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05/14/2013CHECKLIST TO ASSIST IN EVALUATING WHETHER COMMERCIAL CHEMICAL PRODUCTS ARE SOLID AND HAZARDOUS WASTE UNDER THE RESOURCE CONSERVATION AND RECOVERY ACTMemo
 Description: This memorandum transmits a separate revised memorandum that provides guidance and a checklist for evaluating the regulatory status of materials that would, under usual circumstances, be commercial chemical products (CCPs). CCPs are not solid waste if they are appropriately stored or managed for use, legitimately reclaimed, or appropriately stored or managed for legitimate reclamation; CCPs are solid waste if they are abandoned by being accumulated, or by being stored, or treated before, or as a means of, being disposed. The checklist is designed to assist in applying this regulatory structure to specific situations and evaluating whether a particular CCP, managed in a particular way, is a solid waste. If a CCP is a solid waste, it then must be determined if the CCP is listed as a hazardous waste or exhibits a characteristic of hazardous waste. If the CCP is a solid and hazardous waste, it must be managed in compliance with the RCRA Subtitle C hazardous waste management regulations.
 
02/17/2012SCOPE OF HAZARDOUS WASTE LISTING P046 (PHENTERMINE)Memo
 Description: The scope of the P046 listing does not include phentermine salts (SEE ALSO: RO 14778).
 
08/23/2010CHARACTERIZATION OF USED TOLUENE WHEN SOLD AS A FUEL ADDITIVE OR FOR OTHER FUEL PURPOSESMemo
 Description: Used toluene is a spent material and not a commercial chemical product (CCP), therefore the solid waste exemption for fuels burned for energy recovery does not apply. "Commercial chemical product" refers to a chemical substance which is manufactured or formulated for commercial or manufacturing use. This consists of the commercially pure grade of the chemical, any technical grades of the chemical that are produced or marketed, and all formulations in which the chemical is the sole active ingredient. It does not refer to a material such as a manufacturing process waste. Used toluene is a spent material because it has been used and as a result of contamination, can no longer serve the purpose for which it was produced without processing. Additionally, "contamination" as used in the definition of spent material, is any impurity, factor, or circumstance which causes the material to be taken out of service. Finally, the definition of spent material has been consistently applied to materials that have been used and are no longer fit for use without being regenerated.
 
08/23/2010REGULATION OF UNUSED DERMAL NICOTINE PATCHESMemo
 Description: Unused dermal patches containing nicotine would be regulated as a listed hazardous waste when disposed. Nicotine in finished dosage forms, such as tablets or capsules, is regulated because it is a commercial chemical product formulation containing nicotine as the sole active ingredient. EPA views transdermal patches as an analogous dosage form. However, after the patch has been applied and removed, it has been used for its intended purpose and therefore would not be listed hazardous waste when discarded. EPA does not view dermal patches to be “manufactured articles”. This letter supersedes an earlier response that was included in a report for the RCRA, Superfund & EPCRA Hotline, RCRA/UST, Superfund and EPCRA Monthly Hotline Report, April 1995 (RO 13741, page 1).
 
03/18/2003REGULATION OF NITROGLYCERINE UNDER REVISED MIXTURE AND DERIVED-FROM RULESMemo
 Description: Under the revised mixture and derived-from rules, wastes listed solely for exhibiting the characteristic of ignitability, corrosivity, or reactivity are not hazardous wastes if they do not exhibit a characteristic. Medicinal nitroglycerine is not listed as P081 if it is not reactive because P081 is listed solely for reactivity. If a waste does not exhibit a characteristic at the point of generation, then land disposal restrictions (LDR) are not applicable (SEE ALSO: 66 FR 27286; 5/16/01). The revised mixture and derived-from rules are less stringent, so authorized states may choose not to adopt them. Nitroglycerine will remain regulated as P081 in states that do not adopt the new rules.
 
12/01/2002REGULATORY STATUS OF SOLVENT RESIDUE FROM SPRAY CANSQuestion & Answer
 Description: Unused solvent removed from a non-empty spray can may meet a hazardous waste listing if the solvent is on the P or U list. The unused solvent might also exhibit a characteristic of hazardous waste. An unused solvent would not be classified as an F-listed spent solvent since it was never used. Hazardous waste determinations are the responsibility of the generator.
 
