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12/04/2001CRUISE SHIP IDENTIFICATION NUMBERS AND STATE REQUIRED ANNUAL REPORTING COMPONENTSMemo
 Description: Individual cruise ships should be assigned only one EPA hazardous waste identification number as a generator of hazardous waste for the purposes of RCRA. A cruise ship should determine its American-based home port state, which is the state in which it has corporate offices or its main port of call. The cruise ship should notify the selected state or appropriate EPA regional office of its hazardous waste activities and determine its generator size in accordance with 261.5(c). The home port state or region will issue a hazardous waste identification number. EPA recommends issuing ID numbers based on a ship's International Maritime Organization (IMO) number. Assigned ID numbers will remain with the ship and should be used on all hazardous waste manifests. State assigned numbers will not impact the applicability of state-specific RCRA requirements in other states.
 
01/01/2001Environmental Fact Sheet: Hazardous Waste Manifest System to be StreamlinedPublication
 Description: This factsheet describes how EPA proposes to improve the Uniform Hazardous Waste Manifest system by automating procedures and standardizing the manifest form. Waste handlers could realize savings between $24-37 million a year, and states could save 25% in manifest-related costs while ensuring the continuous, safe management of hazardous waste.
 
02/16/2000BROKER AS INTERMEDIARY ARRANGING FOR EXPORTMemo
 Description: It is acceptable for persons who hold Acknowledgement of Consent to be different from generator identified on manifest. Intent of Acknowledgement of Consent is to ensure that importing country is aware of proposed transboundary movement and has consented to such movement.
 
06/01/1999TRACKING REQUIREMENTS FOR USED OILQuestion & Answer
 Description: A hazardous waste manifest does not need to accompany each shipment of used oil. Used oil transporters, burners, processors/re-refiners, and marketers must maintain records documenting the acceptance and delivery of each used oil shipment. The tracking record need not physically accompany each used oil shipment.
 
08/07/1998INTERPRETATION REGARDING THE TRANSFER OF DRUMS AMONG TRANSPORTATION VEHICLES AT TRANSFER FACILITIESMemo
 Description: If a shipment of hazardous waste appearing on a single manifest must be divided by the transporter and split between outbound shipments, the transporter must obtain consent from the generator to amend the original manifest to show the correct information (i.e., number of drums and waste descriptions) for the first truck and complete a second manifest to indicate the correct information for the second truck. The transporter should note on the first manifest the manifest number for the second manifest. Additional requirements may apply if the transporter combines waste from different containers.
 
04/27/1998REPORTING WASTEWATERS MANAGED IN RCRA-EXEMPT UNITS ON THE 1997 HAZARDOUS WASTE REPORTMemo
 Description: EPA considered dropping the reporting requirement for wastewaters on the 1997 Hazardous Waste (Biennial) Report. Based on concerns raised by data users, EPA decided not to change the requirement that hazardous wastes going to RCRA-exempt units be reported (NOTE: See 2001 Biennial Report Forms for current requirements). EPA did change the system type code in an effort to simplify the reporting. EPA does not plan to overrule state or regional guidance which may have contradicted this policy. Reporting for wood preserving wastewaters may be affected by the conditional exclusion added by the land disposal restrictions (LDR) Phase IV rulemaking .
 
02/01/1998DEFINITION OF TRANSPORTER AND TRANSPORTER SIGNATURE ON MANIFESTQuestion & Answer
 Description: When waste shipments are exchanged among drivers of the same transport company, the generator is not required to identify those individuals as multiple transporters on the manifest. The signature and EPA ID number of a second transporter is required only when a second transport company, with its own EPA ID number, takes possession of the waste.
 
01/20/1998DEFINITION OF SOLID WASTE TASK FORCE RECOMMENDATIONSMemo
 Description: The Definition of Solid Waste Task Force recommendation for a new recyclable materials manifest may be addressed in the hazardous waste manifest regulations now under development. The Task Force recommendation is not a formal Agency position and does not necessarily reflect all the perspectives that would determine an EPA position. EPA has decided that further data will be needed to proceed with the redefinition of solid waste rulemaking.
 
05/30/1997TRANSPORTATION OF LEAD-ACID BATTERY COMPONENTS THAT ARE SHIPPED OFF-SITE FOR RECLAMATIONMemo
 Description: A facility shipping lead-acid battery plates would not be exempt from preparing a manifest under Part 266, Subpart G. Only the management of intact spent batteries prior to reclamation is exempt. Unmanifested waste reports (UWR) are not intended to be routinely submitted as an alternative to compliance with the manifest system. UWRs are designed to detect suspicious patterns of unusually high incidences of unmanifested wastes.
 
05/29/1997PETITION TO ADD WASTES TO THE UNIVERSAL WASTE PROGRAMMemo
 Description: EPA has no plans to address Utility Solid Waste Activities Group’s (USWAG) petitions to add mercury-containing equipment, paint, and paint-related wastes to the universal waste (UW) rule in 1997. The universal waste rule explicitly provides flexibility for states to add other waste categories to their approved state program. EPA established the workgroup to reduce the burden of the current manifest system. The workgroup’s proposal to allow generators to consolidate waste at central locations would cover utility access residuals.
 
03/05/1997APPROVALS FOR CONTINUATION OF RCRA HAZARDOUS WASTE REPORTING AND RECORDKEEPINGMemo
 Description: Discusses the list of information collection activities recently approved for continuation by the Office of Management and Budget (OMB) (e.g., 8700-22 manifest, 8700-12 notification form, 8700-13A and 8700-13B Biennial Report, 8700-23 Part A permit application). The manifest renewal expires September 30, 1999. The old manifest can be used if the old expiration date is crossed out and the form contains OMB control number 2050-0039. Changes to DOT materials shipping papers affect the manifest. Memo includes approval and expiration dates for each form as well as the extent of the revisions, and discussion of information collection activities which do not require form (e.g., Part B permit application, general hazardous waste facility standards, waste specific unit requirements and special waste processes and types).
 
02/18/1997ANNOUNCEMENT OF AUTOMATION PILOT TESTS FOR THE HAZARDOUS WASTE MANIFESTMemo
 Description: EPA announces sponsorship of several pilot tests aimed at demonstrating the feasibility of automating the hazardous waste manifest. Two distinct pilot tests will be conducted. A standards-based approach using electronic data interchange (EDI), and a smart-form test that will allow facilities to complete and transmit manifests via the Internet. Participants will have to maintain a manual manifest system while conducting the pilot tests.
 
02/13/1997UNIVERSAL WASTE QUESTIONS AND ANSWERS DOCUMENTMemo
 Description: Presents a Universal Waste Questions and Answers Document. Addresses state authorization. Discusses the addition of wastes to the federal and state universal waste (UW) programs, fluorescent lamps (SEE ALSO: 64 FR 36466; 7/6/99), land disposal restrictions (LDR) recordkeeping requirements, the Mercury-Containing and Rechargeable Battery Management Act, batteries, pesticide collection programs, liability and enforcement, storage limits, mixtures of UW and hazardous waste, and manifesting.
 
11/12/1996USE OF AUTOMATED INFORMATION TECHNOLOGIES IN THE HAZARDOUS WASTE MANIFEST SYSTEMMemo
 Description: An electronic record system may comply with current requirements for the use and retention of the manifest. The system should include manifest image files with original handwritten signatures, controls to ensure record accuracy, integrity and security, and retrieval features that allow for reasonable access during inspections. The company must verify that their automated system complies with applicable state manifest retention regulations.
 
09/26/1996FINAL RESPONSE FROM OSWER TO OIG AUDIT REPORT ON GENERATOR REQUIREMENTSMemo
 Description: Provides final response from the Office of Solid Waste and Emergency Response (OSWER) to Office of Inspector General audit report on generator requirements for manifesting, notification, and hazardous waste determination using process knowledge.
 
09/01/1996TOLLING AGREEMENTS AND EXPORTSQuestion & Answer
 Description: Export standards apply only to primary exporters of waste. The primary exporter is an exporter that requires a manifest. Small quantity generators (SQGs) with contractual reclamation agreements do not require a manifest. SQGs shipping waste under a reclamation agreement are not subject to export requirements because they are not a primary exporter.
 
06/19/1996CLARIFICATION OF TWO SECTIONS OF THE HAZARDOUS WASTE REGULATIONS: WASTE CHARACTERIZATION IN 40 CFR 262.11 AND LDR NOTIFICATIONMemo
 Description: EPA does not require waste codes on the manifest, but states may require one or more waste codes to be identified. RCRA waste codes may be part of the proper DOT shipping description. When a waste meets a specific listing and exhibits a characteristic for one of the constituents that make up the listed waste code, the generator may decide which waste code to include on the manifest based on which waste code most accurately identifies the waste for emergency response purposes.
 
06/01/1996HAZARDOUS WASTE LIQUID-CONTAINING PUMPS AND THE LIQUIDS IN LANDFILLS PROHIBITIONQuestion & Answer
 Description: Owners and operators have three options for disposing of containerized liquids in landfills: remove liquid, add sorbent or solidify, or eliminate by other means. There is no requirement to dismantle pumps containing free liquids prior to disposal in a landfill under the liquid in landfill prohibition. There is no requirement to remove or sorb free liquids in containers such as pumps holding liquids for use other than storage.
 
