASR is hazardous waste before disposal. Provides the estimated ASR yearly generation. Most shredder residue is managed in solid waste (SW) landfills. Some states ban disposal of white goods (appliances) and autos from landfills or impose a consumer surcharge.
	01/18/1993	HAZARDOUS WASTE TESTING ISSUES	Memo
	Description: EPA has no data that trivalent chromium oxidizes to hexavalent chromium in a landfill. The TCLP is based on co-disposal scenario. Methods 9010 and 9012 are suggested for a concentration of total cyanide and cyanide amenable to chlorination.
	01/12/1993	NOTES ON RCRA METHODS AND QA ACTIVITIES	Memo
	Description: Discusses the method and formula for using totals analysis to determine the theoretical maximum concentration of contaminants that could leach from a waste when using the TCLP, and the maximum theoretical extract concentration (MTEC) (SEE ALSO: RPC# 1/1/94-01). EPA’s current regulations for characterizing waste include determining the average property of the universe or whole, even when the waste is heterogeneous (i.e., contains hot spots).
	12/24/1992	CLARIFICATION ON WHAT CONSTITUTES DIOXIN RELATED MATERIALS	Memo
	Description: Contains a list of waste codes that contain dioxin (F020, F022, F023, F026, F027, F028, F032, D017, D041, D042). The F-listed dioxin waste codes do not apply if waste contains dioxin but does not meet the listing description. Waste exhibits the toxicity characteristic only if the level of constituent exceeds the regulatory level. F039, K043, and K099 have land disposal restrictions (LDR) for certain dioxins and furans. If waste meets the listing description, the waste code applies even if no Appendix VIII constituents are present. For purposes of F021, a pentachlorophenol derivative includes any substance which is related structurally and can be made from pentachlorophenol (PCP), including sodium pentachlorophenate, octachlorodibenzodioxin, octachlorodiphenyl ether, and potassium pentachlorophenate. Derivatives from tri- and tetrachlorophenol include tri- and tetra-chlorophenoxy derivatives of carboxylic acids. F020 -F023, F026-F028 hazardous waste must be incinerated in an unit meeting 99.9999 DRE or burned in thermal treatment unit meeting same DRE. Waste that contains Appendix VII constituents but cannot be traced to the original process that would generate the waste meeting listing description is exempt from regulation unless characteristic.
	12/07/1992	MANAGEMENT OF USED FLUORESCENT LAMPS	Memo
	Description: EPA test results indicate that fluorescent lamps often exhibit the toxicity characteristic for mercury (D009) as determined using the TCLP.
	11/25/1992	QUESTIONS ON FINAL USED OIL RULE	Memo
	Description: The toxicity characteristic rule is federally enforceable in every state until it is adopted by the state and EPA approves its authorization. The used oil filter exclusion applies in Arizona on 6/19/92. Discusses the applicability of the used oil regulations in authorized states.
	11/05/1992	CLARIFICATION OF NEWLY LISTED WASTES AND HAZARDOUS DEBRIS	Memo
	Description: Characteristic debris treated to meet the land disposal restrictions (LDR) performance standards and contaminant restrictions that no longer exhibits a characteristic, is not hazardous waste. If a mixture of a material is comprised primarily of debris, by volume, based on visual inspection, the entire mixture is debris. Non-debris mixtures may be treated via equivalent method variance or variance from treatment standard. Analysis of leachability reduction of microencapsulated waste may be achieved by determining the constituent leachability before and after treatment using TCLP.
	10/15/1992	Environmental Fact Sheet: EPA Revises Quality Assurance Measures for the Toxicity Characteristic Leaching Procedure	Publication
	Description: Announces the removal of spike recovery correction requirements for TCLP testing. The removal makes testing requirements consistent with those outlined in EPA's manual on RCRA testing methodology. Waste previously found to be TC-hazardous using spike recovery correction must still be managed as hazardous until reevaluated according to revised TCLP testing procedure.
	09/21/1992	CALCULATION OF TCLP CONCENTRATIONS FROM TOTAL CONCENTRATIONS	Memo
	Description: A generator may use total analysis in lieu of the TCLP analysis to determine if analyte could possibly be above regulatory level by dividing total concentration by 20 and comparing result with the regulatory limit. Discusses the maximum theoretical extract concentration (MTEC) (SEE ALSO: RPC# 1/1/94-01 “Use of Total Waste Analysis in Toxicity Characteristic Determinations”).
	09/16/1992	RCRA STATUS OF LEAD-BASED PAINT ABATEMENT DEBRIS AND LEAD PAINT CONTAINING DEMOLITION DEBRIS	Memo
	Description: Revising the toxicity characteristic levels for lead based on groundwater modeling, rather than extraction procedure levels, would result in most lead-based paint abatement wastes no longer testing hazardous. The revision of the toxicity characteristic level for lead may occur as part of Hazardous Waste Identification Rule. EPA considered extending the household hazardous waste exclusion to lead-based paint (LBP) abatement wastes from renovation (SEE ALSO: 63 FR 70233, 70241; 12/18/98).
	09/04/1992	STATUS OF FLUORESCENT LAMPS UNDER RCRA	Memo
	Description: CESQG or household hazardous waste (HHW) fluorescent light bulbs may be land disposed in Subtitle D landfill regardless of characteristic properties. Land disposal restrictions (LDR) do not apply to D009 mercury-containing fluorescent light bulbs that pass the extraction procedure (EP) test (SUPERSEDED: see 63 FR 28556; 5/26/98). The bulbs are subject to LDR because they exhibit the EP toxicity characteristic and toxicity characteristic (TC), and could be considered debris per 268.45.
	07/21/1992	REGULATIONS FOR DISPOSAL OF CERAMIC MATERIALS	Memo
	Description: The disposal of ceramic tiles is regulated only if they meet the definition of hazardous waste. If the tiles are hazardous, they may be subject to the land disposal restrictions (LDR). Appropriate treatment could consist of chemical stabilization or vitrification, depending on the metals in the waste.
	06/16/1992	DESIGNATION OF AMERICIUM BERYLLIUM SOURCES UNDER RCRA	Memo
	Description: Discusses the tentative determination that americium beryllium (AmBe) sealed source wastes are not RCRA hazardous wastes. AmBe sealed sources are not P015, and are not ignitable (D001), corrosive (D002), or reactive (D003). EPA does not expect stainless steel casings to fail the toxicity characteristic. Beryllium residues discarded during sealed source manufacturing process may be P015. Solder from sealed sources may be evaluated using a combination of testing and mass balance approaches. The theoretical TCLP concentration can be based on solder composition or by testing.
	05/15/1992	Environmental Fact Sheet: EPA Proposes Revised Hazardous Waste Identification Rule	Publication
	Description: Proposes an amendment to define hazardous waste by either establishing concentration-based exemption levels for some hazardous constituents found in certain wastes, or by expanding the number of hazardous constituents in the Toxicity Characteristic rule. This proposal was withdrawn in the October 30, 1992, Federal Register.
	02/04/1992	CLASSIFICATION OF INFILTRATION GALLERIES UNDER THE UIC AND RCRA PROGRAMS	Memo
	Description: Discusses the distinction between, and definition of, infiltration galleries (IGs) and SDWA underground injection control (UIC) wells for purposes of the April 2, 1991, rule extending the toxicity characteristic (TC) effective date for reinjection of groundwater pursuant to hydrocarbon recovery operations at petroleum refineries and transportation facilities (56 FR 13406). IGs can be UIC wells. IGs are often trenches. Remediation activities using reinjection may be subject to state groundwater protection statutes, SDWA, RCRA, and/or CERCLA authorities.
	12/19/1991	USED AUTOMOBILE ANTIFREEZE DISPOSAL	Memo
	Description: Used antifreeze from households is exempt from regulation. Used antifreeze from business is hazardous waste only if characteristic. Small business may be able to enjoy the reduced CESQG regulation. Industry data indicates used antifreeze may fail TCLP.
	12/01/1991	SW-846 TEST METHODS	Question & Answer
	Description: The test methods found in SW-846 are generally not required, but are intended as guidance for both hazardous waste identification and compliance with the land disposal restrictions (LDR) treatment standards. In certain instances, such as delisting and characteristic testing, EPA requires the use of the SW-846 methods.
	11/12/1991	APPLICABILITY OF SPECIAL COLLECTION SYSTEM PROPOSAL TO BATTERIES	Memo
	Description: Hazardous waste batteries (battery) generated by households are not subject to regulations. Batteries generated by a CESQG are subject to limited controls. Until EPA develops special management standards for recycling hazardous waste batteries, generators must still determine whether used nickel-cadmium batteries exhibit the toxicity characteristic (SEE ALSO: Part 273).
	11/01/1991	REMOVAL OF TOXICITY CHARACTERISTIC WASTES FROM A SURFACE IMPOUNDMENT	Question & Answer
	Description: The one-time removal of toxicity characteristic (TC) waste from a surface impoundment on or after the TC rule’s effective date does not subject the unit to regulation (55 FR 11798; March 29, 1990). The unit can then be used to manage nonhazardous waste. The surface impoundment holding TC waste that is left in place and that is not actively managed after the TC effective date is not subject to regulation.
	10/29/1991	TCLP EXTRACTIONS APPLIED TO LIQUID WASTES, OILS AND SOLVENT-BASED PRODUCTS	Memo
	Description: Provides suggested analytical steps when inconclusive results are obtained from application of the TCLP to solvent and oily wastes. Generators may always apply their knowledge in lieu of testing. TCLP analysis is unnecessary for used oil destined for recycling.
	10/09/1991	EXEMPTION FROM PARTICLE SIZE REDUCTION STEP IN TCLP	Memo
	Description: Generator knowledge may include previous testing data on similar waste. The generator must test or apply knowledge to make a determination of hazardous waste characteristics. The TCLP particle size reduction method is up to the lab’s best professional judgment.
	10/01/1991	ANALYTICAL METHODS FOR CONDUCTING TESTING UNDER THE TC RULE	Memo
	Description: Up until June 21, 1990 the analytical methods for the toxicity characteristic of arsenic, selenium, and mercury were 7060, 7061,7740, 7470, and 7471. On June 21, 1990, the Agency promulgated method 6010.
