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05/21/2007APPLICABILITY OF RCRA TO DISPOSAL OF UNIFIED GROUP RATION - EXPRESS (UGR-E)Memo
 Description: For disposal of expired flameless heaters in Unified Group Ration - Express (UGR-E), EPA believes that it is unlikely that intact UGR-Es would be RCRA hazardous waste when disposed. For disposal of unused, individual chemical heaters by a unit, although the heaters may exhibit the characteristic of reactivity, EPA believes unused individual heaters taken from an UGR-E issued for use in the field are excluded under the household waste exclusion. Therefore, EPA urges generators and handlers to manage unused heaters carefully and recycle them if possible.
 
06/08/2006GUIDANCE FOR GENERATORS DISPOSING OF FULLY-DISCHARGED LITHIUM SULFUR DIOXIDE BATTERIESMemo
 Description: A fully discharged lithium sulfur dioxide battery would have zero volts and would be unlikely to exhibit the reactivity characteristic. Lithium sulfur dioxide batteries that have been discharged using a Complete Discharge Device (CDD) to a voltage of one volt per cell or less are unlikely to be reactive. Discharge of batteries to remove the electric charge is an acceptable waste management practice under the universal waste rule. Batteries are considered hazardous waste at the time of removal from service. Generators, transporters, and consolidation points managing universal waste are required to comply with the land disposal restrictions (LDR). If lithium sulfur dioxide batteries are reasonably expected to contain underlying hazardous constituents (UHCs) above its universal treatment standard (UTS) level, the UHC must be treated to the UTS level before land disposal. Once batteries have been discharged and are no longer characteristic hazardous waste, it is not necessary to treat UHCs at a RCRA-permitted facility. Decharacterized universal waste meeting LDR requirements, including applicable UTS for UHCs, can be managed as nonhazardous waste and may be sent to a municipal solid waste landfill (MSWLF).
 
10/29/2004CLASSIFICATION AND DISPOSAL OF WASTE FLAMELESS RATION HEATERSMemo
 Description: The disposal of flameless ration heaters (FRHs) that are discarded by individual soldiers issued Meals, Ready-to-Eat (MREs) is excluded from RCRA Subtitle C regulation under the household waste exclusion. It is unlikely that multiple, unused MREs (that contain FRHs) would be RCRA hazardous waste when disposed. EPA generally considers multiple unused FRHs (not packaged with MREs) that are discarded to be a D003 reactive waste which, therefore, must be managed as a RCRA hazardous waste when disposed.
 
12/16/2003HAZARDOUS WASTE CHARACTERISTICS SCOPING STUDYMemo
 Description: The Hazardous Waste Characteristics Scoping Study reviewed the current hazardous waste (HW) characteristics that address the properties of ignitability, corrosivity, reactivity, and toxicity. The study examined the effectiveness of the regulations in identifying HW, whether other waste properties should be used to classify HW, and whether HW characteristics should be expanded. The study found that most nonhazardous waste is managed appropriately when disposed. The study identified the need for investigations on the risk of waste releases to air, on the potential for hazardous constituents to leach from waste, and on the measurement of ignitability, corrosivity, and reactivity. The air studies found no need for additional regulation. Other investigations are underway.
 
04/18/2003RESULTS OF THE HAZARDOUS WASTE CHARACTERISTICS SCOPING STUDYMemo
 Description: The Hazardous Waste Characteristics Scoping Study reviewed RCRA hazardous waste characteristics. The Scoping Study examined whether RCRA regulations were effective in identifying hazardous waste, whether other waste properties should be used to classify hazardous waste, and whether hazardous waste characteristics should be expanded. The study found that most nonhazardous wastes are managed appropriately when disposed. The study identified the need for investigations on the risk of waste releases to the air, on the potential for hazardous constituents to leach from wastes, and on the measurement of the ignitability, corrosivity, and reactivity characteristics. Air studies found no need for additional regulation. Other investigations are currently underway.
 