06/01/1996TANK STORAGE AT TRANSFER FACILITIESQuestion & Answer
 Description: A transporter may not store hazardous waste in stationary tanks at a transfer facility without a permit or interim status. Hazardous wastes at transfer facilities must be manifested, stored in containers meeting DOT requirements, and be held 10 days or less. Discussed the definition of container.
 
05/01/1996INTERPRETATION OF GENERATOR REQUIREMENTS AS APPLIED TO VARIOUS ON-SITE AND OFF-SITE SCENARIOSMemo
 Description: Provides a clarification of the terms on-site, facility, installation, and individual generation site. Contiguous properties owned by different persons require separate identification numbers. Manifests are required for all off-site shipments of waste, even if both properties belong to the same generator (SUPERSEDED: manifest exemption for shipments along the border of contiguous properties; 62 FR 6622; 2/12/97). No manifest is required to ship hazardous waste between two properties under the same ownership that are located at opposite corners of an intersection. Large quantity generator (LQG) and small quantity generator (SQG) waste must be sent to a designated facility. No final interpretation exists on whether conditionally exempt small quantity generator (CESQG) waste sent to an intermediate location for consolidation loses its exemption. Waste in transportation may be consolidated at transfer facilities. The emergency response exemption from permitting applies to immediate response only. Hazardous waste generated as the result of discharge may be accumulated for 90 days under Section 262.34.
 
04/08/1996DEFINITION OF TRANSPORTERMemo
 Description: When one company owns or operates the means of locomotion of a vehicle and a different company owns or operates the cargo-containing transport vehicle (e.g., railroad car or truck trailer), both parties are potentially subject to transporter requirements (i.e., both meet the definition of transporter). EPA recommends identifying on the manifest only the transporter company that is primarily responsible for the movement of waste during that transportation segment. The company primarily responsible will be the one performing the transporter functions, such as signing and dating the manifest received from the generator.
 
04/01/1996FREQUENTLY ASKED QUESTIONS ON HAZARDOUS WASTE GENERATOR REQUIREMENTSQuestion & Answer
 Description: Large quantity generators (LQGs) and small quantity generators (SQGs) may treat without a permit or interim status under Section 262.34. SQGs are not subject to Biennial Report requirements. Conditionally exempt small quantity generators (CESQG) regulations are found in Section 261.5. EPA does not require waste codes on the manifest but DOT regulations may. States may require waste codes to be listed on the manifest.
 
03/07/1996FEDERAL POLICY ON SEVERAL ISSUES RELATED TO THE USE OF THE HAZARDOUS WASTE MANIFEST BY HAZARDOUS WASTE TRANSPORTERSMemo
 Description: The transporter block on the manifest is used to identify companies that transport waste. Transfer facilities do not need to be identified on the manifest unless the owner of the transfer facility takes custody of the waste as a new transporter. Brokers, transporters, or TSDFs may be an importer and therefore subject to generator requirements. One party should assume the generator responsibilities. Discusses the procedures for handling rejected shipments of hazardous waste exported to Canada.
 
03/06/1996NAMemo
 Description: Proivdes background on the stakeholders meetings for revising the current manifest system. EPA's goal is to reduce regulatory paperwork burden by 25 percent. EPA envisions a tracking form that will be significantly reduced from the current manifest in required data elements and copy requirements. EPA also will examine the role of automated systems for tracking forms.
 
03/01/1996GENERATORS AND DESIGNATED TRANSPORTERSQuestion & Answer
 Description: A transporter must seek approval of the generator to change the chain of transportation on the manifest. The generator must designate all transporters on the manifest. The generator alone is responsible for a complete chain of transportation on the manifest.
 
02/05/1996UNIVERSAL WASTE NOTIFICATION REQUIREMENTSMemo
 Description: Large quantity handlers of universal waste (LQHUW) may fulfill the notification requirement by sending a one-time written notification or submitting an 8700-12 form. There is no national requirement to track this information in RCRIS (NOTE: RCRIS data was replaced by RCRAinfo data in Summer, 2000).
 
09/14/1995CLARIFICATION OF CIRCUMSTANCES INITIATING EPA'S ""MANIFEST DISCREPANCY"" PROCEDURESMemo
 Description: The manifest discrepancy regulations do not apply to waste which loses the corrosivity characteristic during transit (transportation). The manifest discrepancy regulations are intended for situations where the quantity of waste is unaccounted for. The manifest is not a certification that shipped waste is indeed hazardous. A generator can apply knowledge conservatively, rather than incur the costs of testing each waste batch or stream.
 
08/22/1995EPA'S CURRENT INTERPRETATION OF THE REQUIREMENTS IN 40 CFR SECTION 262.12 REGARDING EPA ID NUMBERSMemo
 Description: Two autonomous divisions of the same company operating on an individual generation site are not separate generators. EPA expects each site to have one ID number. Requests for multiple ID numbers for one site are evaluated on a case-by-case by the Region or State implementing agency.
 
06/01/1995RCRA WASTE MINIMIZATION REQUIREMENTSQuestion & Answer
 Description: Discusses waste minimization requirements for generators and treatment, storage, and disposal facilities (TSDFs). Large quantity generators (LQGs) and TSDFs are required to certify they have a program in place. LQGs are required to describe their waste minimization efforts in the biennial report (Sections 3002(a)(6), 3002(b), and 3005(h)) (SUPERSEDED: no longer required on biennial report, see 1997 Hazardous Waste Report Instructions). Small quantity generators (SQGs) must certify a good faith effort on the manifest.
 
03/01/1995SIGNING THE MANIFEST AS AN AGENT WHEN IMPORTING HAZARDOUS WASTEQuestion & Answer
 Description: An agent signing the manifest must be legally affiliated with the EPA ID number on the manifest. Foreign brokers can sign the manifest if they have an EPA ID number (requiring U.S. address) or are legally related to the importer (e.g., a subsidiary).
 
02/17/1995DO VESSELS TRANSPORTING A RCRA REGULATED HAZARDOUS WASTE REQUIRE AN EPA ID NUMBER FOR TRANSPORT BETWEEN THE U.S. AND BELGIUM?Memo
 Description: An EPA ID number is not required for a vessel once a waste shipment is outside U.S. jurisdiction.
 
12/13/1994RESPONSE TO COMMENTS ON REENGINEERING RCRA FOR RECYCLINGMemo
 Description: Issues before the Definition of Solid Waste Task Force concerning the hazardous recyclable materials manifest are discussed.
 
12/01/1994NOTIFICATION REQUIREMENTS FOR EXPORTED WASTESQuestion & Answer
 Description: Export regulations apply only to hazardous wastes that are subject to manifest requirements. Generators of wastes which are nonhazardous in the U.S. but hazardous in the exporting country do not need to notify EPA of the export.
 
11/09/1994RESPONSE TO A REQUEST FOR MODIFICATION OF 40 CFR PART 262 REGARDING TRANSPORTATION OF RECYCLABLE HAZARDOUS WASTESMemo
 Description: EPA is considering new regulations for tracking hazardous wastes destined for recycling since the Definition of Solid Waste Task Force identified high transportation costs for transporters using the Uniform Hazardous Waste Manifest.
 
11/04/1994RCRA REGULATION OF UNIVERSITY LABORATORIESMemo
 Description: University buildings separated by city blocks or divided by public roads are individual generation sites, each requiring separate EPA ID numbers and manifests for the exchange of hazardous waste (SUPERSEDED: manifest exemption for shipments along the border of contiguous properties; 62 FR 6622; 2/12/97). If access between buildings is possible without traveling along a public road, the university is one site, and only one EPA ID number is needed.
 
10/05/1994INTERPRETATION REGARDING THE REGULATORY STATUS OF SILVER RECOVERY UNITS UNDER RCRA REGULATIONSMemo
 Description: If a silver recovery unit that is used to treat wastewater qualifies as a characteristic sludge, it is not a solid waste when destined for reclamation. Materials generated from wastewater treatment are sludges, even if the treatment is not undertaken to meet any discharge requirements. Metals suitable for direct reuse, or that only need minor refining to be usable, are products (e.g., silver flake that is 98% pure refined to 99.99% pure).
 
09/28/1994CLARIFICATION ON: MANIFEST DOCUMENT NUMBER; F003, F005, D001; WASTE DESTINED FOR RECYCLING; AND TREATMENT STANDARDS FOR CFCMemo
 Description: F003 and F005 waste exhibiting ignitability must carry a notification for and meet the D001 treatment standard (TS), since F003/F005 does not operate in lieu of D001 (SEE ALSO: 55 FR 22520, 22530; 6/1/90) (USE WITH CAUTION: see RPC# 3/1/94-02). The TS for chlorinated fluorocarbons (CFC) is discussed. A CFC waste may be subject to the California list prohibition for halogenated organic compounds (HOC) (SUPERSEDED: California list removed, see 62 FR 25997; 5/12/97) (SEE ALSO: RPC# 5/16/91-01). Materials that are not a solid waste (SW) when recycled are exempt even if shipped to a recycler via a TSDF. Scrap metal is both a SW and is hazardous, but is exempt if recycled. The legitimacy of recycling must be documented. Use of manifest continuation sheets is outlined.
 
08/09/1994COMMENTS ON STRAWMAN PROPOSAL REGARDING CUSTOMS MODERNIZATION ACTMemo
 Description: All imports and exports of hazardous waste arriving at a Customs port must be accompanied by a hazardous waste manifest. EPA Acknowledgement of Consent must accompany hazardous waste exports. Under a Memorandum of Understanding (MOU) between EPA and the U.S. Customs Service, the U.S. Customs Service collects the manifest from the exporter and transmits it to EPA.
 