	09/26/1991	APPLICABILITY OF THE TOXICITY CHARACTERISTIC TO USED OIL FILTERS	Memo
	Description: No hazardous waste determination is necessary for oil filters destined for scrap metal recycling (SEE ALSO: 261.4(b)(13)). Crushed and hot drained oil filters are unlikely to exhibit the toxicity characteristic.
	09/25/1991	TC RULE DELAY OF IMPOSITION ON OIL FILTERS	Memo
	Description: Data suggests that crushed oil filters may not exhibit the toxicity characteristic. No toxicity characteristic determination is necessary for oil filters destined for recycling (SEE ALSO: Section 261.4(b)(13)).
	08/30/1991	LEAD PAINT REMOVAL DEBRIS AND THE TCLP PROCEDURE	Memo
	Description: Adding iron or other material to lead-based paint (LBP) removal waste (or to removal abrasive) to mask the lead (D008) characteristic is not legitimate and may subject the generator to additional liability. Whether the masking agent is added to the paint removal abrasive prior to the abatement process or added to the waste following generation is immaterial (SEE ALSO: RPC# 7/3/91-02).
	08/30/1991	UNDERGROUND INJECTION WELLS USED IN HYDROCARBON RECOVERY	Memo
	Description: Groundwater reinjected through injection wells following hydrocarbon recovery at certain types of facilities is not subject to the toxicity characteristic rule until January 25, 1993. Disccusion of the rationale for extending the compliance date. OSW and the Office of Water should agree on terms of implementation.
	08/05/1991	APPLICABILITY OF THE TOXICITY CHARACTERISTIC RULE TO UNREGULATED HEAVY METALS	Memo
	Description: Certain heavy metals (e.g., vanadium, copper, zinc, nickel, tin, antimony) are not regulated constituents under the toxicity characteristic because they have not yet been assigned MCLs and EPA's fate and transport model does not fully account for the behavior of metals.
	07/31/1991	TC RULE HAZARDOUS WASTE DETERMINATION	Memo
	Description: Pulp and paper mill wastes should be sampled at an outlet from the bleach plant (point of generation), prior to commingling (mixing) with other wastestreams, to determine whether they exhibit the toxicity characteristic for chloroform (D022). The dilution of characteristic hazardous waste at a pulp and paper mill is acceptable for CWA compliance provided there is no specified method of treatment (58 FR 29860; 5/24/93). The definition of aggressive biological treatment (ABT) units for the purposes of the F037 and F038 listings does not apply to the exemption for biological treatment units from the surface impoundment minimum technical requirements.
	07/09/1991	METHODOLOGIES EMPLOYED IN USED OIL SAMPLING	Memo
	Description: Discusses the 1989-1990 used oil sampling data that was gathered to support the used oil characterization effort. Used oil was analyzed for compositional characteristics and analyzed via TCLP. 7 types of used oils were analyzed. The results do not reflect regional variations as all samples, where possible, were taken from the Washington, D.C. area. Addresses the role of TCLP and other methods used in the determination (SEE ALSO: 57 FR 41566; 9/10/92).
	07/03/1991	DRAFT REGION VIII POLICY ON “AGGRESSIVE BIOLOGICAL TREATMENT”	Memo
	Description: Sludges formed in aggressive biological treatment (ABT) units are not F037 or F038. Only secondary or tertiary treatment units qualify as ABT units. ABT units receiving or generating toxicity characteristic hazardous waste are subject to all applicable rules. F037/F038 sludges can be formed in ABT units that are not operating properly.
	07/03/1991	TCLP AND LEAD PAINT REMOVAL DEBRIS	Memo
	Description: Provides general guidance for the representative sampling of lead-based paint abatement wastes (debris and abrasives) from drums, roll off boxes, and other containers. Shipments of LBP abatement wastes from a field site (bridge repair) to a central accumulation point must generally be accompanied by a manifest. The central accumulation point must be a transfer facility or a TSDF to accept manifested hazardous waste. Generators conducting lead-based paint (LBP) abatement must test the wastes using TCLP unless they can apply knowledge to determine characteristics (SEE ALSO: 63 FR 70233, 70241; 12/18/98). If an LBP waste first tests nonhazardous in TCLP due to the masking effect of an iron abrasive but exhibits the characteristic prior to disposal, all hazardous waste regulations apply. LBP abatement wastes that are characteristic for lead may be stabilized on site during accumulation in tanks or containers without a permit.
	06/28/1991	CCA TREATED WOOD WHEN DISPOSED	Memo
	Description: The treated wood exemption applies to wood failing the toxicity characteristic for D004-D017, not just arsenic (SEE ALSO: 57 FR 30657; 7/10/92).
	06/21/1991	SPENT ANTIFREEZE AND THE TOXICITY CHARACTERISTIC	Memo
	Description: Discusses the use of TCLP to determine if spent antifreeze exhibits the characteristic for lead. The extraction procedure (EP) and TCLP are functionally equivalent for liquid wastes, since both lead to a direct analysis of the liquid. Extraction procedure toxic wastes are a subset of all hazardous waste. Generators may apply their knowledge instead of testing.
	06/13/1991	TCLP EXTRACTIONS AS THEY APPLY TO OILY WASTE	Memo
	Description: The Agency does not recommend applying the TCLP test to oily waste. If oily waste is used oil, characterization is unnecessary if going for recycling (SEE ALSO: Part 279). If the TCLP is inconclusive on oily wastes, the generators may use knowledge.
	05/29/1991	PARTICLE SIZE REDUCTION PROCEDURE FOR TCLP SAMPLES OF DRY CELL BATTERIES	Memo
	Description: The Agency is unable to determine if sample freezing with liquid nitrogen to facilitate grinding and crushing would alter accuracy of TCLP.
	05/21/1991	APPLICABILITY OF THE TCLP TO WASTE MUNITIONS	Memo
	Description: The mandatory hazardous waste determination should be based on knowledge when the application of TCLP to discarded munitions would result in an inherently unsafe situation due to the particle reduction step. The exemption from TCLP is unwarranted because generators can apply their knowledge.
	05/09/1991	SHELL OIL FACILITY - TC COMPLIANCE	Memo
	Description: Infiltration galleries are not exempted by the 261.4(b)(11) groundwater injection exclusion. Treatment wastewaters from extracted petroleum-bearing groundwater are considered sludges and are not eligible for the extended toxicity characteristic compliance date (exclusion expired 1/25/93).
	05/01/1991	TCLP PARTICLE SIZE REDUCTION EXEMPTION FOR MUNITIONS	Memo
	Description: Particle reduction in TCLP is unsafe for military munitions. Facilities may apply knowledge to determine characteristic.
	04/16/1991	TC RULE RELATIONSHIP TO USED OIL FILTER DISPOSAL	Memo
	Description: In spite of the toxicity characteristic rule, generators may still apply their knowledge to make a hazardous waste determination. They must, however, be correct in their determination. Used oil filters are subject to hazardous waste determination (SEE ALSO: 261.4(b)(13)).
	03/26/1991	SUBSURFACE FATE AND TRANSPORT MODEL	Memo
	Description: EPA‘s Composite Model for Landfills (EPACML) is a subsurface fate and transport model developed for national regulatory purposes, not site-specific use. EPA is proposing to use EPACML in delisting petitions. EPA discourages application of the model to site-specific corrective actions.
	03/25/1991	DILUTION OF TEST SAMPLING	Memo
	Description: TCLP is difficult to use on wastes such as oils and neat solvents because dilution step shifts detection limits are above the toxicity characteristic levels. A generator should apply knowledge in such cases. If no information is available, it would be prudent to handle it as hazardous waste (SEE ALSO: RPC# 8/14/90-01). There is no need to run TCLP on used oil that will be recycled.
	03/19/1991	MATRIX SPIKE IN TCLP PROCEDURE	Memo
	Description: A matrix spike may be used in the TCLP when the contaminant concentration is completely unknown to monitor method performance and to estimate the extent of bias or interference (SEE ALSO: 57 FR 26986; November 24, 1992). A matrix spike is a predetermined quantity of certain analytes added to a sample matrix before sample extraction/preparation.
	03/08/1991	SLUDGES WITHIN SURFACE IMPOUNDMENTS, NEWLY REGULATED DUE TO TC RULE	Memo
	Description: Toxicity characteristic sludges that are generated in surface impoundments are solid waste (discarded by being abandoned). The sludges are solid waste subject to regulation not only when the surface impoundment is cleaned or closed but when sludge is generated (sludges are generated at the moment of deposition at the bottom of a unit).
	02/27/1991	MOBILE TREATMENT UNITS QUALIFIED FOR INTERIM STATUS	Memo
	Description: Discusses the explanation of three criteria necessary for a facility to qualify for interim status under the toxicity characteristic (TC) rule. A mobile treatment unit may qualify for interim status at more than one location. Routine movement of a mobile treatment unit from site-to-site does not require a change in interim status. The addition of waste codes to a Part A at a interim status facility is regulated by EPA due to the TC rule in an authorized state that has not adopted the TC rule.
	02/22/1991	ANALYSIS OF FLUFF MATERIALS	Memo
	Description: Discusses tha analysis of fluff using TCLP v. extraction procedure (EP) and the use of different extraction fluids for TCLP.
	02/15/1991	Environmental Fact Sheet: Interim Final Rule Suspending Application of the Toxicity Characteristic for Used Chlorofluorocarbon Refrigerants Being Reclaimed	Publication
	Description: This fact sheet discusses the interim final rule suspending the application of toxicity characteristics for reclaiming used chlorofluorocarbon refrigerants, how the recycling used refrigerants is gaining acceptance, and that venting certain chemicals, including refrigerants, will be prohibited effective July 1, 1992.
	02/12/1991	TC APPLICABILITY TO MIXED WASTE	Memo
	Description: Discusses the definition of mixed radioactive waste. Mixed waste was first subject to RCRA regulation in 1986. The toxicity characteristic does not apply to mixed waste in states with only RCRA base program authorization until the State revises its program and receives authorization for mixed waste. Discusses the status of mixed waste that fails the TCLP.