03/25/2003RESULTS OF HAZARDOUS WASTE CHARACTERISTIC SCOPING STUDYMemo
 Description: The Hazardous Waste Characteristics Scoping Study reviewed RCRA hazardous waste characteristics. The Scoping Study examined whether RCRA regulations were effective in identifying hazardous waste, whether other waste properties should be used to classify hazardous waste, and whether hazardous waste characteristics should be expanded. The study found that most nonhazardous wastes are managed appropriately when disposed. The study identified the need for investigations on the risk of waste releases to the air, on the potential for hazardous constituents to leach from wastes, and on the measurement of the ignitability, corrosivity, and reactivity characteristics. Air studies found no need for additional regulation. Other investigations are currently underway.
 
03/07/2003FOLLOW-UP ACTIVITIES TO THE HAZARDOUS WASTE CHARACTERISTICS SCOPING STUDYMemo
 Description: The Hazardous Waste Characteristics Scoping Study reviewed the effectiveness of current hazardous waste characteristics in identifying regulated hazardous wastes. The study examined whether other properties should be used to classify a waste as hazardous or if current characteristics should be expanded. The Scoping Study found most nonhazardous waste is managed appropriately when disposed. More investigations are needed on the risk of waste releases to air, on the potential for hazardous constituents to leach from waste, and on the measurement of the ignitability, corrosivity, and reactivity characteristics. Air studies found no need for additional regulation. Other investigations are currently underway.
 
11/15/2002REGULATION AND DISPOSAL REQUIREMENTS FOR SODIUM AZIDEMemo
 Description: RCRA regulates the management of wastes containing sodium azide in certain circumstances, including disposal of commercial sodium azide, disposal of wastes from the manufacture of explosives, and disposal of wastes that, when mixed with water, generate toxic gases in quantities sufficient to present a danger to human health or the environment. States may have more stringent or more specific waste management regulations. The Occupational Safety and Health Administration (OSHA) governs safety procedures for managing various classes of explosives and has general guidelines for handling chemicals and risk communication.
 
10/07/2002FOLLOW-UP ACTIVITIES TO THE HAZARDOUS WASTE CHARACTERISTICS SCOPING STUDYMemo
 Description: The Hazardous Waste Characteristics Scoping Study reviewed the effectiveness of current hazardous waste characteristics in identifying regulated hazardous wastes. The study examined whether other properties should be used to classify a waste as hazardous or if current characteristics should be expanded. The Scoping Study found most nonhazardous waste is managed appropriately when disposed. More investigations are needed on the risk of waste releases to air, on the potential for hazardous constituents to leach from waste, and on the measurement of the ignitability, corrosivity, and reactivity characteristics. Air studies found no need for additional regulation. Other investigations are currently underway.
 
09/10/2002RESULTS OF HAZARDOUS WASTE CHARACTERISTICS SCOPING STUDYMemo
 Description: The Hazardous Waste Characteristics Scoping Study reviewed RCRA hazardous waste (HW) characteristics. The Scoping Study examined whether the regulations were effective in identifying HW, whether other waste properties should be used to classify HW, and whether HW characteristics should be expanded. More studies are needed on the risks of waste releases to air, the potential for hazardous constituents to leach, and measurements of the ignitability, corrosivity, and reactivity characteristics. Air studies found no need for additional regulation. The Scoping Study found that most nonhazardous waste is managed appropriately when disposed.
 
12/15/2000COMBUSTION PROHIBITION AND EXPLOSIVE WASTESMemo
 Description: Toxicity characteristic (TC) metal wastes are prohibited from dilution by combustion unless one or more of the criteria in 268.3(c) are met. D003 explosive wastes that are also TC metal wastes may be combusted under 268.3(c)(5). Explosive wastes contain hazardous concentrations of organics.
 