07/24/1997REGULATORY DETERMINATION ON THE STATUS OF CERTAIN MANUFACTURING WASTESMemo
 Description: Warfarin tablets meeting a commercial chemical product (CCP) listing are still considered listed CCPs when tested by crushing or dissolving. The de minimis mixture rule exclusion in Section 261.3(a)(2)(iv)(D) applies to discharges of CCPs from rinsing and cleaning personal protective equipment (PPE). Discarded equipment meeting the definition of debris which is contaminated with a listed waste must be managed as a hazardous waste (HW) until it no longer contains the HW. Contaminated equipment can be washed using the alternative debris treatment standards to the point where it is no longer considered to contain a HW. Whether air filters from a manufacturing process meet a listing depends on site-specific factors. Air filters used in the production of a P or U listed commercial chemical product (CCP) do not fall within the scope of the Section 261.33 listings prior to the material (warfarin) becoming a CCP. Once the material meets the listing description (becomes a CCP), particles captured in the filters are a listed CCP when disposed (USE WITH CAUTION: see 56 FR 7200; 2/21/91). Air filters are regulated as a solid waste mixed with a listed hazardous waste. Air filters may qualify as hazardous debris and may be washed so as to no longer contain a listed hazardous waste.
 
08/01/1996DEFINITION OF COMMERCIAL CHEMICAL PRODUCT FOR SOLID WASTE DETERMINATION VS. HAZARDOUS WASTE IDENTIFICATIONQuestion & Answer
 Description: Discusses the definition of commercial chemical product (CCP) for purposes of definition of solid waste v. for purposes of definition of P-listed or U-listed hazardous waste. For purposes of the P- and U-lists, EPA intended to include only those CCPs and manufacturing chemical intermediates known by generic name listed in Section 261.33. P- and U- listed wastes exclude manufactured articles such as thermometers and fluorescent lamps. For purposes of Section 261.2, CCP means all types of unused commercial products, whether chemicals or not. Off-specification thermometers going for reclamation are CCPs going for reclamation and are not solid wastes. Thermometers going for disposal are not U151 and are only regulated if characteristic.
 
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.
 
02/27/1996CLARIFICATION OF THE ""MIXTURE RULE,"" THE ""CONTAINED-IN"" POLICY, LDR ISSUES, AND ""POINT OF GENERATION"" FOR U096Memo
 Description: U096 spilled on soil is subject to the contained-in policy. The contained-in policy does not specify levels at which contained-in determinations must be made. EPA leaves contained-in determinations to the discretion of the implementing agency. Under the Section 261.3(a)(2)(iii) mixture rule exemption, mixture of hazardous waste listed solely for exhibiting a characteristic (e.g., U096) and solid waste that no longer exhibits a characteristic can be disposed in a subtitle D landfill, but must still meet land disposal restrictions treatment standards (SEE ALSO: 268.3; 61 FR 18780; 4/29/96; 66 FR 27266; 5/16/01).
 
02/15/1996USE OF USED OIL AS A DUST SUPPRESSANTMemo
 Description: EPA prohibits the use of used oil as dust suppressant. EPA does not have the authority under RCRA to regulate commercial dust suppressants or other commercial products other than waste-derived products and discarded commercial chemical products.
 
09/01/1995ISOMERS OF P- AND U-LISTED WASTESQuestion & Answer
 Description: If the generic mixed isomer name and CAS number of a compound appear on the P-list or U-list, any individual isomers of that compound and all mixtures of isomers of that compound meet the listing. When EPA designates a particular isomer, only that isomer is covered by the listing.
 
08/24/1995CARBAMATE LISTING DETERMINATION (60 FR 7824, FEBRUARY 9, 1995) AS IT RELATES TO THE LATEX PROCESS WASTES GENERATED BY A COMPANYMemo
 Description: K161 is limited to production wastes from dithiocarbamate acids and their salts. Latex process wastes containing dithiocarbamate (ethyl zimate) are not U407, as ethyl zimate is not the sole active ingredient (SUPERSEDED: U407 listing vacated by Dithiocarbamate Task Force v. EPA). Residue remaining in a container or inner liner removed from a container that held any listed CCP is a hazardous waste when discarded or intended for discard.
 