	02/05/1991	GENERATOR HAZARDOUS WASTE DETERMINATION AND THE TCLP	Memo
	Description: Clarifies a letter (RPC# 11/8/90-04). A generator may always apply knowledge in determining if a waste is hazardous waste. If no information is available except for inconclusive TCLP data, it is prudent for the generator to assume that the waste is hazardous. There is no need to perform TCLP on used oil that is destined for recycling.
	01/08/1991	LEADED PAINT SANDBLASTING WASTE TESTING USING TCLP	Memo
	Description: The land disposal restrictions (LDR) regulations continue to allow the use of either the extraction procedure (EP) or the TCLP to demonstrate compliance with the treatment standards for certain lead and arsenic wastes (SUPERSEDED: see 63 FR 28556; May 26, 1998). The TCLP is only test usable for characterization and identification of toxicity characteristic hazardous waste.
	11/09/1990	PETROLEUM-CONTAMINATED MEDIA AND DEBRIS DEFERRAL FROM THE TOXICITY CHARACTERISTIC	Memo
	Description: The petroleum contaminated media deferral does not apply to D001-D017. There is no need to run TCLP to determine if wastes are D018 - D043, provided the wastes are generated as part of UST corrective action.
	11/08/1990	APPLICABILITY OF THE TCLP	Memo
	Description: TCLP is inappropriate for certain matrices, like oils and neat solvents. Dilution step shifts detection limits are above regulatory levels. If that is the case, the generator must assume that the waste is hazardous (SEE ALSO: RPC# 3/25/91-01). TCLP must be used to obtain the extract.
	11/08/1990	BIAS CORRECTION APPLIED TO THE TCLP	Memo
	Description: Whenever the TCLP is used, all the requirements in the procedure must be met. All results should be corrected for bias, even if below standard. Spike matrix recovery is a bias correction tool (SEE ALSO: 57 FR 26986; November 24, 1992). Data collected before September 25, 1990 need not be corrected for bias per toxicity characteristic rule. The owner/operation may be held liable for the proper disposal of improperly characterized waste.
	11/01/1990	QC REVIEW OF PERMIT DATA	Memo
	Description: A matrix spike assists in ascertaining and correcting co-extracted artifacts (analytical bias) and tests laboratory conditions. Discusses performance of matrix spike recovery for TCLP analytes (SEE ALSO: 57 FR 26986; November 24, 1992).
	10/30/1990	USED OIL FILTERS - REGULATION; USED OIL FILTERS, REGULATORY DETERMINATION	Memo
	Description: Crushing a filter to remove used oil (UO) is exempt if the removed UO is recycled (SUPERSEDED: see 261.6(a)(4) and 279.10(c)). Generally, used auto oil filters are not containers because they are not storing oil. Filters are not empty containers. A filter with UO removed is exempt scrap metal if it is recycled. Undrained, uncrushed filters have too much oil for the scrap metal exemption (SEE ALSO: 261.4(b)(13)). TCLP is performed on UO filters by crushing, cutting, or grinding filters and their contents until the pieces are smaller than one cm in the narrowest dimension. A characteristic UO filter that is sent for disposal is subject to regulation (SUPERSEDED: see 261.4(b)(13)).
	10/01/1990	REGULATORY STATUS OF PETROLEUM CONTAMINATED MEDIA AND DEBRIS UNDER THE TOXICITY CHARACTERISTIC UST TEMPORARY DEFERRAL	Question & Answer
	Description: The Section 261.4(b)(10) exclusion applies to media and debris from UST corrective action. The exclusion does not apply to sludge removed from UST during remediation. The exclusion does not apply to media and debris that exhibit the toxicity characteristic for D003-D017.
	10/01/1990	TC RULE - IMPLEMENTATION	Memo
	Description: Discusses the potential impact of the toxicity characteristic final rule on reinjection of petroleum-contaminated groundwater, solvent-contaminated chlorofluorocarbons (CFCs), automobile and appliance fluff, oil-contaminated media, and off-site crude oil reclaimers.
	09/20/1990	SQG COMPLIANCE WITH TC RULE	Memo
	Description: A fuel oil leak from a household tank is exempt household hazardous waste (HHW). EPA does not determine if a particular waste is characteristic. The hazardous waste determination is the generator’s responsibility. SQGs that are newly subject due to the toxicity characteristic (TC) rule had until 11/2/90 to notify the region. SQGs were granted an additional three months to comply with the TC Rule. Spilled petroleum products that are reclaimed from contaminated soil and used to produce fuels are not solid wastes.
	08/24/1990	LEAD AND ARSENIC WASTES TREATMENT STANDARDS	Memo
	Description: Either the TCLP or extraction procedure (EP) can be used to demonstrate compliance with land disposal restrictions (LDR) treatment standards for lead and arsenic (SUPERSEDED: see 63 FR 28556; May 26, 1998). EP is no longer used for purposes of hazardous waste identification.
	08/24/1990	SPENT ANTI-FREEZE COOLANT REGULATORY STATUS	Memo
	Description: Waste antifreeze coolant (ethylene glycol) is not a listed hazardous waste (HW) but is a solid waste if intended for discard. The generator must determine if it is characteristic, by testing the waste or applying knowledge. Anecdotal evidence indicates that used antifreeze may exhibit the toxicity characteristic for lead, as determined using the EP (extraction procedure).
	08/17/1990	USED OIL FILTERS CLASSIFICATION	Memo
	Description: If the extract from the TCLP-tested used oil filter equals or exceeds the regulatory levels for any hazardous constituent the filter is a hazardous waste. Filters that have been drained are less likely to be hazardous (SEE ALSO: Section 261.4(b)(13)).
	08/14/1990	TCLP APPLICABILITY	Memo
	Description: The use of TCLP to evaluate solid waste prior to the effective date of TCLP is valid. Addresses the use of matrix spike recovery. TCLP is difficult to apply to oily or solvent matrices. In the absence of usable data, it is safest to assume the material is a hazardous waste (SEE ALSO: RPC# 3/25/91-01).
	08/13/1990	USED OIL AS A DUST SUPPRESSANT	Memo
	Description: Discusses the restrictions on the use of used oil (UO) as a dust suppressant (SUPERSEDED: see 279.12(b)). Toxicity characteristic used oil must not be used as a dust suppressant (SEE ALSO: 279.82).
	07/31/1990	MULTI-SOURCE LEACHATE AND TREATMENT STANDARDS OF LAND DISPOSAL RESTRICTIONS	Memo
	Description: Waste codes not required on the manifest. A TSDF may rely on waste analysis data from the generator, but the TSDF must periodically test representative samples. A lab may certify for land disposal restrictions (LDR) as representative of the waste handler. Waste analysis parameters. Stabilization of cyanide to reduce leachability is an inappropriate treatment and generally impermissible dilution. No dilution of toxicity characteristic wastes if land disposed. Generators must determine characteristics. If a listed treatment standard addresses the characteristic, it operates in lieu of characteristic (even if less stringent). Prohibited waste only placed in a minimum technological requirement (MTR) surface impoundment if meets treatment standards, variance or extension, or 268.4. Notice and certification for de-characterized waste is sent to the implementing agency. F039 HSWA. Permitted TSDFs with F039 submit Class 1 modification by 8/8/90. Lab packs must be burned in Subpart O incinerator, not cement kilns.
	07/30/1990	SUBMARINE REACTOR COMPARTMENTS - LAND DISPOSAL RESTRICTIONS	Memo
	Description: Lead reactor compartments may meet the land disposal restrictions (LDR) treatment standard of macroencapsulation for D008, radioactive lead solids as generated. Compliance with the technology-based standard does not require that waste undergo TCLP analysis.
	07/19/1990	ELECTRIC UTILITY POLES	Memo
	Description: Utility poles may exhibit the toxicity characteristic (TC) for organic constituents and trigger hazardous waste regulation. A generator of used utility poles removed from ground must determine if poles exhibit a characteristic of hazardous waste.
	07/11/1990	LOSS OF INTERIM STATUS FROM NEWLY IDENTIFIED TC WASTES	Memo
	Description: Discussion of loss of interim status (LOIS) dates for TSDFs subject to toxicity characteristic (TC) rule (55 FR 11798; 3/29/90). A facility that obtained interim status for the new TC waste is subject to federal requirements until the state is authorized for TC. Discussion of federal versus state regulation of TSDFs in authorized states that have not adopted TC rule. 3010 notification not required for facility that commenced treatment, storage or disposal after 6/27/90 but before 9/25/90.
	07/11/1990	NEWLY IDENTIFIED WASTE STREAMS AS A RESULT OF NEW TC	Memo
	Description: Discuses the loss of interim status (LOIS) dates for TSDFs subject to the toxicity characteristic (TC) rule (55 FR 11798; March 29, 1990). A facility that obtained interim status for new TC waste is subject to federal requirements until the State is authorized for the TC rule. Discusses federal v. state regulation of TSDFs in authorized states that have not adopted the TC rule. RCRA Section 3010 notification is not required for a facility that commenced treatment, storage or disposal after June 27, 1990 but before September 25, 1990.
	07/03/1990	CREOSOTE TREATED CROSS-TIES DISPOSAL	Memo
	Description: Creosote-treated railroad cross ties are solid waste when intended for discard. They are not covered by any listing. Although cresols and phenolic compounds are in the toxicity characteristic, commenters suggest creosote-treated cross ties unlikely to exhibit any characteristic.
	07/01/1990	TOXICITY CHARACTERISTIC WASTE PART B PERMIT APPLICATION DEADLINES	Question & Answer
	Description: Discusses Part A and Part B permit application deadlines for newly regulated land disposal facility and other types of facilities after promulgation of toxicity characteristic (TC) rule, and the definition of land disposal facility.
	06/25/1990	LEAD-BEARING WASTES TREATMENT STANDARDS	Memo
	Description: The TC (toxicity characteristic) is effective 9/25/90. There are different TC compliance dates for LQG (9/25/90) and SQG (3/29/91). D008 (lead) wastes that fail TCLP but pass EP (extraction procedure) are considered in compliance with D008 treatment standard and can be land disposed (SUPERSEDED: see 63 FR 28556; 5/26/98).