07/22/1994REGULATION OF SURFACE IMPOUNDMENTS UNDER THE SEPTEMBER 10, 1992 RECYCLED USED OIL MANAGEMENT STANDARDSMemo
 Description: The de minimis used oil exemption does not apply to used oil intentionally introduced into a wastewater treatment system. Surface impoundments managing used oil must operate under RCRA Subtitle C permits or interim status.
 
07/21/1994CLARIFICATION: IS A FACILITY THAT HAS A ""PRIMARY PURPOSE"" OF BURNING HAZARDOUS WASTE FOR DESTRUCTION SUBJECT TO RCRA REGULATIONS?Memo
 Description: Solid waste includes materials that are abandoned by being burned or incinerated. Discusses the history of the incinerator and BIF rules. The BIF rules apply even to BIFs burning hazardous waste (HW) for destruction. A facility with the “primary purpose” of burning HW for destruction is an incinerator. A test to determine whether a device is a BIF is in definition at Section 260.10. The revenue of a facility for treatment versus recycling is not sole factor in identifying the unit, but is factor in determining whether the activity is destruction, or legitimate or sham recycling. Delisting is not a prerequisite to use the Section 266.20 use in manner constituting disposal exemption. Section 266.20 only applies to to legitimate products derived from hazardous waste, not to hazardous waste residues that are merely claimed to be products. HSWA requires that facilities should conduct proper hazardous waste management in order to protect the environment and to achieve the ultimate goals of waste minimization and the reduction of land disposal.
 
07/18/1994WASTE MINIMIZATION REQUIREMENTS OF SECTION 3002(B) OF RCRA FOR HAZARDOUS WASTE DISPOSAL FACILITIESMemo
 Description: The 3005(h) waste minimization and certification requirements apply to an owner of a landfill that generates and has a RCRA Subtitle C treatment permit for F039 leachate. If the owner is a large quantity generator (LQG) and sends the waste off-site, the owner is also subject to the 3002(b) waste minimization requirements. There is no statutory exemption from waste minimization certification for facilities generating remedial waste.
 
06/23/1994ON-SITE TREATMENT OF MANHOLE SEDIMENT WHICH MAY EXCEED THE TOXICITY CHARACTERISTIC FOR LEADMemo
 Description: A material must exceed a 60 mm particle size to meet the debris definition. Debris stabilization with lime, fly ash, or portland cement is considered microencapsulation or immobilization and must be disposed of in hazardous waste landfill if characteristic, or may be disposed of in nonhazardous landfill if not characteristic. Nonhazardous disposal is subject to Section 268.9 for land disposal restrictions (LDR) notification, but not the hazardous waste manifest.
 
06/21/1994USE OF MULTIPLE TRANSFER FACILITIES AS PART OF THE ""NORMAL COURSE OF TRANSPORTATION""Memo
 Description: Regulations do not specifically prohibit the use of multiple transfer facilities during the normal course of transportation. To be considered in the normal course, transportation should be completed in a timely manner. The normal course of transportation is decided on a case-by-case basis. A transporter remains responsible for the waste and the Part 263 standards while at a transfer facility. A generator must receive signed copies of manifests within the specified time periods or must file an exception report.
 
05/09/1994RECORDKEEPING REQUIREMENTS FOR SMALL QUANTITY GENERATORS SUBJECT TO LAND DISPOSAL RESTRICTIONSMemo
 Description: Small quantity generators are subject to the land disposal restrictions (LDR) program. Only CESQGs are exempt from Part 268. The manifest does not address all of the information required to comply with the Part 268 notification requirements.
 
04/01/1994DESIGNATING EXEMPT RECYCLING FACILITIES ON THE MANIFESTQuestion & Answer
 Description: Permit-exempt recycling facilities can be a designated facilities on a manifest. Exempt recycling facility must obtain an EPA identification number and comply with manifest requirements.
 
03/22/1994REQUIREMENTS FOR MANIFESTING SHIPMENTS OF HAZARDOUS WASTE BY RAIL FROM CANADAMemo
 Description: RCRA Subtitle C regulations can only apply to U.S. parties. The U.S. importer, importer's agent, and transporter may all be generators. All generators are jointly and severally liable for compliance with the generator requirements. Rail shipments of hazardous waste need not be accompanied by a manifest. A generator of waste that is transported solely by rail forwards copies of the manifest directly to the designated facility.
 
03/04/1994USING A GENERATOR IDENTIFICATION NUMBER AND/OR MANIFEST TO DETERMINE LIABILITYMemo
 Description: The presence of an EPA ID number on the manifest is not the decisive factor in assessing liability. Cogenerators of waste are all potentially liable. While a second EPA ID number can be placed on the manifest to designate cogenerators, this is not required. There is no national policy on the issuance of EPA ID numbers for waste generated on ships.
 
09/20/1993TRANSPORTING WASTES FROM CONDITIONALLY EXEMPT SMALL QUANTITY GENERATORSMemo
 Description: CESQGs may send waste to a facility that beneficially uses or reuses, or legitimately recycles or reclaims waste. CESQG waste does not need to be accompanied by a manifest.
 
07/15/1993COMMENTS ON DRAFT MEMO OF ORDER BETWEEN EPA AND THE U. S. GOVERNMENT SERVICEMemo
 Description: Addresses the Memorandum of Understanding (MOU) between EPA and U.S. Customs. Importers or transporters are not obligated to submit manifests to U.S. Customs at the border.
 
04/29/1993CLARIFICATION OF HOW MANIFEST AND BIENNIAL REPORTING APPLIES TO MIXTURES OF HAZARDOUS WASTEMemo
 Description: EPA does not require generators to list hazardous waste codes on the manifest, nor do they have to complete Section J of the manifest. 262.20 establishes the procedure that generators must follow in obtaining the manifest. The content of the biennial report is contingent upon the hazardous waste that is generated by the reporter during the reporting year, not on the waste codes that may be listed on the manifest.
 
10/28/1992REGULATORY REQUIREMENTS PERTAINING TO THE MANAGEMENT OF WASTE SOLVENTS AND USED OILMemo
 Description: A generators may make a hazardous waste determination either by testing or by applying knowledge of the characteristics of the waste, in light of materials or process used in its generation; testing is not required. A generator must determine each waste code applicable to waste. A generator can rely on the analysis of unused mineral spirits plus knowledge of the operation to determine whether or not the resulting waste solvent exhibits any hazardous characteristic, provided he has sufficient information to make an accurate determination.
 
09/09/1992NOTIFICATION REQUIREMENTS FOR TREATABILITY STUDIESMemo
 Description: Addresses the reporting, notification, and recordkeeping requirements for treatability studies. 261.4(f)(1) requires a one-time notification of treatability study activities.
 
10/17/1991EXTENSION DATE FOR THE UNIFORM HAZARDOUS WASTE MANIFESTMemo
 Description: A manifest with a 9/30/91 expiration date may be used through 9/30/92. Cross out the printed 1991 expiration date and replace it with the new 1992 expiration date (SUPERSEDED: manifest extended to 9/30/99 by 61 FR 54998; 10/23/96).
 
09/27/1991DESIGNATED FACILITY UNDER THE TREATABILITY STUDY EXCLUSIONMemo
 Description: The designated facility definition allows the shipment of waste from a state where it is hazardous to a state where it is not hazardous. The manifest requirements should be followed as required by the originating state. Discusses the applicability to shipment of excluded treatability study samples from states where it is not excluded.
 
07/01/1991TRUCK TRANSPORT OF WASTEWATER FOR PURPOSES OF SECTION 261.3(A)(2)(IV)(A)Question & Answer
 Description: A solvent-wastewater mixture transported to a wastewater treatment unit (WWTU) by truck qualifies for the Section 261.3(a)(2)(iv) exemption provided the WWTU is subject to Sections 402 or 307(b) of CWA, and the wastewater meets the de minimis levels specified in Section 261.3(a)(2)(iv).
 
03/19/1991REGULATORY STATUS OF ELEMENTAL MERCURY RECYCLINGMemo
 Description: Used mercury that is 99% pure is considered product rather than solid waste because it is pure enough to require only minor refining, rather than substantial reclamation, in order to be usable.
 
03/13/1991SMALL QUANTITY GENERATOR (SQG) REQUIREMENTS AND LIABILITIESMemo
 Description: If a generator receives the return copy of the manifest with the required signatures (generator, transporter, TSDF) and maintains proper records, the generator should be in compliance with RCRA Subtitle C even if the waste is subsequently remanifested and sent by the TSDF to another facility for further treatment. A generator retains potential liability under CERCLA for future mismanagement.
 
03/01/1991AMENDMENTS TO PART 262 HAZARDOUS WASTE DETERMINATION AND RECORDKEEPING REQUIREMENTS OF PART 262 AND 268Question & Answer
 Description: The Section 262.11(c) requirement for generators to evaluate listed waste for characteristics applies to land disposal restrictions (LDR) paperwork only, and does not affect generator paperwork such as the manifest or the biennial report. If waste is both listed and characteristic, then the LDR standards for the listing operate in lieu of the characteristic standards, unless the listing does not address the characteristic or is not in effect (i.e., under a variance).
 