06/08/1994APPLICABILITY OF 261.33 TO DIETHYLHEXYL PHTHALATE-CONTAINING CAPACITORS FROM FLUORESCENT LIGHT BALLASTSMemo
 Description: Capacitors that contain diethylhexyl phthalate (DEHP) that are removed from lamp ballasts have been used, and therefore are not U028. If DEHP from ballasts is reclaimed and then spilled or discarded, the listing could apply.
 
03/01/1994OFF-SPECIFICATION PARAFORMALDEHYDE MEETS COMMERCIAL CHEMICAL PRODUCT LISTINGQuestion & Answer
 Description: Paraformaldehyde is an off-specification form of formaldehyde and meets the U122 listing. When commercial chemical products (CCPs) undergo chemical changes and become off-specification, the original P or U code still applies.
 
09/20/1993DISCARDED OFF-GAS PIPING, EQUIPMENT, AND OFF-GAS SCRUBBER SOLUTION FROM A TANK SYSTEMMemo
 Description: Discarded off-gas scrubber solution is not listed hazardous waste because the gas contained in the solution is derived-from a product, not a waste. Liquid tank residuals are listed CCP. If container from which residues are removed is RCRA empty, residue not hazardous waste (SUPERSEDED: See the April 12, 2004 letter from Springer to Coles). Contains discussion of the triple rinsing requirement for acute (P-listed) waste.
 
09/01/1993NITROGLYCERINE PILLS AS COMMERCIAL CHEMICAL PRODUCTSQuestion & Answer
 Description: Discarded pills containing nitroglycerine as the sole active ingredient are P081 (SUPERSEDED: see 66 FR 27286; May 16, 2001 and RPC# 3/18/03-01). There is not a critical percentage or cut-off concentration in order to be the sole active ingredient for the P- and U-listed listings.
 
11/01/1992RECLAIMED COMMERCIAL PRODUCTS: REGULATORY STATUSQuestion & Answer
 Description: Reclaimed creosote is classified as U051 if discarded. Creosote-contaminated soil is regulated as hazardous waste because it contains U051.
 
03/01/1992COMMERCIAL CHEMICAL PRODUCT DEFINITION IN 261.33Question & Answer
 Description: Discarded unused commercial chemical product (CCP) with two active ingredients cannot be P-listed or U-listed waste because the listed chemical is not the sole active ingredient. Functionally inert components are not active ingredients.
 
04/12/1991NOTIFICATION OF ERRORS IN THE TECHNICAL AMENDMENT TO THE THIRD THIRD LAND DISPOSAL RESTRICTIONS (LDRS), PUBLISHED JANUARY 31, 1991Memo
 Description: Addresses the corrections to the treatment standards for K048, P003, P073, U001, U003, U154 (errata sheet for 58 FR 3877; 1/31/91, Technical Amendment to the Third Third) (SEE ALSO: current 268.40).
 
08/20/1990REGULATORY STATUS OF MANUFACTURING PROCESS WASTE WITH XYLENE AND PESTICIDE CONSTITUENTSMemo
 Description: The presence of xylene and pesticide constituents in manufacturing process waste does not necessarily trigger the hazardous waste listings.
 
06/20/1990CLARIFICATION OF SPENT SOLVENT LISTINGSMemo
 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.
 
06/14/1990RCRA 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.
 
05/01/1990HAZARDOUS WASTE IDENTIFICATIONQuestion & Answer
 Description: Mercury spilled from a used thermometer is a spent material and is a solid waste when reclaimed. Mercury-contaminated soil is a hazardous waste if it exhibits a characteristic. P-list and U-list designation for spill residues applies to a unused CCP, not used mercury.
 
04/05/1990DIMETHYL BENZENE-LISTING CLARIFICATIONMemo
 Description: Benzene dimethyl (U239, CAS No. 1330-20-7), a synonym for xylene, is listed for ignitability only (typographical error in CFR). The 4/22/88 Federal Register (53 FR 13382) added CAS numbers and chemical synonyms to P- and U-lists.
 
03/29/1990INCINERATOR RESIDUES FROM TRIAL BURNMemo
 Description: The residues from an incinerator trial burn that uses carbon tetrachloride and chlorobenzene are U211 and U037. Using a material for an incinerator trial burn is intent to dispose.
 