	06/20/1990	CLARIFICATION OF SPENT SOLVENT LISTINGS	Memo
	Description: If the total of all F001, F002, F004, or F005 solvents before use is 10% or more by volume, the waste from using solvent is listed and carries all applicable codes. F001-F005 codes can apply even if each F001-F005 constituent is under 10%. Trichloromethane (chloroform) is U044 or D022, not F-listed.
	06/14/1990	ADOPTION OF TCLP FOR DELISTING DEMONSTRATIONS	Memo
	Description: Notification to petitioners that, after finalization of toxicity characteristic rule, TCLP data will be required in all delisting petitions instead of extraction procedure (EP) data (SEE ALSO: 261.24).
	06/14/1990	PERSONAL PROTECTIVE GEAR DISPOSAL	Memo
	Description: Lead-contaminated personal protective equipment (PPE) or gear is subject to land disposal restrictions (LDR). Hazardous waste eligible for a national capacity variance may be disposed without treatment in a minimum technological requirement (MTR) landfill or surface impoundment if the waste is below California list prohibition levels (SUPERSEDED: California list removed, see 62 FR 25997; 5/12/97).
	04/20/1990	CLASSIFYING MERCURY-CONTAINING PAINTS AS HAZARDOUS WASTES	Memo
	Description: Mercury-containing paint discarded by homeowners is exempt household HW. Mercury-containing latex paint usually exhibits the toxicity characteristic when properly tested. The statement that paint will not exhibit mercury characteristic unless concentration exceeds 540 ppm is incorrect.
	04/12/1990	CADMIUM WASTES FROM MILITARY COATING MATERIALS	Memo
	Description: Cadmium wastes from coating materials and spent sacrificial anodes generated by military operations may be F-listed electroplating, heat treating, or aluminum conversion coating wastes (F006, F019, F007, F008, F009, F010, F011, F012) or may exhibit EP (extraction procedure) Toxicity for cadmium (SUPERSEDED: see Section 261.24).
	03/01/1990	USED OIL USED FOR DUST SUPPRESSION OR ROAD TREATMENT	Question & Answer
	Description: Used oil that exhibits the toxicity characteristic is prohibited from placement on the land for dust suppression or road treatment. The use of used oil for dust suppression or road treatment is use in a manner constituting disposal (SEE ALSO: 279.82).
	03/01/1990	USED OIL USED FOR DUST SUPPRESSION OR ROAD TREATMENT	Question & Answer
	Description: Used oil that exhibits the toxicity characteristic is prohibited from placement on the land for dust suppression or road treatment. The use of used oil for dust suppression or road treatment is use in a manner constituting disposal (SEE ALSO: Section 279.82).
	02/16/1990	IGNITABILITY OR CORROSIVITY TESTING-LIQUID AND AQUEOUS DEFINITION	Memo
	Description: No mandatory test for determining liquid and aqueous for ignitability (D001) and corrosivity (D002) characteristic testing. Paint filter liquid test (PFLT) Method 9095 may be used. Method 9095 is not appropriate for toxicity characteristic.
	02/15/1990	Environmental Fact Sheet: Plastics: The Facts on Source Reduction	Publication
	Description: Presents EPA's Report to Congress on methods to manage and control plastic wastes. Outlines EPA's belief that source reduction is the best method for reducing environmental impacts from wastes, by decreasing the amount or toxicity of materials that are thrown away.
	12/13/1989	DIGESTION OF EP AND TCLP EXTRACTS PRIOR TO METAL ANALYSIS	Memo
	Description: For Method 1310 (extraction procedure) (EP) and Method 1311 (TCLP) the extracts should be digested prior to metal analysis if waste contains phases or if the waste precipitates during cold storage.
	11/03/1989	BLAST SLAG TESTING PROCEDURES	Memo
	Description: Discusses representative sampling for blast slag generated at lead recycling facilities for purposes of extraction procedure (EP) (SUPERSEDED: see Section 261.24).
	10/05/1989	DEFINITION OF A LIQUID AS IT APPLIES TO IGNITABLE AND CORROSIVE WASTES; LIQUID AS IT APPLIES TO IGNITABLE OR CORROSIVE WASTES	Memo
	Description: The definition of liquid depends on the specific regulatory application for ignitable (D001), corrosive (D002), and extraction procedure (EP) (SUPERSEDED: see 261.24). For toxic wastes, liquid is defined as the material expressed from the waste in Step 2 of Method 1310. Liquids produced from paint filter test are generally also liquids under Method 1310 (SEE ALSO: 60 FR 3092; January 13, 1995). Only wastes containing a liquid component are subject to the flash point test (ignitability (D001)) and the pH test (corrosivity (D002)). Method 9095 is used to determine if a waste is prohibited from disposal in a landfill for containing free liquids. Method 9096 is a draft procedure for determining if adsorbents contain releasable liquids. Adsorbents containing releasable liquids are prohibited from disposal in a landfill by HSWA.
	10/03/1989	PETITION TO WITHDRAW K090 AND K091 LISTINGS	Memo
	Description: K090 and K091 cover waste generated by air pollution control devices from ferrochromium or ferrochromium silicon production furnaces. K090 and K091 are listed for total chromium (Cr). As of 1989, there is no plan to remove listings since new data show trivalent Cr may be a carcinogen. EPA is considering removing the 261.4(b)(6) exclusion for wastes containing trivalent chromium. EPA will not remove listed waste from regulation based solely on whether or not waste exhibits toxicity characteristic. In making delisting decisions, EPA considers whether waste meets any of the criteria for which it was originally listed, as well as additional constituents and factors.
	08/17/1989	SCRAP DENTAL AMALGAM	Memo
	Description: Dental silver amalgam is not specifically listed as a hazardous waste. The American Dental Association (ADA) research suggests amalgam does not exhibit extraction procedure (EP) toxicity (SUPERSEDED: See 261.24), but the burden of determination is ultimately the generator's. ADA data could be the basis of a determination by knowledge. CERCLA 107 liability is independent of the material’s regulatory status under RCRA.
	08/02/1989	CHLOROFLUOROCARBONS (CFCS) AS REFRIGERANTS, RECYCLING OF SPENT	Memo
	Description: Used CFC refrigerants are not hazardous waste F001 or F002 because they were not used as solvents, and are not U121 because they have been used. Such wastes are only hazardous if characteristic (SEE ALSO: 261.4(b)(12)).
	08/01/1989	WASTE IDENTIFICATION OF DISCARDED THERMOMETERS	Question & Answer
	Description: An unused mercury thermometer is not U151 when discarded. A thermometer is considered a manufactured article, not CCP. EPA did not intend for P and U-lists to apply to manufactured articles containing chemicals listed in Section 261.33. Thermometers are hazardous waste if they fail toxicity characteristic for mercury. (SEE ALSO: 70 FR 45508; 8/5/05)
	07/20/1989	LIQUID, FREE LIQUID, RELEASABLE LIQUID DEFINITIONS	Memo
	Description: Liquid for purposes of corrosivity (D002) determined by Method 1310 (extraction procedure (EP)). The definition of free liquid applies to the prohibition of liquids in landfills. Definition of releasable liquid applies to absorbent materials that might release liquids (SEE ALSO: current Sections 264.314(e), and 265.314(f)).
	06/30/1989	DENTAL AMALGAM DISPOSAL	Memo
	Description: Dental amalgam is not specifically listed, so the generator is responsible for determining the applicability of hazardous waste characteristics. Silver and mercury are of particular concern. EPA has no plan to develop specific rules regarding the recycling of dental amalgam.
	05/17/1989	SCRAP AMALGAM FILLINGS FROM DENTISTS, DISPOSAL OF	Memo
	Description: Dental amalgam is hazardous if it exhibits extraction procedure (EP) toxicity for lead or silver (SUPERSEDED: See 261.24). Most dentists are probably classified as CESQGs.
	05/12/1989	PROCEDURE FOR APPLYING EP TOXICITY TEST TO BLAST SLAG AT SECONDARY LEAD SMELTERS	Memo
	Description: Discussion of the proper procedure for testing blast slag at secondary lead smelter according to extraction procedure (EP) toxicity test (SUPERSEDED: See 261.24). Reconciliation of particle reduction step with structural integrity requirement.
	04/20/1989	EP TOXICITY LEVEL FOR BARIUM IN DRINKING WATER	Memo
	Description: The regulatory levels for extraction procedure (EP) toxicity depend on both MCLs and a fate and transport factor of 100 (EP toxicity levels are equal to 100 times the MCLs). Therefore, a change to the MCL for barium would not automatically merit a change to the extraction procedure regulatory level (SUPERSEDED: See 261.24).
	02/22/1989	REGULATORY STATUS OF SOLVENT, “ULTIMA-GOLD”	Memo
	Description: Unused solvent is only subject to regulation as a discarded material when abandoned (i.e., disposed or incinerated) or recycled by being burned for energy. A CCP that is abandoned is a solid waste, while a CCP being reclaimed is not a solid waste. The transportation and sale of unused solvent, Ultima-Gold, is not subject to Subtitle C because it is a product rather than a discarded material. The material safety data sheet for solvent product "Ultima-Gold" indicates potential to be corrosive (D002) and reactive (D003). The product "Ultima-Gold" does not exhibit ignitability (D001) or extraction procedure (EP) toxicity (SUPERSEDED: See 261.24). A product solvent only meets P-listing or U-listing if the chemical on the P-list or U-list serves as the product's sole active ingredient.
	01/27/1989	TOTAL CONCENTRATION USED TO DEMONSTRATE A WASTE DOES NOT EXHIBIT THE CHARACTERISTIC OF EP TOXICITY	Memo
	Description: The maximum theoretical leachate concentration limits for TCLP can be calculated from the results of a total waste analysis of liquid wastes, solid wastes, and dual-phase wastes using a specific formula. Discusses the maximum theoretical extract concentration (MTEC) (SEE ALSO: RPC# 1/1/94-01).
	01/25/1989	FLUFF ANALYSIS/SAMPLES	Memo
	Description: The extraction procedure (EP) (SUPERSEDED: see 261.24) analyses of fluff should be conducted after samples have undergone the appropriate size reduction. The extraction procedure does not require the size reduction of materials whose ratio of surface area to weight is greater than 3.1 cm2/g (e.g., pieces of fabric or wire).