02/05/1991EXPORT OF HAZARDOUS WASTES UTILIZED FOR PRECIOUS METALS RECLAMATIONMemo
 Description: Part 266, Subpart F precious metals that are exported for reclamation are also subject to Part 262 export requirements. The export requirements apply to wastes that require a manifest.
 
12/03/1990SHIPS AS GENERATORS AND EPA IDENTIFICATION NUMBERSMemo
 Description: The Navy and a contractor generating hazardous waste on a ship are cogenerators and can mutually pick who assumes generator responsibilities. Cogenerators operating at the same site normally use that site’s EPA ID number for the manifest. A generator may use an "internal" tracking number to identify the contractor generating hazardous waste. Normally, there should only be one EPA ID number per site. Regions can make their own determinations on assigning EPA ID numbers to port facilities.
 
10/30/1990TRANSFER FACILITY REGULATION INTERPRETATIONMemo
 Description: A transportation company has one ID number. All company trucks are assigned the same number. Transporters may consolidate hazardous waste (HW) shipments at a transfer facility. They must indicate the new composition and re-manifest the waste to the original designated facility. A TSDF can be a transfer facility if it is not already the designated facility. Waste is in the custody of the last transporter that signed the manifest until the designated facility or the next transporter signs it. Transfer facilities are subject to HW discharge requirements. Burners and marketers must notify EPA of HW fuel activities, even if they already have ID numbers (SUPERSEDED: see Part 266, Subpart H).
 
07/31/1990MULTI-SOURCE LEACHATE AND TREATMENT STANDARDS OF LAND DISPOSAL RESTRICTIONSMemo
 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.
 
06/14/1990RCRA WASTE CLASSIFICATION OF LABORATORY STANDARDSMemo
 Description: F-listed solvent used to dissolve CCP to formulate lab standards use as an ingredient, not a solvent. Diluting or dissolving chemicals to make lab standard is not use. Discarded unused lab standards with P- or U-list chemicals are P-list or U-list hazardous waste if there is one active ingredient. The federal regulations do not require waste codes on the manifest, but the state may. If the waste is both listed and characteristic, it carries all applicable codes for land disposal restrictions (LDR) and incompatible waste.
 
06/07/1990TRANSPORTATION REGULATIONSMemo
 Description: Manifested waste may temporarily be stored at a transfer facility for less than 10 days during the normal course of transportation. Using multiple transporters to buy time in order to accumulate waste quantities to fill transport vehicle not in “normal course of transportation”.
 
02/01/1990MANIFESTING REQUIREMENTS AND EPA IDENTIFICATION NUMBERSQuestion & Answer
 Description: Two facilities owned by same company but separated by a river must have separate EPA ID numbers. Waste transported from one facility to another by public highway must be accompanied by a manifest (SUPERSEDED: manifest exemption for shipments along the border of contiguous properties; 62 FR 6622; February 12, 1997).
 
11/17/1989NITRIC ACID WASTE CHARACTERIZATIONMemo
 Description: While Federal regulations do not require waste codes on the manifest, nitric acid waste that is both ignitable (D001) (i.e., an oxidizer) and corrosive (D002) must be managed in compliance with all special requirements for D001 (e.g., 264.17) and D002 wastes. A waste exhibiting two characteristics carries two waste codes.
 
09/05/1989INTERPRETATIONS OF THE EPA MEDICAL WASTE REGULATIONS (NUMBERS 8-14)Memo
 Description: Medical waste Qs and As, second set (numbers 8-14: recordkeeping requirements, glass intravenous (i.v.) bottles; containers holding blood products; plastic i.v. bags; pleural fluid containers; discarded specimen container; disposable razors; feminine hygiene products; body parts) (SUPERSEDED: see 60 FR 33912; 6/29/95).
 
09/01/1989MANIFEST REQUIREMENTS AND THE OFF-SITE DEFINITIONQuestion & Answer
 Description: Waste moved within a corporate park among wholly owned subsidiaries without use of public road does not need a manifest because it is not transported off-site. Off-site is interpreted as that which is not on-site.
 
08/18/1989EPA I.D. NUMBER AND FACILITY LOCATIONMemo
 Description: ID numbers are issued by-site. On-site includes geographically contiguous property which may be divided by public or private right-of-way. If the public has access to rights-of-way, it is not considered a single property (SUPERSEDED: manifest exemption for shipments along the border of contiguous properties; 62 FR 6622; February 12, 1997).
 
08/15/1989EPA IDENTIFICATION NUMBERS AND FACILITY LOCATIONMemo
 Description: Generators and transporters must obtain EPA ID numbers before they treat, store, dispose of, transport, or offer for transportation, hazardous waste. EPA generally issues one EPA ID number to each unique site. The on-site definition may help in deciding whether a facility constitutes more than one site for purposes of assigning ID numbers (SEE ALSO: RPC# 9/1/83-01). The Region or state implementing agency ultimately decides how many EPA ID numbers apply to particular facility.
 
07/13/1989UNIFORM HAZARDOUS WASTE MANIFESTMemo
 Description: A manifest is no longer required to have a burden box statement.
 
06/26/1989MIXED WASTE REGULATION - RCRA REQUIREMENTS VS. NRC REQUIREMENTSMemo
 Description: Activities that do not require a permit include: recycling, resource recovery, totally enclosed treatment, and treatment in a generator’s accumulation tank. EPA is not planning to modify storage rules to allow generators to hold radioactive mixed waste on-site for radionuclide decay beyond 90 days without a permit (SEE ALSO: 64 FR 63464; November 12, 1999). EPA and the Nuclear Regulatory Commission (NRC) are developing guidance to integrate regulations on radioactive mixed waste storage. EPA and the NRC agree on dual manifesting of mixed waste. Hazardous waste can be shipped to a designated facility in a state that does not regulate that waste as hazardous. EPA does not require a transporters to obtain permits, but States may do so. States may list used oil as hazardous waste.
 
06/15/1989SECONDARY MATERIAL SUBJECTED TO NOTICE REQUIREMENTS UNDER THE US-CANADIAN BILATERAL TREATYMemo
 Description: Spent abrasives from sandblasting used as an ingredient in Portland cement are solid wastes because they are used to produce a product that "will be, or is likely to be, placed on the land," and are subject to hazardous waste regulation if characteristic, including manifesting and export notification.
 
05/03/1989RECYCLING ACTIVITIESMemo
 Description: An owner of the solvent and the recycler are cogenerators of the residue that is generated from the mobile recycling unit. Generators are generally only required to notify once. If the recycler takes on generator responsibilities, he needs an EPA ID number for that particular site. The mobile recycler does not need a permit. Generators may accumulate waste for up to 90 days without interim status or a permit. A generator must comply with 265 Subparts I or J for accumulation units as well as emergency response and training provisions. Wastes residues from recycling are newly-generated wastes with a new point of generation and are allowed a 90 day accumulation period. Waste residues are derived-from wastes, and are assigned the same EPA ID number as the waste from which they are derived. Even if a facility does not have a permit, the owner must comply with the land disposal restrictions (LDR) requirements.
 
04/01/1989GENERATOR STANDARDS APPLICABLE TO TRANSPORTERSQuestion & Answer
 Description: Transporters who mix wastes of different DOT descriptions are not generators of waste. Instead, they assume generator responsibilities such as initiating a new manifest or amending an existing manifest. Previous manifests must be attached to the new manifest.
 
02/07/1989DROSS FROM ALUMINUM SMELTING USED IN MANUFACTURE OF CEMENTMemo
 Description: The 261.4(b)(7) Bevill exclusion covers wastes from processing ores when the feedstock to smelter is greater than 50% ore or mineral. Feedstock of greater than 50% scrap aluminum would not qualify. Aluminum dross is a by-product. Discussion of use of dross in the manufacture of cement as reclamation. If cement or aluminum dross by-product will be placed on the land or in a product that will be placed on the land, the material is a solid and hazardous waste subject to Part 266, Subpart C and must meet land disposal restrictions (LDR) treatment standards. Discussion of sham recycling (SEE ALSO: 63 FR 28556; 5/26/98).
 
12/23/1988HAZARDOUS WASTE MANAGEMENT CAPACITY AND RCRA CONSISTENCY ISSUESMemo
 Description: The CERCLA capacity assurance process under 104(c)(9) ensures that states have adequate capacity to manage hazardous wastes. EPA may withdraw authorized states RCRA programs if the state has unreasonable restrictions on interstate waste movements or fails to use a uniform manifest.
 
10/27/1988TREATMENT RESIDUALS OF CHARACTERISTIC HAZARDOUS WASTE AS A LISTED HAZARDOUS WASTEMemo
 Description: A sludge is F006 once it precipitates from an electroplating wastewater, whether at generator site or at off-site TSDF. Discussion of the derived-from rule for characteristic waste and waste listed solely for characteristic (SUPERSEDED: See RPC# 7/5/89-01; SEE ALSO: 66 FR 27266; 5/16/01). A generator is not required to identify the source of nonhazardous wastewater, but the TSDF responsible for assigning F006 to sludges. For improper waste characterization, correct the error on the manifest or reject the shipment. The generator and TSDF are potentially liable.
 