02/14/1990END-USERS OF CHLORDIMEFORM EXEMPTIONMemo
 Description: Chlordimeform not listed, but may be ignitable (D001). Not subject to regulation if returned to the manufacturer for resale or reclamation. If there is a valid market, continued use as product is not solid waste (SW). The burden of proof is on the party making the claim. Canceled pesticides are SW if discarded (abandoned), intended for discard, or fuel.
 
10/05/1989WASTE CODE LISTINGS AND TECHNICAL CORRECTIONSMemo
 Description: Warfarin is the common name associated with the chemical listed as P001. The U036 listing covers all formulations in which chlordane is the sole active ingredient. There is no CAS number associated with U051 because EPA wants to include all forms of creosote. Discussion of corrections to U126 and U161.
 
08/21/1989P AND U-LISTED WASTESMemo
 Description: The P-and U-listings do not apply to chemicals listed in 261.33 that have been used for their intended purpose, but waste must still be evaluated for characteristics. If an unused chemical is no longer a technical or commercially pure grade due to contamination, it can still be an off-specification species of that chemical and so still meet the applicable P or U listing when discarded. Solvent CCPs that have been used for their solvent properties may meet one of F001-F005 listings.
 
08/02/1989CHLOROFLUOROCARBONS (CFCS) AS REFRIGERANTS, RECYCLING OF SPENTMemo
 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)).
 
08/01/1989WASTE IDENTIFICATION OF DISCARDED THERMOMETERSQuestion & 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)
 
06/23/1989REGULATION OF CANCELLED PESTICIDESMemo
 Description: Until the FIFRA regulations are amended to reflect RCRA Subtitle C storage standards, the regulations applicable to storage of suspended or canceled U-listed pesticides (silvex and 2,4,5-T) are determined on a case-by-case basis (SUPERSEDED).
 
11/02/1988WASTE LISTINGS FOR COMMERCIAL CHEMICAL PRODUCTS - MERCURYMemo
 Description: The determination of whether mercury-containing thermometers, batteries (battery), and switches are CCPs and solid waste are U151 when discarded depends on the contamination and usage of the material. (SEE ALSO: 70 FR 45508; 8/5/05)
 
07/21/1988CHLOROFLUOROCARBON RECYCLINGMemo
 Description: Used refrigerants meet the definition of a spent material. Used CFC refrigerant is not F-listed spent solvent but may exhibit a characteristic. Used refrigerant is not U121 or U075 because it has been used. The P-listings and U-listings do not apply to used chemicals. Cylinders containing used refrigerants to be reclaimed are solid waste (SW). Generators may use knowledge of similar operations at different facilities to characterize waste (SEE ALSO: 261.4(b)(12)). An owner of refrigeration equipment and a company or individual performing servicing may be generators of used refrigerant waste (i.e., cogenerators).
 
05/03/1988CHLORDANE AND HEPTACHLOR PESTICIDE WASTEMemo
 Description: CCPs (pesticides) must be discarded or intended for discard to be P- or U-listed hazardous waste. Materials are "discarded" when abandoned, applied to the land, or used to produce a fuel. Products containing small amounts of other chemicals as manufacturing impurities still have a sole ingredient. There is no percentage cutoff for active ingredient. An active ingredient performs the function of a product. Fillers, carriers, and propellants are not active ingredients. Chlordane product (U036) that contains small amount of heptachlor (P059 if CCP) has only one active ingredient (chlordane) because heptachlor is a manufacturing impurity. Technical grade means all commercial grades of chemical. There is no exact criteria define technical grade. Product purity varies from compound to compound.
 
04/25/1988REGULATORY STATUS OF ANTINEOPLASTIC DRUG WASTESMemo
 Description: Antineoplastic drugs that have been diluted are not spent materials because they are not contaminated and have not been used for their intended function. Excess portions of unused antineoplastic drugs listed in 261.33 that have been diluted are solid waste when discarded and are P-listed or U-listed hazardous wastes if drug is sole active ingredient.
 
03/14/1988ECOSCINT A & ECOSCINT OMemo
 Description: Ecoscint A and Ecoscint O are not listed. They would be hazardous waste if they exhibit a characteristic.
 