05/20/1999CLASSIFICATION AND DISPOSAL OF UNUSED FLAMELESS RATION HEATERSMemo
 Description: Unused Flameless Ration Heaters (FRH) for the Army’s Meals Ready to Eat (MRE) may be a reactive (D003) hazardous waste when disposed. The Department of the Army (DOA) has developed several management options for FRHs including reuse, incineration, and/or treatment and disposal. Products that have not been used, and which are to be used for their original purpose, are generally not wastes under RCRA. Unused commercial chemical products (CCPs) being reclaimed are not regulated as wastes. FRHs may be reacted with water and then disposed of as ordinary wastes if treatment is conducted in accordance with applicable requirements and if land disposal restrictions (LDR) requirements are met before land disposal. Some states may have more stringent requirements. The disposal of spent FRH materials, following normal use to heat a MRE, is not disposal of a hazardous waste.
 
04/21/1998WITHDRAWAL OF CYANIDE AND SULFIDE GUIDANCEMemo
 Description: The cyanide and sulfide reactivity guidance is withdrawn (See RPC# 7/12/85-02). Critical errors were made in developing the original guidance. A Federal Register notice announcing the withdrawal of the guidance from SW-846 will be prepared soon. The Agency expects that generators should continue to classify their high concentration sulfide- and cyanide-bearing wastes as hazardous based on the narrative standard.
 
08/14/1997REGULATORY STATUS OF USED NICKEL CATALYSTMemo
 Description: Discusses the regulatory status of spent catalyst being reclaimed. A material is reclaimed if it is processed to recover a usable product, or if it is regenerated. The hazardous waste determination is the generator’s responsibility. Determination is made by evaluating the waste using a required test or by comparing the properties of the waste with the narrative standard. A lack of required test for ignitability of solids and reactivity does not prohibit consideration of test data where there is reason to question the generator’s RCRA determination.
 
08/12/1997SOLIDIFICATION OF K044 WITH POZZOLANIC MATERIALMemo
 Description: Solidification of K044 with pozzolanic material satisfies the land disposal restrictions (LDR) treatment standard. Solidified material can no longer exhibit the potential to form reactive residues and must not exhibit any hazardous waste characteristic.
 
05/19/1997CLARIFICATION OF REACTIVITY CHARACTERISTIC AS IT PERTAINS TO AEROSOL CANSMemo
 Description: EPA is unable to make a categorical determination as to whether various types of aerosol cans that may have contained a wide range of products exhibit the characteristic of reactivity. The generator is responsible for making this determination, Steel aerosol cans that have been punctured and drained would meet the definition of scrap metal. Scrap metal that is recycled is exempt from RCRA, thus generators need not make a hazardous waste determination.
 
06/08/1995GUIDANCE ON WHETHER GENERATORS MUST POST ""NO SMOKING"" SIGNS WHEN A FACILITY HAS A ""TOBACCO-FREE"" POLICYMemo
 Description: Discusses the EPA interpretation of enforceability of comments and notes in the regulations. Comments and notes are not legal requirements. Generators meeting the requirements of Section 262.34 need not comply with Section 265.17(a). Generators may be required to post a “no smoking” sign in accordance with Section 265.31. Treatment, storage, and disposal facilities (TSDFs) must, at a minimum, post “no smoking” signs wherever there is a hazard from ignitable or reactive waste, even if the facility has a tobacco-free environment.
 
02/24/1995REGULATORY ISSUES PERTAINING TO WASTES CONTAMINATED WITH EXPLOSIVE RESIDUESMemo
 Description: Section 261.23(a)(8) should not be used because it references DOT regulations which have been changed. Debris/media mixed with explosives are reactive if they continue to exhibit a characteristic. The Bureau of Alcohol, Tobacco, and Firearms (BATF) methods may be used to determine reactivity for Section 261.23(a)(6) and (7), but would not be enforceable.
 
02/15/1995Environmental Fact Sheet: EPA Proposes Concentration-Based Treatment Standards for Hazardous Constituents Found in Characteristic Wastes Managed in Clean Water Act SystemsPublication
 Description: Announces EPA's proposed innovative compliance options for meeting requirements posed by the DC Circuit Court's opinion on the Third Third land disposal restrictions for ignitable, corrosive, and reactive wastes. Addresses ways to integrate overlapping requirements under the Clean Water Act and RCRA statutes to avoid duplication.
 