10/11/1988CONTRACTORS AND GENERATOR RESPONSIBILTIESMemo
 Description: Waste produced at sea is subject to regulation as soon as it is produced unless it is in an exempt unit such as product or raw material storage tank, product or raw material tank vehicle or vessel, or manufacturing process unit (SEE ALSO: Federal Facility Compliance Act (FFCA) section 3022)). Under EPA's cogenerator policy, either Navy personnel or contractors meeting generator definition may perform Part 262 duties. A contractor may sign a manifest certification on behalf of a generator, such as the U.S. Navy, if properly authorized.
 
05/13/1988INTERPRETATION OF 40 CFR 268.7 REQUIREMENTSMemo
 Description: Listings depend on how materials are used in a process, not only on the hazardous constituents. Restricted wastes that are treated, stored, disposed on site or sent off site are subject to the testing, recordkeeping, and manifest requirements. Wastes sent to a recycling facility are subject to the land disposal restrictions (LDR). Treatment residues are subject to LDR notification (SEE ALSO: 62 FR 25997; 5/12/97).
 
05/13/1988LAND DISPOSAL RESTRICTIONS TESTING AND RECORD KEEPING REQUIREMENTSMemo
 Description: Listings depend on how materials are used in a process, not only on the hazardous constituents. Restricted wastes that are treated, stored, disposed on site or sent off site are subject to the testing, recordkeeping, and manifest requirements. Wastes sent to a recycling facility are subject to the land disposal restrictions (LDR). Treatment residues are subject to LDR notification (SEE ALSO: 62 FR 25997; 5/12/97).
 
05/01/1988LAND DISPOSAL RESTRICTIONS - MANIFEST REQUIREMENTSQuestion & Answer
 Description: The manifest number information that is required in the land disposal restrictions (LDR) notification provisions is not necessary for those waste shipments which are not required to have manifests (SEE ALSO: 268.7(a)(10)).
 
02/01/1988IDENTIFICATION NUMBERSQuestion & Answer
 Description: The definition of generator is keyed to both person and site. Where different persons conduct different regulated activities at one site, each person must apply for separate EPA ID number. The region or state implementing agency may assign the same number to both entities.
 
01/20/1988MIXED SOLVENT WASTESMemo
 Description: U-listed product residuals flushed from the product line and mixed together results in a waste with multiple U listings. If the CCPs are intended for reclamation, they are not solid wastes. Discusses the use of a manifest continuation sheet v. more than one manifest for multiple waste shipments.
 
12/01/1987MIXTURE RULE - DISCHARGES TO WASTEWATERQuestion & Answer
 Description: Incidental spills of virgin solvent at a manufacturing site that are collected and discharged to a wastewater treatment unit (WWTU) are exempt from the mixture rule as de minimis losses of commercial chemical products (CCP) (261.3(a)(2)(iv)(D)), not as spent solvents.
 
11/03/1987MANIFEST DOCUMENT NUMBERSMemo
 Description: Manifest document numbers are unique five digit numbers assigned to the manifest by the generator. The number may be entirely numeric or alphanumeric.
 
10/28/1987COMPLIANCE WITH CALIFORNIA LIST FINAL RULEMemo
 Description: Generators managing restricted waste must send the land disposal restrictions (LDR) notification to the treatment facility (SEE ALSO: See 62 FR 25997; 5/12/97). The notification must include the appropriate treatment standard and the California list prohibitions (SUPERSEDED: California list removed, see 62 FR 25997; 5/12/97). The notification information may be placed on the manifest.
 
10/08/1987DECISION DEADLINES FOR RETROFITTING WAIVER REQUESTSMemo
 Description: Interim status surface impoundment retrofit waivers are not necessary for units holding Bevill exempt mining and mineral processing wastes.
 
10/01/1987EXPORT OF RESTRICTED WASTEQuestion & Answer
 Description: Generators must send land disposal restrictions (LDR) notification and/or certification with each shipment of waste even if the waste is to be exported (SUPERSEDED: See 62 FR 25997; 5/12/97). The waste analysis, recordkeeping, and notification requirements apply when the generator handles restricted wastes, regardless of whether the waste will be land disposed.
 
10/01/1987MANIFESTING REQUIREMENTSQuestion & Answer
 Description: Transporters distributing or splitting waste from a bulk storage tank into several loads at a transfer facility, for delivery by different transporters, would need to ensure that the generator prepared separate manifests noting the total amount of waste and that the waste will be split among the different transporters (SEE ALSO: RPC#8/7/98-02).
 
09/01/1987LAND DISPOSAL RESTRICTIONS - CALIFORNIA LISTQuestion & Answer
 Description: An off-site shipment of a California list hazardous waste must be accompanied by a manifest, even if the waste code which makes it hazardous is not restricted (SUPERSEDED: California list removed, see 62 FR 25997; 5/12/97). Sludges which result from the treatment of restricted characteristic wastewaters and are destined for reclamation are not subject to the land disposal restrictions (LDR) because they are not solid wastes (SUPERSEDED: see 58 FR 29860; 5/24/93) (SEE ALSO: 60 FR 43654; 8/22/95).
 
08/19/1987MIXTURES OF LISTED AND CHARACTERISTIC WASTESMemo
 Description: Combining different hazardous waste in the same tank truck for transport is not regulated as hazardous waste treatment. The optional boxes on the manifest that are left blank are for use by states. EPA does not require waste codes on the manifest. Each waste in a waste mixture must be described on the manifest (currently under EPA review).
 
08/07/1987MTR COMPLIANCE DATES FOR SURFACE IMPOUNDMENTS (THERMEX ENERGY)Memo
 Description: The loss of a temporary exclusion is the same as being a newly listed waste for purpose of complying with minimum technical requirements (MTR) for surface impoundments (SIs). There is a conflict between the Section 3005(j)(1) and Section 3005(j)(6) MTR dates. Part B permit application for an interim status facility is due when requested by the State or Regional office. Implementation of closure must begin either 90 days after the SI stops receipt of waste or when the closure plan is approved. The time allowed for closure implementation or completion may be extended.
 
08/07/1987PERMIT REQUIREMENTS, THERMEX ENERGY/RADIANMemo
 Description: The loss of a temporary exclusion is the same as being newly listed for the purpose of complying with the minimum technical requirements (MTR) for surface impoundments (SIs). Addresses the conflict between the 3005(j)(1) and 3005(j)(6) MTR dates. Part B permit applications for interim status facilities are due when requested by a state or Regional office. A facility must initiate closure either 90 days after the SI stops receiving waste or when the closure plan approved. The time for closure implementation or completion may be extended.
 
08/01/1987DEFINITION OF SOLID WASTE AND RECLAMATIONQuestion & Answer
 Description: A commercial chemical product (CCP) that has exceeded its shelf-life can be shipped back to the manufacturer for possible reclamation without a manifest (reverse distribution). An unused chemical remains a CCP (not solid waste) until such time that the manufacturer discards or intends to discard the CCP.
 
08/01/1987DOT MANIFEST REQUIREMENTSQuestion & Answer
 Description: DOT requires hazardous waste generators to include waste codes and waste descriptions on hazardous waste manifests. Provides a summary of the DOT manifest regulations found under 49 CFR Parts 171 and 172.
 
08/01/1987EXPORTING HAZARDOUS WASTEMemo
 Description: Uncracked lead-acid batteries sent to Canada for recycling are not subject to the export requirements (3017) because they are not subject to manifesting. (SUPERSEDED: See 266.80(a)(6)-(7), 273.20, 273.40, 273.56)
 
07/24/1987WASTES GENERATED BY COKE AND COAL TAR PLANTSMemo
 Description: There are no solids or organics content or % water limits for “primarily aqueous” wastewater streams. Addresses the industrial wastewater discharge exclusion (261.4(b)(2)) and “commonly defined by the industry as wastewaters,” and provides examples. The wastewater treatment unit (WWTU) exemption is not for surface impoundments. Discusses “trigger” levels for possible coke by-product K-listings. The listing will be based on 261.11 criteria, which are based on potential hazards and mismanagement, but are not based directly on waste minimization.
 
06/15/1987EXPORTERS OF HAZARDOUS WASTE TO MEXICO, RESPONSIBILITIES OFMemo
 Description: The export of hazardous waste is prohibited unless the 262 Subpart E requirements are met. The U.S. and Mexico have bilateral agreements. The legal liability for hazardous waste does not end when the waste exits the U.S. Exported wastes must be manifested and handled in accordance with the receiving country’s terms of consent.
 
06/01/1987EPA WASTE MINIMIZATION PROGRAM ACTIVITIESQuestion & Answer
 Description: Describes current (1987) EPA activities in waste minimization. EPA is evaluating the desirability of “command and control” regulations.
 
06/01/1987WASTE MINIMIZATION REQUIREMENTSQuestion & Answer
 Description: Includes a summary of the basis for the 3002 waste minimization and its requirements. Addresses the definition of waste minimization.
 
04/30/1987UNIFORM MANIFEST FORM, USE OF CONTINUATION SHEETMemo
 Description: The manifest instructions require generators to use continuation sheets when more than two transporters are used or if more space is needed for DOT description information. States may require the use of additional manifests rather than continuation sheets.
 