02/11/1988SPENT PIPELINE FILTER CARTRIDGESMemo
 Description: If F-listed solvents pass through a pipeline and filter cartridge, the spent filter is listed via the derived-from rule until or unless it is delisted (SEE ALSO: 66 FR 27266; 5/16/01). If the filter contains a discarded P- or U-listed CCP solvent, the filter is listed until it no longer contains hazardous constituents.
 
01/14/1988WASTE GENERATED BY AN INCINERATOR TRIAL BURN OF SAND SPIKED WITH TRICHLOROBENZENE AND HEXACHLOROETHANEMemo
 Description: A mixture of sand and unused CCP hexachloroethane (U131) for use in an incinerator trial burn is a hazardous waste. Ash derived from burning the mixture carries U131 via the derived-from rule.
 
06/16/1987CONTAINERS USED TO HOLD LISTED CHEMOTHERAPY DRUGSMemo
 Description: Several chemotherapy drugs are U-listed wastes. In order to minimize exposure, EPA recommends against rendering vials holding these drugs empty under 261.7. Instead, the entire volume of waste, including the vials themselves, should be weighed.
 
05/13/1987PACKAGES CONTAINING RESIDUAL URETHANE COATING CHEMICALSMemo
 Description: Containers holding listed or characteristic residues should be emptied according to 261.7 to ensure that containers are no longer subject to Subtitle C regulation. 261.7 applies to all hazardous wastes, not just P-listed and U-listed CCPs.
 
03/11/1987SOILS CONTAMINATED WITH CHLORDANE AND HEPTACHLOR DURING TREATMENT OF BUILDINGS FOR TERMITESMemo
 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.
 
12/05/1986SOLVENTS USED AS REACTANT AND SOLVENT WASTES GENERATED BY A PRODUCTION PROCESSMemo
 Description: Process waste containing xylene used as a reactant in the formulation of sodium xylenesulfonate CCP is not F003. Still bottoms from the distillation of excess reactant xylene are not F003. Spent xylene and still bottoms from xylene recovery are not U239. Characteristic still bottoms are not subject to the F001-F005 treatment standards promulgated in the solvents and dioxins rule (51 FR 40638; 11/7/86).
 
12/05/1986SOLVENTS USED AS REACTANT NOT LISTED AS SPENT SOLVENT OR COMMERCIAL CHEMICAL PRODUCTMemo
 Description: Process waste containing xylene used as a reactant in the formulation of sodium xylenesulfonate CCP is not F003. Still bottoms from the distillation of excess reactant xylene are not F003. Spent xylene and still bottoms from xylene recovery are not U239.
 
09/29/1986SOIL CONTAMINATED WITH CHLORDANE AS A RESULT OF PESTICIDE APPLICATIONMemo
 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.
 
09/15/1986DEFINITION OF SOLID WASTEMemo
 Description: Ignitable discarded paint with xylene is D001 as the xylene is not spent F003, nor a discarded unused CCP (U239). A mixture of waste listed solely for a characteristic with a solid waste is not hazardous waste if the mixture is not characteristic (SEE ALSO: 268.3; 66 FR 27266; 5/16/01). Spent toluene is F005, not F002. A pyridine osmium tetroxide mixture is not P- or U-listed because the mixture is not a pure or technical grade of the chemical or a sole active ingredient.
 
06/03/1986REQUEST FOR COMMENT ON MEMORANDUM CONCERNING THE CLEANUP OF RESIDUES OF COMMERCIAL CHEMICAL PRODUCTS WITHIN A WAREHOUSE STORAGE AREAMemo
 Description: Listed or characteristic CCPs spilled in a warehouse are subject to RCRA Subtitle C regulation unless immediately cleaned up.
 
05/09/1986HEALTH ASSESSMENT INFORMATION IN LISTING DECISIONSMemo
 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.
 
05/06/1986HEALTH ASSESSMENT INFORMATION IN LISTING DECISIONS; LISTING OF TF-1, AN ELECTRICAL TRANSFORMER FLUSHING AGENTMemo
 Description: The presence of Appendix VIII hazardous constituents or a combination of P-listed and U-listed ingredients are not the only factors in the listing determination for solvent TF-1. Concentration, migration potential, persistence, quantity generated, and management history are part of the determination. To be listed under on P- or U-list it must be a pure or technical grade of a listed solvent, or contain a sole active ingredient.
 