	11/21/1988	FLUFF RESIDUALS FROM FERROUS METALS RECYCLING (AUTOMOBILE SHREDDING)	Memo
	Description: Fluff residual from automobile shredding may commonly exhibit extraction procedure (EP) toxicity (SUPERSEDED: See 261.24) for lead. Other metals of concern include cadmium and chromium. PCB contamination may subject the fluff to additional regulation under TSCA. Hazardous waste fluff is subject to California list if it equals or exceeds halogenated organic compound (HOC) prohibition levels (SUPERSEDED: California list removed, see 62 FR 25997; 5/12/97).
	10/19/1988	MULTIPLE EXTRACTION PROCEDURE, METHOD 1320	Memo
	Description: For the multiple extraction procedure (Method 1320), the weight of the wet material remaining after each extraction procedure (EP), not the original dry weight, is used to calculate the 20:1 liquid to solid ratio. Method 1320 is trying to predict the effect on the waste in a landfill that is subject to rain for a long period of time.
	07/30/1988	RCRA TEST METHODS & QA ACTIVITIES	Memo
	Description: Provides clarification of an error in Method 3500. The SOXTEC extraction procedure is suitable for determining PCBs in soil. Discusses suitable techniques for determining total halogens in used oil. Contract Lab Program (CLP) participation does not constitute EPA certification.
	05/18/1988	COLORED GLAZE SOLIDS COLLECTED IN POTTERY MANUFACTURING OPERATIONS	Memo
	Description: Extraction procedure (EP) (SUPERSEDED: See 261.24) toxic glazes incorporated into pottery are not solid wastes because they are used as an ingredient in an industrial process to make a product.
	05/02/1988	CALIFORNIA AUTHORIZATION - EVALUATION OF THE WASTE EVALUATION TEST	Memo
	Description: California’s waste extraction test (WET) is equivalent to the extraction procedure (EP) for the toxicity characteristic. WET may be broader in scope (cover more waste) rather than more stringent (tighter control over covered waste) and thus affect EPA enforcement and authorization of California’s RCRA program.
	04/14/1988	APPLICABILITY OF SOLVENT AND ELECTROPLATING LISTINGS	Memo
	Description: Discarded paint, residues (scrubber water) with a solvent ingredient are not F-listed, but may be characteristic. Paint stripper is a solvent use. A sludge from metal cleaning wastewater associated with electroplating is F006. Routine cleaning, stripping not normally associated with electroplating. The purpose of cleaning, not the location, determines if associated. Metal stripping is part of electroplating. Stripped paint waste listed solely for a characteristic (F003) mixed with a solid waste is hazardous only if it is characteristic (SEE ALSO: 66 FR 27266; 5/16/01). Discussion of mixture rule wastewater exclusions (SEE: 261.3(a)(2)(iv)). F007-F009 are for cyanide electroplating solutions or where cyanides are used in the process. A spent stripping bath itself might also be F001-F005. The scale and size of aluminum chemical conversion coating operation does not affect F019.
	03/24/1988	REGULATORY STATUS OF ECOSCINT A AND ECOSCINT O	Memo
	Description: Liquid scintillation cocktails Ecoscint A and O are not listed, EP (extraction procedure) toxic (SUPERSEDED: See 261.24) or ignitable (D001), but data provided are not sufficient to make corrosivity (D002) or reactivity (D003) determination (SEE ALSO: RPC# 3/1/89-04). The generator is responsible for the hazardous waste determination.
	03/09/1988	PROPOSED BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BDAT) FOR K061 WASTE	Memo
	Description: Zinc oxide collected in a baghouse that is sold as a product is no longer derived from K061. Calcining residuals from K061 wastes may exhibit a characteristic. The use of a K061 treatment residual as roadbed and anti-skid material is use in a manner constituting disposal (SEE ALSO: 266.20(c), 59 FR 67256; 12/29/94). The K061 treatment standards are performance standards that are based on a Best Demonstrated Available Technology (BDAT) of high temperature metals recovery (HTMR). EPA does not require or recommend the use of any specific class of high temperature metals.
	02/10/1988	RESIDUALS GENERATED BY PROCESS FOR SEWAGE SLUDGE TREATMENT	Memo
	Description: The generator of residuals from treating sewage sludge must determine if the residuals are characteristic hazardous waste. The determination can be made by testing or by applying knowledge of the materials and processes. EPA does not endorse or support specific processes.
	12/31/1987	TOTAL CONSTITUENT ANALYSIS TO DETERMINE HAZARDOUS CHARACTERISTICS OF WASTE SAMPLE	Memo
	Description: Discusses the applications of totals analysis in lieu of TCLP. If guidance levels of the compound are not exceeded assuming 100% leachability, no further analysis is required. Provides the 100% leachability formula. Addresses the maximum theoretical extract concentration (MTEC) (SEE ALSO: RPC# 1/1/94-01).
	12/04/1987	ALLOWABLE HOLDING TIMES WHEN TESTING RCRA SAMPLES	Memo
	Description: Discusses the holding time determination for RCRA samples. The holding time begins when the sample is generated. Addresses the holding times for the extraction procedure (EP) analysis, for volatile organics in groundwater using Method 8010, and semi-volatile organics in groundwater using Methods 3510 and 8270.
	12/03/1987	PAINT FILTER LIQUIDS TEST USED TO DETERMINE COMPLIANCE WITH THE CALIFORNIA LIST RESTRICTIONS	Memo
	Description: EPA is considering the use of the paint filter liquids test, the extraction procedure, and the Toxicity Characteristic Leaching Procedure to determine compliance with the statutory California List land disposal restrictions (LDR) prohibition levels (SUPERSEDED: California list removed, see 62 FR 25997; 5/12/97).
	11/20/1987	LEAD-BASED PAINT RESIDUES AND CONTAMINATED SOILS	Memo
	Description: Paint wastes are exempt household hazardous wastes (HHW) if they are generated by homeowners and not by contractors (SUPERSEDED: RPC# 3/1/90-06). HHW from federal agencies is not HHW. Certain material and soil contaminated with weathering lead based paint is characteristic for lead. If characteristic soil is actively managed, it is a hazardous waste. Discusses lead paint remediation methods (SEE ALSO: RPC# 3/7/95-01). A property owner is normally not required to characterize soil left on site. Addresses factors in determining if soil removal is required. On-site soil treatment needs a permit unless the generator is exempt (SEE ALSO: 61 FR 18779; 4/29/96).
	11/18/1987	TCLP IN THE LAND DISPOSAL RESTRICTIONS PROGRAM AND HAZARDOUS WASTE IDENTIFICATION PROGRAM	Memo
	Description: TCLP was created for the land disposal restrictions (LDR) program for testing for solvents and dioxins, and for the toxicity characteristic.
	11/12/1987	PULVERIZING / CRUSHING WASTE PRIOR TO EP TEST	Memo
	Description: Metal rings and lids that are part of an ash wastestream should not be removed when testing a representative sample for the toxicity characteristic. Although pulverizing is inappropriate for metal objects, the particle reduction requirement in the extraction procedure (EP) (SUPERSEDED: see 261.24) is still in effect.
	11/05/1987	LEACHING TESTS FOR EVALUATING SOILS CONTAMINATED WITH LEAD	Memo
	Description: Method 1310 extraction procedure (EP) is used to determine if contaminated soils exhibit the toxicity characteristic (SUPERSEDED: see 261.24). Method 1312 for in-place soil and debris is under development. It may be appropriate for facility investigations and clean closure determinations. 1311 (TCLP) may not be appropriate for groundwater contamination of soil and debris.
	10/20/1987	RCRA TESTING TECHNIQUES	Memo
	Description: Addresses the gas chromatograph/mass spectrometer suitability testing of RCRA Appendix VIII and Michigan List Analytes. Includes notes on laboratory safety and noxious fumes from nitric acid digestion. Discusses the standardization of method 8610, microwave oven safety, the 1988 Solid Waste Testing and Quality Assurance Symposium, the TCLP video, and the application of the structural integrity procedure when performing extraction procedure analyses.
	10/08/1987	ENVIRONMENTAL HAZARDS ASSOCIATED WITH BURNING HAZARDOUS WASTE IN CEMENT KILNS	Memo
	Description: Cement kiln dust (CKD) generated during the use of hazardous waste fuel contains elevated lead levels but tends not to leach enough lead to fail the extraction procedure (EP) toxicity test (SUPERSEDED: see 261.24). EPA considers cement kiln dust to be nonhazardous under the Bevill exemption and does not plan on issuing specific guidance (SEE ALSO: 60 FR 7366; 2/7/95).
	10/02/1987	DELISTING POLICY ALLOWS EXCLUSION OF SEPARATE WASTE TREATMENT UNITS AT MULTI-UNIT FACILITIES	Memo
	Description: Delistings allow the exclusion of separate waste treatment units at a multi-unit facility. Discusses the Oily Waste Extraction Procedure (OWEP) for oil and grease exceeding 1% (SEE ALSO: 261.24). Addresses the 6 month deadline for the submission of information before a petition dismissal. A withdrawal prevents a denial notice in the Federal Register.
	09/23/1987	F021 LISTING FOR SUBSTANCES CONTAINING CHLOROPHENOLIC COMPOUNDS	Memo
	Description: Wood chips and sawdust from wood treated with a pentachlorophenol (PCP) formulation (Noxtane) are not F-listed or K-listed. They could be characteristic. Discarded CCP Noxtane is F027 due to the active ingredient PCP.
	09/16/1987	SW-846 METHODS MANUAL	Memo
	Description: The use of SW-846 methods is generally not required except for quality assurance/quality control procedures and determining if the waste is characteristic. Discusses sampling, analysis for delisting petitions, incinerator trial burns, and determining if bulk or containerized waste contains free liquids prior to disposal in a landfill.
	08/11/1987	METHODS 1310 AND 1330: EXTRACTION PROCEDURE AND EXTRACTION PROCEDURE FOR OILY WASTE	Memo
	Description: Method 1310 extraction procedure (EP) is the only method to be used for determining the applicability of the toxicity characteristic, even for oily waste (SUPERSEDED: See 261.24). Method 1330 (EP for oily waste) may be used for delisting.