03/30/1987SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTSMemo
 Description: A native soil foundation does not constitute a liner for the purposes of the 3005(j)(2) waiver. A 264.282 compatibility demonstration applies to both hazardous and nonhazardous waste. Addresses HSWA waste minimization requirements (3002(b)) and the application of sludge to land treatment units. The identification of principal hazardous constituents for land treated wastes must include all constituents that may enter the waste stream. A land treatment unit performance evaluation must include the unit’s ability to treat and degrade organic constituents, as well as its ability to immobilize heavy metals. Provides guidance on the frequency of soil pore liquid sampling at land treatment units (unsaturated zone monitoring) and guidance on screening groundwater monitoring wells. QA/QC methodology at a land treatment unit should include verification of the organic constituent analysis by gas chromatography/mass spectroscopy (GC/MS). Includes guidance on the content of construction quality assurance plans. A person who conducts quality assurance measures for surface impoundments, waste piles, and landfills should be independent of the construction contractor. Discusses the use of Method 9090 for compatibility testing of liner materials with waste or leachate. All man-made materials that contact waste or leachate should be subjected to the immersion test portion of 9090. A sample of waste or leachate used in compatibility testing must be representative of the actual waste or leachate managed in the surface impoundment, waste pile, or landfill. A concrete pad cannot be equivalent protection. If the design slope of a final landfill cover exceeds 3-5%, the applicant must demonstrate that soil erosion will not be excessive and may need to perform a slope stability analysis. Waste and soil settlement must be included in calculations for the final landfill cover design to be substituted for a waste pile liner as equivalent protection under 3015(a). A flexible membrane liner should not be used in a final cover when the landfill is unusually deep and slopes are steep. Clean, not contaminated, soil should be used for the final cover. A leachate collection system design should be based on realistic infiltration rates. Geogrid and geotextile materials used in place of conventional drainage materials for a landfill must have an equivalent drainage capacity of a one-foot layer of compacted sand. Berms constructed of manufactured slag should not contain hazardous constituents. For landfills, the use of a composite primary liner below the primary synthetic liner is allowable. An owner of a land treatment unit who cannot establish vegetative cover may use an alternate closure procedure. A facility cannot extend closure in order to receive nonhazardous waste (SUPERSEDED: see current 264.113(d)). Addresses the role of the Agency for Toxic Substances and Disease Registry (ATSDR) in exposure information and evaluation. The review of Exposure Information Reports should be coordinated with ongoing RCRA Facility Assessments.
 
03/25/1987PESTICIDE DISPOSAL BY FARMERS AND CONTAINER MANAGEMENTMemo
 Description: Farmer can dispose of rinsate from containers of 2, 4-D pesticide at their own farm if they comply with 262.51 (SUPERSEDED: now 262.70). If farmers render a container empty, they can ship the container without a manifest .
 
03/10/1987GROUNDWATER CLEANUP STANDARDS/ACLS IN DRAFT HSWA PERMIT (INTERNATIONAL PAPER COMPANY)Memo
 Description: Groundwater protection standards may use alternate concentration limits (ACLs) or minimum detection limits. Groundwater containing hazardous waste must be managed as hazardous waste until the hazardous waste is removed. Concentration limits may be set at human health criteria levels that are above taste and odor thresholds. Achieving concentration limits at any monitoring does not terminate further monitoring.
 
03/01/1987SOLVENT MIXTURE RULEQuestion & Answer
 Description: Discusses the applicability of the solvent mixture rule to F003. Wastes that meet both the F003 and F005 listings must receive both waste codes on the manifest and on generator notification. A technical or commercial grade xylene solution meets the F003 listing.
 
02/24/1987WASTEWATER TREATMENT UNITS ARE NOT DESIGNATED FACILITIES AND MAY NOT RECEIVE OFF-SITE HAZARDOUS WASTESMemo
 Description: A facility with an exempt wastewater treatment unit (WWTU) is usually not a designated facility and cannot accept manifested off-site waste. A POTW with a permit-by-rule is a designated facility. A designated facility is facility permitted, interim status, or a recycler (SUPERSEDED: See RPC# 3/26/98-01).
 
02/19/1987REPROCESSING OF BATTERIESMemo
 Description: Waste destined for recycling has the same potential for harm as waste destined for treatment or disposal. Only persons who reclaim lead-acid batteries are subject to regulation for storage prior to recycling (SEE ALSO: Part 273). RCRA 3017 mandated export regulations unless the Administrator is notified, the receiving country has consented, a copy of the consent is attached to the manifest, and the shipment conforms to the consent.
 
02/18/1987SMALL QUANTITIES OF WASTE GENERATED BY LARGE NUMBERS OF GENERATORSMemo
 Description: Includes a summary of the small quantity generator rule. The regulations provide some relief from the paperwork and recordkeeping requirements applicable to large quantity generators.
 
02/05/1987RAPID ISSUANCE OF IDENTIFICATION NUMBERS TO SITES UNDER INVESTIGATION BY DEAMemo
 Description: EPA will issue provisional identification numbers by telephone to Drug Enforcement Administration (DEA) agents that are shipping hazardous waste from clandestine laboratories secured by DEA.
 
01/20/1987NOTIFICATION BY BURNERS OF USED OIL WHO FIRST CLAIM THAT USED OIL MEETS SPECIFICATIONSMemo
 Description: 8700-12 notification is required for all persons who claim that their oil meets specifications (marketers). A handler may notify using either 8700-12, or a letter (SEE ALSO: 279.62).
 
01/07/1987DEMILITARIZATION OF MUNITIONSMemo
 Description: Addresses EPA comments on the draft DOD Instruction on the Applicability of RCRA to demilitarization of munitions. “Leakers” are not normally amenable to further use. Hazardous waste munitions that are commingled with other munitions are subject to regulation, including the use of a manifest (SEE ALSO: 62 FR 6622; 2/12/97).
 
12/19/1986REGULATORY STATUS OF PRECIOUS-METAL CONTAINING WASTES THAT ARE RECLAIMEDMemo
 Description: Reclamation of precious metal-containing hazardous waste is subject to notification, recordkeeping, and manifesting.
 
12/01/1986TREATMENT CAPACITYQuestion & Answer
 Description: Under section 270.42, the addition of new wastestreams to an existing permit is a minor permit modification provided certain conditions are met (SUPERSEDED: See current 270.42)).
 
11/28/1986RESPONSIBILITY FOR CERTIFYING ACCURACY OF GENERATOR CERTIFICATIONSMemo
 Description: There is no requirement for an authorized representative to sign the manifest certification. The person signing the certification should have direct knowledge of the information on the manifest. The generator biennial report certification allows a certification of accuracy and completeness of the report.
 
11/24/1986PROPOSED PERMIT-BY-RULE FOR USED OIL RECYCLERSMemo
 Description: The filing of a used oil burner notification form 8700-12 before the effective date of the used oil rule will not subject the filer to the standards. Filing 8700-12 does not subject the filer to section 3004(u) corrective action. 8700-12 is not a permit application. A discussion of the proposed permit-by-rule provision for used oil recyclers per section 3014(d).
 
11/17/1986LISTING HAZARDOUS WASTE NUMBERS ON GENERATOR PAPERWORKMemo
 Description: A generator is not required to list waste codes on the manifest. States might require waste codes. When completing notification form 8700-12 , the generator must list all the individual hazardous waste codes generated.
 
10/20/1986MODIFIED MANIFEST WASTE MINIMIZATION CERTIFICATION FOR SMALL QUANTITY GENERATORSMemo
 Description: Small quantity generators (SQGs) became subject to the manifest waste minimization certification requirement (3002(b)) on 9/22/86. EPA modified the waste minimization statement for SQGs.
 
09/30/1986SLUDGE WASTE HANDLING IF TEMP. EXCLUSION IS WITHDRAWN / FUTURE METALS RECOVERY-STEEL FACILITYMemo
 Description: Waste subject to the temporary exclusion is not subject to the manifest requirements until the exclusion is lost. Once the exclusion is lost, the waste must be handled as hazardous.
 
09/29/1986RESPONSES TO ACCIDENTAL SPILLS OF LISTED OR CHARACTERISTIC HAZARDOUS WASTESMemo
 Description: An authorized official may approve the removal of a transportation spill without an EPA ID number or a manifest in an emergency. The transporter must respond immediately. A summary of the exemption from the sections 264 and 265 standards for immediate responses to hazardous waste discharges. Spills should be addressed in accordance with the contingency plan. Spills that are not cleaned up become land disposal sites subject to permitting. There is no definition of immediate response. Spill areas where hazardous waste is treated, disposed, or stored past an immediate response phase are subject to interim status and permitting standards. RCRA regulations do not specify the cleanup standards for spill situations.
 
09/25/1986MANAGEMENT OF WASTES PRIOR TO INTRODUCTION INTO SEWERMemo
 Description: A facility that generates a hazardous waste and ships it to POTW for treatment must comply with all applicable accumulation and transportation requirements, including the manifest.
 
09/08/1986REGULATORY OBLIGATIONS OF PRINTERS WHO USE RECYCLABLE RAGS AND WIPERSMemo
 Description: Generator status is determined by the total of the hazardous waste generated in a calendar month. Waste identification for solvent-contaminated rags and shop towels is under review for petition (SEE ALO: RPC# 2/14/94-01). SQG solvent rags from the printing industry may be managed under a tolling agreement. A printer shipping hazardous rags to an industrial laundry may qualify for the manifest exemption under 262.20(e) if the printer is a SQG and all conditions of the exemption are met.
 