01/30/1986ANTI-NEOPLASTIC AGENTS IN HOSPITAL WASTES, DISPOSAL OFMemo
 Description: Seven antineoplastics are U-listed hazardous waste. Antineoplastics are not regulated as class. Hospitals generating less than 100 kg/mo exempt as CESQG. There is no EPA guidance for a proper incineration destruction temperature.
 
12/01/1985BURNING AND BLENDINGQuestion & Answer
 Description: A mixture of used oil and a commercial chemical product (CCP) (xylene) that is itself a fuel or normal component of commercial fuels is regulated as used oil, not hazardous waste fuel, when it is burned for energy recovery. The generator who burns the used oil is subject to 266, Subpart E (SUPERSEDED: See 279.20 and 279.60).
 
11/01/1985SOLVENT MIXTURE RULEQuestion & Answer
 Description: If a spilled product has two or more active ingredients (e.g., toluene and benzene) then the spill residue would not be classified as a P-listed or U-listed waste. The contaminated soil is only hazardous if it exhibits a characteristic.
 
07/16/1985CREOSOTE TREATED CROSS TIES, DISPOSAL OF, FIFRA INTERFACEMemo
 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.
 
06/27/1985SCRAP DEHP AND SMALL CAPACITORS CONTAINING DEHP, DISPOSAL REQUIREMENTS FORMemo
 Description: Contaminated diethylhexyl phthalate (DEHP) generated in a manufacturing process is U028. The capacitors are not U028. Gloves and rags used to clean up spills or leaks of DEHP are listed. The materials contaminated as a result of handling during the manufacturing would not be listed.
 
05/14/1985DISCARDED COMMERCIAL CHEMICAL PRODUCTSMemo
 Description: Section 262.11 outlines the generator’s responsibility for identifying hazardous wastes. The P- and U-listings apply only to unused CCPs, not to process wastes containing chemicals listed in 261.33. The U122 formaldehyde listing does not apply to waste containing used formaldehyde or fish contaminated with formaldehyde. Discarded fish and formaldehyde must be evaluated for characteristics. EPA regulates certain chemicals in their unused form but not all wastes containing the same chemicals.
 
05/01/1985SOLID WASTE DETERMINATION - ACRYLONITRILE ASHQuestion & Answer
 Description: A burned product is viewed as discarded. Ash from the product acrylonitrile that burns in a warehouse fire meets the U009 listing via derived-from rule.
 
04/10/1985PERCHLOROETHYLENE AND SURFACTANT, DISTILLATION OF RESIDUE CONTAININGMemo
 Description: Product perchloroethylene mixed with surfactant is still the CCP U210. CCPs being reclaimed are not solid wastes. The residue from distillation is hazardous.
 
01/18/1985K001-LISTED WASTES FROM WOOD PRESERVING PROCESSESMemo
 Description: EPA is aware of no single analytical method with which to determine the presence of creosote. U051 applies to raw creosote that is discarded. K001 applies to wastes from wood preserving processes that use creosote and/or pentachlorophenol (PCP).
 
12/26/1984CONTAMINATED GROUNDWATER, RCRA REGULATORY STATUSMemo
 Description: Generators do not use Appendix VIII in hazardous waste (HW) determination. Wastes containing Appendix VIII constituents are not HW unless they are listed or characteristic. Collected groundwater contaminated with listed or characteristic waste is regulated as HW. Discussion of the contained-in policy.
 
11/29/1984CORROSIVE SOLIDS, COMMERCIAL CHEMICAL PRODUCTS, REACTIVE WASTES DEFINEDMemo
 Description: Solid forms of sodium hydroxide and potassium hydroxide are not D002 corrosive wastes because there is no test for corrosive solids. Formaldehyde residues in potato starch are not a P-listed or U-listed hazardous waste. The CCP comment in the regulations is in brackets and thus is not part of the regulations. Reactive cyanide and sulfide levels are outlined (SUPERSEDED: see RPC# 4/21/98-01).
 
08/01/1984METHYL CHLOROFORMQuestion & Answer
 Description: Off-specification methyl chloroform produced from the reclamation of listed solvent (F002) is considered an off-specification CCP when discarded and meets the U226 listing.
 