	08/07/1987	WASTES FROM ENVIRONMENTAL CHEMISTRY LABORATORY	Memo
	Description: High temperature incineration is the recommended method of management for lab wastes that are not listed hazardous waste and that do not exhibit any characteristics, even though they are contaminated with dioxins.
	07/21/1987	F003 10% RULE AND ASSOCIATED REGULATIONS	Memo
	Description: Discarded, used paint thinner that is 80% xylene, 9% toluene, and 11% glycol ethers before use is ignitable (D001) not F003, F005. Ignitable solvent rags are not subject to the land disposal restrictions (LDR) until third third (SEE ALSO: 55 FR 22520; 6/1/90 and RPC# 2/14/94-01).
	06/26/1987	TREATMENT AND DISPOSAL METHODS FOR LOW-LEVEL WASTES THAT CONTAIN UNCONTAMINATED OR RADIOACTIVE LEAD	Memo
	Description: Activated lead may be stored to allow radioactive decay prior to disposal as a hazardous waste. Mixed waste storage requires a permit. Surface-contaminated lead may be decontaminated. EPA may establish below regulatory concern (BRC) levels for radiation. Container liners used as shielding in low-level waste disposal are not RCRA-regulated. Encapsulation may be a viable treatment for lead wastes if the process results in a product that will not degrade after disposal (SEE ALSO: 64 FR 63464; 11/19/99).
	06/23/1987	USE OF THE METHOD OF STANDARD EDITIONS	Memo
	Description: SW-846 requires that the method of standard editions be used whenever the percent recovery of a matrix spike is outside the range of 75-125%. The method of standard additions is required, in all cases, when analyzing extraction procedure (EP) toxicity extracts (SEE ALSO: 57 FR 55115; 11/24/92).
	06/19/1987	REGULATORY STATUS OF VARIOUS TYPES OF PENTACHLOROPHENOL WASTES	Memo
	Description: F021 is for pentachlorophenol (PCP) manufacturing wastes, not for wood-preserving wastes like dip tank bottom sludge or discarded pentachlorophenol (PCP)-treated wood (SEE ALSO: F032). F027 is for unused PCP wood preservatives, not for used formulations which come in contact with wood that remains in process vessel or dip tank after treatment or contained-in treated wood (posts, poles, railroad ties); K001 for treatment sludges from wastewater from PCP or creosote wood preserving, not dip tank bottom sludge from PCP wood preserving facilities (SEE ALSO: 261.24 and 261.31)
	06/08/1987	F006 WASTES, VHS AND GROUNDWATER MONITORING DATA TO EVALUATE A DELISTING PETITION FOR	Memo
	Description: The vertical and horizontal spread (VHS) model is used in delistings. A delisting for wastes managed in on-site waste management units must have a groundwater monitoring system in place and 4 quarters of data. Oily Waste Extraction Procedure (OWEP) is used for wastes with 1% oil and grease (SEE ALSO: 261.24).
	06/08/1987	TOTAL CHROMIUM ANALYSIS	Memo
	Description: The toxicity characteristic regulates chromium as total chromium.
	05/20/1987	SOLVENT LISTINGS AND LAND DISPOSAL RESTRICTIONS	Memo
	Description: Discusses determining if solvent contaminated rags or wipers are listed hazardous waste (SUPERSEDED: RPC# 2/14/94-01). Product paint with a solvent ingredient is not listed, even if the solvent is added as a thinner after purchase. The addition of product solvent by the user is not solvent use. Listed solvents from ink formulation are both K086 and the appropriate F001-F005 when discarded. Lab solvents used as solvents are listed when spent. Technical grade F003 solvent can be F003 when spent. A solvent containing (before use) less than the technical grade of F003 and less than 10% F001, F002, F004, F005 is not listed.
	04/18/1987	SOIL CONTAMINATED WITH USED AND UNUSED PESTICIDES; SOIL CONTAMINATED WITH PESTICIDE	Memo
	Description: Soil contaminated with discarded unused 2,4,5-T contains F027. Soil contaminated with 2,4,5,-T used as pesticide does not contain a listed waste, but is hazardous if it is excavated for discard and is characteristic. Incinerators burning F-listed dioxin wastes must achieve 99.9999% destruction and removal efficiency.
	04/08/1987	MUNICIPAL WASTE COMBUSTION, DISPOSAL OF RESIDUAL ASH	Memo
	Description: Discusses regulatory alternatives for the management of characteristically hazardous municipal waste combustor (MWC) ash (SEE ALSO: RPC# 10/1/94-02; 59 FR 29372; 6/7/94; 60 FR 6666; 2/3/95; RPC# 3/22/95-01).
	03/11/1987	SCINTILLATION COUNTING COCKTAIL	Memo
	Description: The liquid scintillation cocktail, Bio-Safe II, does not appear to be a hazardous waste, provided that it is not reactive (D003) or corrosive (D002), since it is not ignitable (D001) and does not exhibit the toxicity characteristic (D018-D043). Neither scintillation cocktails, nor lab wastes in general, are listed (SEE ALSO: RPC# 3/1/89-04). Hazardous waste identification is the generator's responsibility.
	03/11/1987	SOILS CONTAMINATED WITH CHLORDANE AND HEPTACHLOR DURING TREATMENT OF BUILDINGS FOR TERMITES	Memo
	Description: Soil contaminated from the treatment of a home for termites with chlordane and heptachlor is not P-listed or U-listed, because the contamination is from normal pesticide use. The soil may be hazardous if it is characteristic. Addresses the contained-in policy.
	03/06/1987	AUTOMOTIVE FLUIDS, REGULATION OF	Memo
	Description: Automotive fluids are not listed hazardous waste, but they may be characteristic. Some brake and automatic transmission fluids are ignitable (D001). Used crankcase oil may be ignitable and may exhibit EP (extraction procedure) for lead (SUPERSEDED: see 261.24). Used oil (UO) that is recycled by burning is subject to 266 Subpart E; other UO recycling is exempt (SUPERSEDED: see Part 279). Brake fluid, power steering fluid, and automatic transmission fluid would all be considered UO. Antifreeze and windshield wiper fluid are not UO (SEE ALSO: 279.1).
	03/06/1987	AUTOMOTIVE FLUIDS, STATUS OF	Memo
	Description: Automotive fluids are not listed hazardous waste, but they may be characteristic. Some brake and automatic transmission fluids are ignitable (D001). Used crankcase oil may be ignitable and may exhibit EP (extraction procedure) for lead (SUPERSEDED: see 261.24). Used oil (UO) that is recycled by burning is subject to 266 Subpart E; other UO recycling is exempt (SUPERSEDED: see Part 279). Brake fluid, power steering fluid, and automatic transmission fluid would all be considered UO. Antifreeze and windshield wiper fluid are not UO (SEE ALSO: 279.1).
	03/06/1987	DRYCLEANING INDUSTRY WASTES	Memo
	Description: Perchloroethylene (PCE) condensed and recovered during fabric drying in a dry cleaning machine is a process waste, not an F-listed solvent. It is hazardous only if it is characteristic. PCE condensate from distillation or spent filter cartridge steam stripping is hazardous because it is derived from F002.
	02/19/1987	PROCESS WASTES CONTAINING INKS, PAINTS, AND ADHESIVES	Memo
	Description: Waste paint, ink, and adhesive are not listed. These are hazardous only if characteristic. Products with ingredient or added solvent not are not listed solvents. A mixture of a listed solvent and a product destined for discard are F-listed via the mixture rule (SEE ALSO: 66 FR 27266; 5/16/01).
	02/05/1987	APPLICABILITY OF LAND DISPOSAL RESTRICTIONS (LDR) TO PAINT SLUDGE WASTES	Memo
	Description: Paint sludge waste from a water-wall paint spray booth is a manufacturing process waste, not an F-listed solvent.
	01/27/1987	SOLVENTS USED AS COOLANTS AND APPLICABILITY OF SOLVENT LISTINGS	Memo
	Description: Spent coolant with 1,1,1,-trichloroethane (111-TCE) as an ingredient is not listed if it is not commingled with 111-TCE used in degreasing (F001). Coolant is only a hazardous waste if it is characteristic. Future changes to the toxicity characteristic might address TCE (SEE ALSO 55 FR 11862; 3/29/90).
	12/30/1986	SAMPLING PLAN FOR DELISTING PETITION ADDRESSING HSWA REQUIREMENTS FOR ANALYZING FOR APPENDIX VIII COMPOUNDS	Memo
	Description: Addresses sampling parameters in delisting petitions. If the amount of oil and grease in sludge exceeds one percent, the Oily Waste Extraction Procedure (OWEP) should be used. OWEP uses a dual solvent extraction instead of a dilute acetic acid solution which is used in the extraction procedure (EP) (SEE ALSO: 261.24).
	10/30/1986	HAZARDOUS WASTE CLASSIFICATION OF PAINTED CIRCUIT BOARDS	Memo
	Description: Although printed circuit boards are not specifically listed, they commonly exhibit the extraction procedure (EP) toxicity characteristic (SUPERSEDED: See 261.24) for lead that leaches from the solder (SEE ALSO: 261.4(a)(14) exclusion for shredded circuit boards).
	10/21/1986	REGULATORY STATUS OF USED WOOD PRESERVATION CONTAINING PENTACHLOROPHENOL (PCP)	Memo
	Description: A mixture of unused pentachlorophenol (PCP) formulation (F027) and used PCP formulation that is spilled, disposed, or intended for disposal, is F027 via the mixture rule. As F027 does not include used PCP formulations, it is only hazardous waste if mixed with a listed or characteristic waste.
	09/30/1986	GLASS FIBER FILTERS FOR USE IN CONDUCTING THE TOXICITY CHARACTERISTIC LEACHING PROCEDURE (TCLP)	Memo
	Description: The denial of a request to add glass fiber filters to the list of filters is deemed suitable for TCLP purposes.
	09/29/1986	SOIL CONTAMINATED WITH CHLORDANE AS A RESULT OF PESTICIDE APPLICATION	Memo
	Description: While unused CCP chlordane is listed as U036 when it is discarded, land application of chlordane pesticide product does not make it a solid waste even though it is used in a manner constituting disposal, since placement on land is the pesticide’s intended purpose (261.2(c)(1)(B)(ii)). Soil contaminated with chlordane as a result of pesticide application is a hazardous waste only if excavated for disposal and characteristic.