08/19/1986TREATMENT OF HAZARDOUS WASTE IN PIPELINES LEADING TO A WASTEWATER TREATMENT PLANTTREATMENT OF HAZARDOUS WASTE IN PIPELINES LEADING TO A WASTEWATER TREATMENT PLANTMemo
 Description: An elementary neutralization unit (ENU) or wastewater treatment unit (WWTU) can be a series of connected units. A flume, gutter, pipe, or open channel may be defined as a tank. WWTU wastewater is water with few percent contaminants (SUPERSEDED: See RPC# 2/11/91-01, RPC# 6/2/93-04). Pouring characteristic hazardous waste (HW) into an industrial sewer drain pipe where HW mixes with wastewaters is not treatment as the dilution is incidental to the pipe's primary purpose of conveyance (SEE ALSO: 268.3). An open channel in an enclosed building is not a totally enclosed treatment unit (TETU). HW subject to substantive regulation is counted for generator category determination. HW piped directly into an ENU and CWA sewer discharge is not counted. The 261.3(a)(2)(iv) de minimis mixture rule exemption is only for listed HW mixtures, not characteristic mixtures.
 
06/04/1986PERMITS FOR PLACEMENT OF HAZARDOUS WASTE IN UNDERGROUND SALT MINESMemo
 Description: Hazardous waste other than bulk liquids, can be placed in salt mines if a permit is issued. Salt mines may be miscellaneous units. An overview of the State and Federal consultation process on joint permitting.
 
05/20/1986USED X-RAY FILM AS A SPENT MATERIAL - SILVER RECLAMATIONMemo
 Description: Used x-ray film is a spent material, but it is not specifically listed hazardous waste (HW). Although trade association data suggest it is not characteristic, each generator is responsible for the HW determination. If HW x-ray film is sent to a silver reclaimer, the generator must get an ID number and manifest the waste.
 
05/01/1986INTERIM STATUS AND SQGSQuestion & Answer
 Description: A CESQG treating on-site exceeding the 1000 kg accumulation limit may apply for interim status instead of managing the waste under LQG requirements. Since CESQGs are exempt from submitting a Notification of Regulated Waste Activity Form (8700-12), the notification is not required for the eligibility for interim status under section 3005(e) of RCRA (3010).
 
04/28/1986WASTE MINIMIZATION CERTIFICATION REQUIREMENTSMemo
 Description: A discussion of a proposal to extend waste minimization certification requirement to small quantity generators. Only one signature is required for two parts of the certification. From an enforcement perspective, EPA is primarily concerned with the compliance with the certification signatory requirement. A generator should make a good faith effort to minimize the amount of waste generated (3002(b)). Judgments made by the generator for purposes of a waste minimization certification are not subject to external regulatory action.
 
04/16/1986MOBILE RECYCLING UNIT FOR REPROCESSING WASTE SOLVENTSMemo
 Description: Vehicles that do not transport hazardous waste do not need manifests or transporter status. Reclamation activities are not regulated. Storage, transportation associated with recycling are regulated. In authorized states, comply with the state rules.
 
04/10/1986TEN DAY REGULATION FOR TRANSPORTATION OF HAZARDOUS WASTEMemo
 Description: Transporters storing manifested waste at a transfer facility for 10 days or less are not subject to permitting. The 10 days does not include waste in transit, only the waste in storage.
 
03/24/1986PERMIT PROCESS ISSUESMemo
 Description: RCRA permits differ from other EPA permits because they minimize the potential threats from entire hazardous waste management facilities v. discrete points of discharge or an emissions source. Specific, complex permitting requirements are necessary.
 
02/13/1986APPLICABILITY OF PERMITTING REGULATIONS TO RECYCLERS Memo
 Description: A recycling facility that does not store waste prior to recycling does not need a RCRA Subtitle C permit. The facility must comply with the 3010 notification requirements and the manifest requirements of 265.71 and 265.72.
 
02/09/1986MARKETING OR BURNING HAZARDOUS WASTE FUEL, NOTIFICATION OFMemo
 Description: A historical discussion of the notification and manifest requirements for hazardous waste-derived fuel handlers (SUPERSEDED: see 56 FR 7194; 2/21/91; see 266.100).
 
02/06/1986WASTE MINIMIZATION AND INCLUSION OF RECYCLINGMemo
 Description: The waste minimization certification on the manifest, a biennial report, and a TSDF permit, is mandatory (3002(b)) (SUPERSEDED: no longer required on biennial report, see 1997 Hazardous Waste Report Instructions). There is no guidance on what constitutes a waste minimization program or activity. The generator determines compliance with the waste minimization criteria. Recycling is a form of waste minimization.
 
01/02/1986PERMIT-EXEMPT STATUS OF SLUDGE DRYERS ADDED TO WASTEWATER TREATMENT UNITSMemo
 Description: A sludge dryer that meets the wastewater treatment unit (WWTU) definition is exempt from permitting. Sludge drying is a treatment. Presses, filters, and sumps may be tanks under the definition of a WWTU. Tanks not discharging under sections 402 or 307(b) of CWA that are part of the wastewater treatment system meet the exemption. WWTU tanks may volatilize their contents and retain the exemption. Sludge dryers can be used to meet the section 3002(b) waste minimization requirements. While the WWTU is exempt from permitting, hazardous waste sludge removed from the unit is subject to regulation.
 
12/23/1985RD&D PERMITS - POLICY GUIDANCEMemo
 Description: Research, development, and demonstration (RDD) permittees must manifest unused/reduced waste to a permitted facility (SEE ALSO: 260.10, definition of designated facility). Explains no set of requirements for RDD information reporting. RDD permit can cover activities which may potentially occur. Discusses the partial closure of a RDD facility. Discusses that sold equipment should be decontaminated. Discusses that there is no policy on expediting permitting mobile treatment units (SEE ALSO: 264 Subpart X).
 
12/13/1985PERMIT ISSUES REGARDING ON-SITE TREATMENT BY FLUIDIZED BED INCINERATIONMemo
 Description: A waste transferred from a generator to an incinerator located on a property leased from the generator does not have to be manifested if the waste never crosses public highway or never leaves the generator’s property. The permit for the incinerator located on a leased property at the generator site must be signed both by the owner of the property and the operator of the incinerator. The owner or operator of facility includes the owner of the land, the owner of the structures, and the operator of the facility or unit. Since both the owner of the property and the operator of a facility must sign a permit application, the two parties are jointly and severally liable for all RCRA requirements, including closure.
 
11/29/1985CANADIAN MANIFEST FOR SHIPMENTS ENTERING THE U.S.Memo
 Description: Generators and transporters are only required to prepare and carry the U.S. Uniform Hazardous Waste Manifest for shipments of hazardous waste from U.S. to Canada. The EPA is considering implementing similar provisions for wastes originating in Canada and transported to the U.S.
 
10/31/1985SMALL QUANTITY GENERATOR REGULATIONS APPLICABILITY TO LABORATORIESMemo
 Description: HSWA sets new requirements for SQG. Laboratories may be SQG. The interim requirements for SQG include manifesting (SEE ALSO: 51 FR 10146; 3/24/86).
 
10/23/1985RECLAIMED METHANOL IS A PRODUCT RATHER THAN A WASTEMemo
 Description: Reclaimed methanol (99.5% purity) sent off-site for further reclamation before use in a manufacturing process is more product-like than waste-like, is not a solid waste, and need not be manifested. It is analogous to reclaimed metals that only have to be refined (SEE ALSO: 50 FR 634; 1/4/85).
 
10/17/1985MANIFEST CERTIFICATION SIGNATURE BLOCK FOR EMPLOYEES SIGNING FOR GENERATING COMPANYMemo
 Description: Employees signing the manifest may sign on behalf of their company. Preprinting the phrase "on behalf of . . ." under the signature line on the manifest is allowed. Additional information about the signature may be included in Item 15.
 
10/01/1985WASTE MINIMIZATIONQuestion & Answer
 Description: The 3002(b) waste minimization requirements are self implementing and leave the choice of a method to the generator. Waste exchanges, recycling of solvents, on-site reuse and off-site recycling are all legitimate waste minimization.
 
09/19/1985BULKING AND CONSOLIDATING SHIPMENTS OF COMPATIBLE WASTES WITH DIFFERENT HAZARDOUS CODESMemo
 Description: Consolidating wastes with different DOT descriptions at transfer facilities is not treatment if it does not render the waste nonhazardous. Consolidating wastes of different DOT description requires a new manifest. Transporters can repackage waste from one container to another.
 
09/11/1985WASTE MINIMIZATION: PERMIT CERTIFICATION AND JOINT PERMITTINGMemo
 Description: RCRA 3005(h) requires that TSDF permits must include a waste minimization certification in facility operating record. The certification requirements must be addressed by either the State or EPA in joint permitting issues.
 
09/01/1985WASTE MINIMIZATION CERTIFICATIONQuestion & Answer
 Description: An unsigned waste minimization certification is not a significant manifest discrepancy. A TSDF that receives a shipment of waste without proper waste minimization certification does not have to notify the Regional Administrator (RA).
 
07/11/1985GENERATOR WASTE MINIMIZATION STATEMENTSMemo
 Description: Employees signing the manifest may sign on behalf of their company. Preprinting the phrase "on behalf of . . ." under the signature line on the manifest is allowed. The individual signing the manifest and the company are responsible for veracity of certification statement.
 