05/30/1984BALLAST FLUID CLASSIFICATIONMemo
 Description: Process wastes containing listed P-list and U-list chemicals are not listed. The P-list and U-list is only for CCPs, which are commercially pure or technical grade substances in which the chemical is the sole active ingredient. Formaldehyde used to control growth in a ship ballast is not listed.
 
04/30/1984TOXICITY OF 2,4,D WASTEMemo
 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.
 
03/01/1984XYLENE (U239) SPILLED ONTO SOILQuestion & Answer
 Description: If unused xylene is spilled onto the ground, contaminated soil is not U239 if the soil is not ignitable, due to the mixture rule exclusion in 261.3(a)(2)(iii) (SUPERSEDED: see RPC# 3/22/94-03; RPC# 11/4/92-01).
 
11/01/1983SALTS AND ESTERS OF P- AND U-LISTED WASTESQuestion & Answer
 Description: Commercial chemical products (CCPs) are regulated under 261.33 only if the chemical is specifically listed in 261.33(e) or (f). If the parent compound is listed but the salt or ester of that compound is not, then only the parent compound is controlled. 302.4 lists CCPs by CAS number (SEE ALSO: RPC# 9/1/95-01).
 
11/01/1983USED COMMERCIAL CHEMICAL PRODUCTQuestion & Answer
 Description: Chemicals listed in 261.33 no longer qualify as commercial chemical products (CCPs) after they have been used, and do not meet a P-listing or U-listing. Tetrachloroethylene (PCE) in a transformer is U210 if it leaked prior to putting the transformer in service.
 
08/01/1983ANTINEOPLASTIC DRUGSQuestion & Answer
 Description: Discusses U-listed antineoplastic (anticancer) drugs, including Cyclophosphamide (Cytoxin), Daunomycin, Melphalan, Mytomycin C, Streptozotocin.
 
03/12/1983CLARIFICATION OF REGULATORY STATUS OF MANUFACTURING WASTES CONTAINING COMPOUNDS LISTED IN 261.33Memo
 Description: P-and U-listings do not apply to manufacturing process wastes with compounds listed in 261.33 because EPA unable to establish reliable concentration levels indicating when such wastes containing P-listed or U-listed chemicals pose enough of a hazard to deserve regulation.
 
02/01/1983BENZENE LEAK INTO GROUNDWATERQuestion & Answer
 Description: Benzene that leaked into groundwater prior to 11/19/80 is classified as hazardous waste (HW) if it was pumped and treated after 11/19/80. Benzene-contaminated groundwater is U019. When the site is reactivated, the facility must comply with HW regulations.
 
05/13/1981APPLICABILITY OF 261.33 TO DISCARDED PRODUCTSMemo
 Description: CCPs are not solid wastes until the decision is made to discard them. Pharmaceutical chemical (U245) becomes a hazardous waste at the point the decision is made to discard (after returned to manufacturer) (reverse distribution system).
 
05/07/1981APPICABILITY OF 261.33(F) LISTING TO SEWER AND CESSPOOL ADDITIVES CONTAINING ORTHODICHLOROBENZENEMemo
 Description: Use of orthodichlorobenzene (U070) to unclog sewer pipes and septic tanks is not disposal of unused CCP and is not listed. CCPs are not hazardous waste until they are discarded. Normal use is not disposal. Organic solvents in cesspool/ sewer lines may contaminate groundwater and soil.
 
03/12/1981MANUFACTURING WASTE CONTAINING COMMERCIAL CHEMICAL PRODUCTS IN 261.33Memo
 Description: P-listed and U-listed CCPs are products usually containing high concentrations of toxics or pesticides of high toxic activity. 261.33 does not include all process wastes due to the problems of establishing de minimis concentration thresholds. Process wastes that contain P-listed and U-listed chemicals are not P-listed or U-listed.
 
11/18/1980ASBESTOS AS A HAZARDOUS WASTEMemo
 Description: Technical grade asbestos is a U-listed hazardous waste (SUPERSEDED: see 45 FR 78532; 11/25/80).
 
09/04/1980COMMERCIAL CHEMICAL PRODUCTS UNDER 261.33Memo
 Description: Wastestreams containing chemicals on the P-list and U-list are not P-listed or U-listed if the chemical is not an unused discarded product.
 
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