	09/04/1986	MERCURY DRY CELL BATTERIES AND APPLICABLE REGULATIONS	Memo
	Description: Mercury dry cell batteries (battery) that exhibit a characteristic are hazardous waste (HW) and must be managed by a HW management TSDF, unless they are household hazardous waste (HHW) or a CESQG waste (SEE ALSO: Part 273).
	09/03/1986	LABORATORY EQUIPMENT USED IN CONDUCTING THE TOXICITY CHARACTERISTIC LEACHING PROCEDURE (TCLP)	Memo
	Description: A tentative EPA decision to list a zero-headspace extractor (ZHE) to the list of suitable extractors for conducting evaluations of volatiles in the TCLP.
	08/22/1986	HYDRAULIC DEVICES CONTAMINATED WITH OIL DURING QUALITY CONTROL TESTING	Memo
	Description: Used oil from hydraulic equipment is hazardous waste if it is characteristic or if the proposed used oil listing is finalized (SUPERSEDED: See 51 FR 41900; 11/19/86, 57 FR 41566; 9/10/92, and Part 279). Hydraulic equipment contaminated with used oil during quality control testing conducted prior to sale and distribution is not subject to the mixture rule because the equipment is a product, not a solid waste.
	08/04/1986	PRE-COAT WASTE CONTAINING 2-ETHOXYETHANOL (EXTRUDING PROCESS WASTE)	Memo
	Description: Using solvents as reactants or ingredients in products is not solvent use. Wastes from processes where solvents were used as reactants are not F-listed. Waste from process where 2-ethoxyethanol was used as ingredient in pre-coating cannot be F-listed solvent waste, although it may exhibit a characteristic.
	07/02/1986	WASTES GENERATED IN A PROCESS USING METHYLENE CHLORIDE TO RECOVER ALKALOIDS FROM PLANT MATTER; WASTES GENERATED FROM EXTRACTION PROCESS	Memo
	Description: A filter cake from an extraction process with listed methylene chloride is not listed, but may be hazardous if characteristic. Wastewater stripped from solvent wastewater is not listed, but may be hazardous if characteristic. Spent solvent from an extractor is listed hazardous waste.
	06/26/1986	SILVER IN WASTES AND IN SEWER DISCHARGES FROM THE PHOTO-FINISHING INDUSTRY	Memo
	Description: RCRA does not limit the photo-finishing (photography) industry’s ability to discharge silver-containing wastewater (D011) to the public sewer. The sewer discharge is regulated under CWA.
	06/02/1986	PAINTING CONTRACTOR WASTES-SMALL QUANTITY GENERATOR	Memo
	Description: Methylene chloride is a listed waste (F002) when used as a solvent and can be toxic. Muriatic acid is likely to be corrosive (D002) but not toxic. Generators who produce greater than 100 kg/mo are subject to regulation. CESQGs may dispose of hazardous waste in any state approved landfill.
	05/30/1986	WASHWATERS GENERATED FROM WASHING PESTICIDE APPLICATOR TRUCKS	Memo
	Description: Truck or service vehicle wash rinsewater contaminated with pesticide from ground application is not hazardous waste (HW) via the mixture rule. The residue is not a discarded CCP because it is released into the environment from use. Rinsewater is a HW only if it is characteristic (SEE ALSO: RPC# 7/22/85-01).
	05/27/1986	RESIDUES FROM MUNICIPAL WASTE RESOURCE RECOVERY FACILITIES; MUNICIPAL WASTE COMBUSTION RESIDUES-ASH AND SLUDGE	Memo
	Description: Municipal waste combustion (MWC) ash may exhibit the toxicity characteristic. Hazardous ash disposed in landfills is subject to all hazardous standards. EPA has authority under CAA and RCRA to control dust. RCRA is the primary authority for groundwater protection at active landfills (SEE ALSO: RPC# 10/1/94-02; 59 FR 29372; 6/7/94; 60 FR 6666; 2/3/95; RPC# 3/22/95-01).
	05/23/1986	USED X-RAY FILMS	Memo
	Description: Based on trade association data, x-ray film does not appear to be hazardous waste (HW). Nonetheless, each generator is responsible for making this determination. If HW x-ray film is sent for precious metal recovery, the generator must manifest the waste and get an D number.
	05/09/1986	HEALTH ASSESSMENT INFORMATION IN LISTING DECISIONS	Memo
	Description: EPA uses health assessment information such as the relative carcinogenic potencies, along with other evaluations of potential exposure and mismanagement, in deciding whether a waste is hazardous.
	05/05/1986	LABORATORY EQUIPMENT USED TO RUN THE TOXICITY CHARACTERISTIC LEACHING PROCEDURE (TCLP)	Memo
	Description: A discussion of the steps necessary for the designation of a substitution TCLP zero-headspace extractor.
	05/02/1986	ACTIVATED CARBON CANISTERS USED TO COLLECT SOLVENT VAPORS GENERATED DURING PAINT APPLICATION	Memo
	Description: F-listings do not apply to solvents such as 1,1,1-trichloroethane, Freon 113, and methylene chloride that are used as ingredients or reactants in CCPs (e.g., paint). Activated carbon used to collect solvents volatilized during paint application would only be hazardous waste if characteristic. Solvent use includes use as a cleaning or degreasing agent, as a medium for chemical reactions, as extractants, and as diluents.
	04/30/1986	FLUORESCENT AND MERCURY VAPOR LAMPS AND CLASSIFICATION USING THE EP TOXICITY TEST	Memo
	Description: Fluorescent and mercury vapor lamps may exhibit the toxicity characteristic (TC) for mercury as determined using the extraction procedure (EP) (SUPERSEDED: See 261.24) (SEE ALSO: RPC# 12/7/92-01). Some States regulate waste based on total mercury, not leachable mercury.
	04/28/1986	GENERATOR USE OF TOTAL CONSTITUENT ANALYSIS IN LIEU OF THE EP OR TCLP TESTS	Memo
	Description: A generator may use knowledge to make a characteristic determination, including the total waste concentration. When using total waste analysis in lieu of the extraction procedure (EP) or TCLP tests, the generator must assume all the contaminant present in the waste will migrate or leach into a liquid extract. A discussion of the maximum theoretical extract concentration (MTEC) (SEE ALSO: RPC# 1/1/94-01).
	04/07/1986	ENVIRONMENTAL RELEASES FROM WOOD PRESERVING PLANTS	Memo
	Description: A summary of EPA regulations applicable to releases from wood preserving facilities. The wood preserving process wastewater effluent is subject to the CWA (SEE ALSO: 261.4(a)(9)). The storage or mixing tanks, kraft bags can be empty containers under section 261.7. Discusses the applicability of the F020, F021, F026, F027 listings. Dioxin wastes are acutely hazardous and are subject to the 1 kg threshold. Wastewater treatment sludges from creosote and pentachlorophenol (PCP) are K001. An explanation of the closure of units used to treat these process wastewaters. The applicability of the EP (extraction procedure) toxicity characteristic (SUPERSEDED: see 261.24) to wood preserving wastes. A discussion of section 3004(u) and (v) corrective action at wood preserving facilities.
	04/07/1986	WOOD PRESERVING AND SURFACE PROTECTION FACILITIES, CONTROLLING ENVIRONMENTAL RELEASES FROM	Memo
	Description: A summary of EPA regulations applicable to releases from wood preserving facilities. The wood preserving process wastewater effluent is subject to the CWA (SEE ALSO: 261.4(a)(9)). The storage or mixing tanks, kraft bags can be empty containers under section 261.7. Discusses the applicability of the F020, F021, F026, F027 listings. Dioxin wastes are acutely hazardous and are subject to the 1 kg threshold. Wastewater treatment sludges from creosote and pentachlorophenol (PCP) are K001. An explanation of the closure of units used to treat these process wastewaters. The applicability of the EP (extraction procedure) toxicity characteristic (SUPERSEDED: see 261.24) to wood preserving wastes. A discussion of section 3004(u) and (v) corrective action at wood preserving facilities.
	03/21/1986	CHROMIUM WASTES: TRIVALENT AND HEXAVALENT, CHROMIUM IN TANNERY WASTES	Memo
	Description: The extraction procedure (EP) toxicity based on the total chromium (hexavalent and trivalent) (SUPERSEDED: see 261.24). Trivalent chromium oxidizes to hexavalent when drinking water is treated with chlorine. Tannery wastes containing solely trivalent chromium are excluded. The extraction procedure thresholds are 100X the drinking water standard.
	03/12/1986	DETECTION LIMIT FOR EP-LEACHATE CONCENTRATION OF SELENIUM	Memo
	Description: The detection limit for the extraction procedure (EP) leachate concentration of selenium is in petition.
	03/03/1986	SPENT CARBON USED TO REMOVE DISSOLVED PENTACHLOROPHENOL (PCP) FROM GROUNDWATER	Memo
	Description: Spent carbon used to treat groundwater contaminated by product pentachlorophenol (PCP) spill is acute hazardous waste F027. Under other circumstances, carbon is not regulated (SEE ALSO: 261.24 and 261.31: F032).
	02/04/1986	REGULATORY STATUS OF PHOTOGRAPHIC FILMS AND PAPERS UNDER RCRA SUBTITLE C	Memo
	Description: Photo film and paper are not listed hazardous waste (HW). They are HW if characteristic. Data suggest they are usually not toxic by the extraction procedure (EP) (SUPERSEDED: See 261.24). The generator must make the determination. Even if not contaminated, used photo film and paper removed from service to recycle are spent materials. Unless characteristic, spent material status irrelevant.
	01/07/1986	EXCLUSION FROM REGULATION FOR CHARACTERISTIC AND LISTED WASTES - LEACHATE LEVELS; DELISTING CRITERIA/LEACHATE LEVELS	Memo
	Description: There is delisting criteria for variable constituent levels depending on waste volume. For delisting, EPA considers the original listing constituents and other factors. A mixture of solid waste (SW) and hazardous waste (HW) listed solely for a characteristic is not HW if not characteristic under the 261.3(a)(2)(iii) mixture rule exemption for wastes listed solely for exhibiting a characteristic (SEE ALSO: 268.3; 66 FR 27266; 5/16/01). The leachate test used depends on the nature of the waste. Discussion of the use of extraction procedure (EP) for Oily Waste (SUPERSEDED: See 261.24).