07/01/1985SQGS, RECLAMATION, AND THE MANIFESTQuestion & Answer
 Description: SQGs producing between 100 and 1000 kg/month of hazardous waste that partially reclaim silver from spent photo fixer prior to shipment off-site for further reclamation are not subject to precious metals recycling recordkeeping, but spent material must be manifested (SEE ALSO: 10/5/94-01, current 261.5, 262.34(d)).
 
06/25/1985GENERATOR RESPONSIBILITIES FOR IMPORTATION OF HAZARDOUS WASTEMemo
 Description: The importer is the generator. The transporter and the U.S. facility arranging the import are importers and cogenerators. There is joint and several liability for generators and cogenerators. Imported hazardous waste (HW) must be manifested. Imported HW is subject to all applicable manifest requirements even if the importer and TSDF are the same.
 
06/01/1985SQG MANIFEST DESIGNATION FOR PLASTIC BOTTLESQuestion & Answer
 Description: Plastic containers (similar to Clorox bottles) containing hazardous waste must be categorized as “DF” in item 12 on the manifest; “DF” means fiberboard or plastic drums, barrels, or kegs.
 
05/01/1985MANIFEST USE AND STATE AUTHORIZATIONQuestion & Answer
 Description: The generator State or designated State determines manifest requirements. A waste that is nonhazardous in both the initiating and the receiving state and is transported through a state where it is hazardous does not need a manifest. Either the generator State or the designated State can require manifesting.
 
11/01/1984WASTE REGULATED ONLY BY THE STATEQuestion & Answer
 Description: Guidance is provided on designating items on the manifest that are state- but not federally-regulated.
 
10/25/1984VIOLATION OF EPA HAZARDOUS WASTE MANIFEST REGULATIONS BY FEDERAL FACILITIESMemo
 Description: Section 262.21 establishes a hierarchy for acquisition of manifests. All generators, including EPA facilities, must follow this protocol.
 
09/01/1984BLOCK TWELVE (CONTAINER TYPE)Question & Answer
 Description: The relationship of DOT container regulations for large batteries (battery) and Item 12 on the manifest are discussed.
 
07/01/1984DRUM OF LISTED WASTE INTO ON-SITE WWT FACILITIESQuestion & Answer
 Description: A drum of listed waste dumped into an on-site wastewater treatment facility does not qualify for the 261.3(a)(2)(iv)(E) de minimis exemption to the mixture rule. The scope of the exemption is outlined.
 
06/26/1984STATE MODIFICATIONS TO UNIFORM HAZARDOUS WASTE MANIFEST REGULATIONSMemo
 Description: 271.10(h) prohibits re-lettering of the manifest form. If a state decides not to require completion of all manifest items, EPA recommends instructing manifest users to leave items blank. Discussion of comments on Missouri’s manifest form modifications.
 
06/01/1984EXPORT OF HW FOR REUSE IN WASTEWATER TREATMENTQuestion & Answer
 Description: K062 that is exported for reuse in wastewater treatment must be accompanied by a manifest, and the generator must notify the Office of International Activities if the receiving facility does not have NPDES permit (SUPERSEDED: see current 261.2, 261.6, and RPC# 6/5/85-01).
 
06/01/1984RECEIVING FACILITY NEEDS EPA ID NUMBERQuestion & Answer
 Description: A facility that receives hazardous waste in a U.S. port prior to export needs an EPA ID number. The facility also needs a storage permit, unless it is a transfer facility.
 
06/01/1984RENOTIFICATION FOR NEWLY LISTED WASTESQuestion & Answer
 Description: A generator, transporter, or TSDF owner or operator must renotify for newly listed wastes only if the Administrator specifically requires renotification in the Federal Register notice for the newly listed waste (SEE ALSO: contact implementing agency).
 
04/01/1984CHARACTERISTIC WASTES EXPORTED FOR RECYCLINGQuestion & Answer
 Description: Characteristic wastes that will be legitimately recycled abroad do not need to be manifested for export. Section 261.6(a) supersedes 262.50 (SUPERSEDED: see current 261.2, 261.6).
 
04/01/1984MAINTAINING COPIES OF MANIFESTS AND BIENNIAL REPORTSQuestion & Answer
 Description: Generators are not required to keep copies of manifests and biennial reports on site. Copies can be kept at corporate headquarters. A generator must be able to provide to EPA information on, or access to, records. TSDFs must keep copies of manifests on site. Biennial reports must be furnished upon request and made available for inspection by EPA personnel.
 
03/01/1984ADDITIONAL INFORMATION REQUIRED ON MANIFEST BY FACILITYQuestion & Answer
 Description: Information, such as waste concentration or pH, that a facility requires on a manifest goes in block 15 - “Special Handling Instructions and Additional Information.”
 
03/01/1984SHIPPING PAPER INSTEAD OF MANIFESTQuestion & Answer
 Description: Bulk water and intermediate rail transporters must have EPA ID numbers, although they may use a shipping paper in lieu of the manifest. A generator must record on the manifest the name and EPA ID number of all transporters.
 
12/15/1983COMPUTERIZED HAZARDOUS WASTE MANIFEST PREPARATION SERVICESMemo
 Description: A generator may use the services of outside firms to aid in preparing manifests. The generator must assure that information on the manifest is correct. The generator is ultimately responsible for the preparation of the form (generator liability).
 
12/14/1983MINIMUM SHELL THICKNESS REQUIREMENT, WAIVERMemo
 Description: There are no provisions for the Regional Administrator (RA) to grant a waiver for the minimum shell thickness that is required for hazardous waste storage or treatment tanks (SUPERSEDED: see 51 FR 25422; 7/14/86).
 
11/01/1983WEIGHT OF CONTAINER FOR QUANTITY DETERMINATIONSQuestion & Answer
 Description: The weight of a container is not counted when determining generator status or for biennial reporting. It is customary to show the total weight (i.e., waste plus container) on the manifest.
 
10/01/1983MANIFEST FOR SPLIT SHIPMENTQuestion & Answer
 Description: Provides guidance on completing the manifest when one rail shipment of waste is divided among five tank trucks for transport to the designated facility identified on the manifest (SEE ALSO: RPC#8/7/98-02).
 
09/01/1983ON SITE/GENERATOR ID NUMBER (UNIVERSITY AS GENERATOR)Question & Answer
 Description: Wastes shipped from one college campus building to another need a manifest while they are on the highway, unless they are shipped directly across the road (SUPERSEDED: manifest exemption for shipments along the border of contiguous properties; 62 FR 6622; 2/12/97). Sites are required to have separate EPA ID numbers, even if the receiving facility is on-site. The on-site definition is used only to determine if a manifest is necessary. Buildings on contiguous property at college campus are classified as a single generation site, and would receive one EPA ID number. All waste generated at a site is evaluated in determining generator status. At university campuses that are divided by a right-of-way that they do not control, each city block or each half of the campus bisected by a public road is a separate generator, and requires their own EPA ID number (SUPERSEDED: see the manifest exemption for shipments along the border of contiguous properties; 62 FR 6622; 2/12/97)
 
08/03/1983RESPONSE TO REGION V’S EPA IDENTIFICATION NUMBER QUESTIONSMemo
 Description: ID numbers site-, not owner-specific. A generator or TSDF at a new site gets a new site number. Corporations at the same site can have different numbers. A lessor of federal property on a federal site may get a separate number. A transporter company has one number for all trucks and trucking locations.
 
05/01/1983PHASE I INTERIM AUTHORIZATIONQuestion & Answer
 Description: Anyone who generates hazardous waste must notify under 3010 of RCRA, even if the generator is located in a state with Phase I interim authorization that does not recognize the federally listed waste as hazardous.
 
01/01/1983CONSOLIDATION OF SHIPMENTS AND MIXING OF HAZARDOUS WASTE BY TRANSPORTERSQuestion & Answer
 Description: Transporters consolidating wastes with the same DOT descriptions at a transfer facility are not required to remanifest the waste, and are not subject to generator standards. Containers empty per 261.7 are not subject to regulation.
 
01/01/1983MANIFEST DISCREPANCY VS. UNMANIFESTED WASTEQuestion & Answer
 Description: If any information required by 262.21 is not on the manifest, the waste is considered unmanifested. The difference between the quantity or type of waste designated on the manifest and the quantity or type of waste received at the facility is a manifest discrepancy (SEE ALSO: current 264.72, 264.76).
 
12/01/1982GENERATOR ID NUMBERSQuestion & Answer
 Description: A generator who does not treat, store, dispose, transport, or offer for transport hazardous waste does not need an EPA ID number. Generators who accumulate waste according to 262.34 need EPA ID numbers because accumulation is a form of storage, even if the waste is subsequently discharged to the sewer.
 
02/01/1982MANIFESTING FOR RECYCLABLE MATERIALSQuestion & Answer
 Description: No manifest is needed for materials handled under 261.6 (SUPERSEDED: see current 261.6).
 
09/29/1981STATES’ ROLE IN ASSIGNING EPA IDENTIFICATION NUMBERSMemo
 Description: Unauthorized states are encouraged to assist EPA in assigning ID numbers. EPA encourages states that issue their own ID numbers to adopt EPA’s numbering system. Facilities may obtain an EPA ID number if they are handling waste only regulated by the state (not EPA). Discusses the ID number issuing process.
 
11/03/1980REGISTRATION AS A WASTE TREATMENT FACILITYMemo
 Description: Requirements to notify EPA regarding Part 262 is independent of the notification requirements for Part 270.
 
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