	01/06/1986	RECYCLING OF MOLDING AND CASTING SANDS	Memo
	Description: Foundry sands are spent materials and are solid wastes when reclaimed (SEE ALSO: RPC# 3/28/2001-01). Foundry sands are hazardous wastes if they exhibit the toxicity characteristic for lead. Once regenerated or reclaimed, foundry sands are not solid wastes and are exempt even if shipped off-site for coating before use. The reclamation process is exempt. The storage and transportation of spent material before reclamation is subject to regulation.
	12/01/1985	USED OIL AS DUST SUPPRESSANT	Question & Answer
	Description: Used oil that exhibits a characteristic of extraction procedure (EP) toxicity (SUPERSEDED: See 261.24) can be used as a dust suppressant provided it has not been mixed with hazardous waste (SUPERSEDED: See RPC# 3/1/90-05 and 279.82).
	10/21/1985	EP TOXICITY TEST EXTRACTION MEDIUM, REQUESTED CHANGE IN	Memo
	Description: The extraction medium in the extraction procedure (EP) (SUPERSEDED: see 261.24) may not be appropriate for determining the hazardousness of oil shale. A listing process may be used if the data indicates a sufficient threat.
	10/03/1985	APPROPRIATENESS OF THE EP/TCLP SIMULATION OF CO-DISPOSAL SITUATION FOR MINING WASTES; CHARACTERISTIC TESTS FOR DETERMINING THE HAZARDOUS CHARACTERISTICS OF MINING WASTES	Memo
	Description: There is no determination on the appropriate tests used to identify mining or Bevill exempt mining and mineral processing wastes to be regulated as hazardous waste. TCLP is designed to simulate the leachability of industrial waste that is co-disposed with sanitary waste. Although the disposal scenario may be incompatible with mining waste disposal, similar generation of acids warrants TCLP or stronger. Mining wastes generate acidic leachate upon exposure to air.
	09/24/1985	REGULATORY STATUS OF CREOSOTE-TREATED RAILROAD TIES	Memo
	Description: Creosote-treated railroad ties are not listed and are unlikely to exhibit any characteristic. FIFRA may place controls on handling and disposal.
	09/01/1985	EP TOXICITY FOR OILY WASTES	Question & Answer
	Description: Method 1330 “Oily Waste Extraction Procedure” should only be used when requested by EPA for delisting purposes. Method 1330 cannot be used in waste identification as a substitute for the extraction procedure (EP) (SUPERSEDED: See 261.24) when analyzing oily wastes.
	07/16/1985	CREOSOTE TREATED CROSS TIES, DISPOSAL OF, FIFRA INTERFACE	Memo
	Description: Creosote-treated railroad cross ties are not likely characteristic. FIFRA may place controls on their handling and disposal. U051 creosote and K001 and K035 do not apply to treated cross ties destined for disposal.
	07/01/1985	EP TOXICITY CHARACTERISTIC AMENDMENTS	Question & Answer
	Description: A discussion of draft TCLP. TCLP will be suitable for determining the mobility of organic and inorganic compounds present in liquid, solid, and multiphase wastes.
	05/31/1985	EMPTY DRUMS CONTAINING METALLIC NICKEL OR NICKEL OXIDE	Memo
	Description: Metallic nickel and nickel oxide are not listed or characteristic compounds. Drums that contained these compounds are not hazardous.
	05/15/1985	BATTERIES, WASTE ELECTROLYTE FROM RECHARGEABLE NICKEL-CADMIUM	Memo
	Description: Disposal of a spent nickle-cadmium battery (batteries) potassium hydroxide electrolyte into a sewer is excluded. The spent electrolyte may be corrosive (D002) or toxic.
	03/04/1985	DIOXIN IN WASTES FROM WOOD PRESERVING PROCESSES USING PENTACHLOROPHENOL	Memo
	Description: F-listed dioxin wastes are rarely generated at wood preserving facilities, although if wood preserving facility makes chlorophenolic formulations or discards unused chlorophenolic formulations, they would generate F-listed dioxin wastes. EPA may amend K001 to address chlorinated dioxins and furans (see also: 261.31: F032-F035). F021 and F027 are listed for acute toxicity (H), while F028 is listed as a toxic waste (T).
	01/01/1985	SOIL CONTAMINATED WITH CHLORDANE	Question & Answer
	Description: Soil contaminated with chlordane would only meet the U036 listing if the chlordane is spilled or discarded prior to use. The soil is hazardous if it exhibits a characteristic.
	12/18/1984	DELISTING TESTING REQUIREMENTS, CYANIDE AND OTHER WASTES, STEEL INDUSTRY	Memo
	Description: The EP (extraction procedure) toxicity test is not applicable to wastes with greater than 1 percent oil and grease. Delisting petitions must test photodegradable cyanide when total (complexed) cyanide exceeds 10 ppm (SEE ALSO: current 261.24).
	12/11/1984	ELECTROPLATING SLUDGE, EXCLUSION PETITION	Memo
	Description: For delistings of an electroplating sludge, total, free (amenable to chlorination), leachable, and photodegradable cyanides must be analyzed. Total and free cyanides are analyzed using Method 9010. Leachable cyanides are analyzed using the extraction procedure (EP) toxicity test (SUPERSEDED: See 261.24). Photodegradable cyanides are analyzed using Method 9011.
	09/01/1984	PRECIOUS METAL ELECTROPLATING SLUDGE	Question & Answer
	Description: Sludge from precious metal electroplating is not F008 (SUPERSEDED: see 261.31, 50 FR 614; 1/4/85).
	08/01/1984	LANDFILLS WITH EP TOXIC LEACHATE, REGULATION OF	Question & Answer
	Description: Once leachate is collected, subsequent management is regulated if the leachate is a hazardous waste. If extraction procedure (EP) (SUPERSEDED: see 261.24) toxic leachate collected from a sanitary landfill is pumped back into the landfill, the landfill is subject to TSDF requirements (SUPERSEDED: see 258.28(a)(2)).
	07/01/1984	EP TOXICITY TEST ON OILY WASTES	Question & Answer
	Description: Conducting the extraction procedure (EP) toxicity test (SUPERSEDED: see 261.24) on oily wastes that do not pass through the filter is outlined.
	05/25/1984	ANALYTICAL METHODS FOR PETROLEUM REFINING RESIDUES AND WASTES	Memo
	Description: Guidance is provided on the analytical methods for petroleum refinery wastes that are the subject of a land treatment permit application (cover letter for “Handbook for the Analysis of Petroleum Refinery Residues and Waste”). A land treatment permit application should include total metal concentrations, not extraction procedure (EP) results.
	04/30/1984	TOXICITY OF 2,4,D WASTE	Memo
	Description: Inclusion of 2,4,-D in the toxicity characteristic and the U-list is based on the National Interim Primary Drinking Water Standards (NIPDWS) evaluation. Toxicity information for 2,4,-D is outlined.
	04/23/1984	RCRA METHODS AND QUALITY ASSURANCE ACTIVITIES (NOTES)	Memo
	Description: The spot-check program to collect samples to verify delisting petition data is discussed. A recommendation that audit cylinders containing organic compounds be used during all source measurement programs is provided. Problems with spike recovery for metals in Method 3030 - Acid Digestion of Oils, Greases, and Waxes and pH adjustment for the extraction procedure (EP) are outlined. Materials that do not pass through 0.45 um filter are solids and must be extracted. The pH of oil and grease is discussed. It is impossible to determine the pH of non-aqueous materials. Unless specifically stated in the method, results are to be reported “as received,” and a sample is not dried before analysis.
	04/04/1984	ANALYTICAL METHODS/EP TOXICITY TEST/REFERENCE STDS.	Memo
	Description: The adjustment of pH during the extraction procedure (EP) toxicity test should be conducted with a pH meter, not pH paper (SUPERSEDED: see current 261.24). Extract digestion, testing manufactured articles that are structurally resistant to crushing, and methods evaluation are discussed. EPA is developing methods for ignitable (D001) solids (SEE ALSO: SW-846 method 1030 finalized in 6/13/97; 62 FR 32451), liquids with flash points less than 60 degrees C, and reactive gases - cyanide and sulfide. EPA is developing a “Waste Analysis Plans Guidance Manual.” The use of reference standards is discussed.
	07/27/1983	WASTE BATTERIES AND CELLS	Memo
	Description: Waste batteries that are resistant to corrosion may be tested for the extraction procedure (EP) (SUPERSEDED: See 261.24) toxicity characteristic without particle reduction. Addresses the saltwater test to measure the corrosion resistance of a product (battery casing).
	07/01/1983	MANUFACTURED ARTICLES TEST FOR EP TOXICITY	Question & Answer
	Description: Manufactured articles are tested using the extraction procedure (EP) (SUPERSEDED: see 261.24) by reducing the size of the representative sample to pieces which can pass through a 9.5 mm sieve, then performing the extraction step. Corrosion-resistant batteries (battery) do not have to be reduced in size prior to testing. Provides guidance on determining corrosion-resistance.
	06/17/1981	EXTRACTION PROCEDURE TOXICITY TEST	Memo
	Description: An acceptable extractor for the extraction procedure (EP) will impart sufficient agitation to the mixture to not only prevent stratification of the sample and extraction fluid, but also insure that all sample surfaces are continuously brought into contact with the well-mixed extraction fluid.
	05/29/1981	REGULATION OF DRYING BED SOLIDS	Memo
	Description: Denial of petition to block applicability of extraction procedure (EP) (SUPERSEDED: See 261.24) to drying bed solids since these wastes could leach hazardous levels of cadmium and lead to groundwater if mismanaged.
Transporters
Treatment
TSDFs
U-wastes
Underground Storage Tanks (UST)
Universal Waste
Used Oil
Variances
Waste Determinations for Combusted Non-Hazardous Secondary Materials
Waste Minimization
Waste Piles
Waste Reduction
Wood Preserving Wastes
(Not Categorized)

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