12/16/1994BUBBLER CANISTERS CONTAINING PHOSPHOROUS OXYCHLORIDE ARE NOT WASTE WHEN RETURNED TO THE UNITED STATES FROM JAPAN FOR REGENERATIONMemo
 Description: Bubbler canisters containing unused phosphorous oxychloride is a commercial chemical product (CCP) when reclaimed and not solid waste. A partially empty bubbler canister which is recharged by adding new phosphorous oxychloride to residual phosphorous oxychloride left in the bubbler is continued use of a product, not waste. The bubbler canister is not subject to OECD provisions when imported into U.S. for reclamation, because the bubbler canister is not subject to U.S. laws and regulations. Phosphorous oxychloride is highly corrosive and reacts violently with water, and therefore could be a reactive or corrosive characteristic hazardous waste if it is a solid waste. It is inappropriate to discharge untreated phosphorous oxychloride to a wastewater treatment system or to land dispose. Phosphorous oxychloride is hazardous reactive (D003) and possibly corrosive (D002) when discarded. Phosphorous oxychloride can be destroyed through the addition of a sodium hydroxide solution.
 
11/03/1994CLARIFICATION OF DISCARDED AMMUNITION OF 0.50 CALIBERMemo
 Description: Small arms ball ammunition up to and including .50 caliber are not reactive (D003) but may be hazardous for another characteristic. Popping furnaces are incinerators. Popping furnaces treating small arms ball ammunition that exhibit a characteristic are subject to RCRA as incinerators.
 
07/08/1994EXPORT FROM JAPAN OF PHOSPHORUS OXYCHLORIDE CONTAINING BUBBLERSMemo
 Description: Waste bubblers containing phosphorous oxychloride may exhibit the characteristics of corrosivity (D002) and reactivity (D003). An importer of waste is responsible for hazardous waste determinations and generator duties. An importer could be a waste broker, transporter, or destination TSDF (SUPERSEDED: RPC# 9/14/94-02).
 
01/26/1994RESPONSE TO PROPOSED PROCEDURE TO DECOMMISSION ALUMINUM CHAFF ROVING BUNDLESMemo
 Description: Aluminum chaff roving bundles could exhibit the reactivity characteristic (D003) for their propensity to release flammable hydrogen gas when they are exposed to moisture. The Part 268 land disposal restrictions (LDR) treatment standard for these wastes is deactivation, which is best achieved by washing them with an acidic solution (SUPERSEDED: treatment standard is deactivation and meet 268.48 standards, see 268.40). Compliance is evaluated based on the removal of the characteristic, not based on following a specified method of deactivation.
 
01/04/1994REGULATORY STATUS OF WASTE AEROSOL CANSMemo
 Description: No categorical determination is possible as to the reactivity of various types of aerosol cans. A hazardous waste determination is the responsibility of generator. Steel aerosol cans that do not contain a significant amount of liquid (e.g., cans that have been punctured and drained) meet the definition of scrap metal. Aerosol cans that are recycled as scrap metal are exempt, and the generator need not make a hazardous waste determination (SEE ALSO: 261.4(a)(13) exclusion for processed scrap metal).
 
01/03/1994REGULATORY STATUS OF METAL CASINGS CONTAINING SPENT POWDERED METALLIC OXIDE CATALYSTMemo
 Description: Metal casting containing spent powdered metallic oxide catalyst (i.e., manganese dioxide and copper oxide) is not a listed waste, but could exhibit a characteristic, most likely ignitability (D001) or reactivity (D003). Manganese dioxide is a strong oxidizer and poses a human health hazard through inhalation.
 
12/22/1993REGULATORY STATUS OF BATTERIESMemo
 Description: Lithium-sulfur dioxide batteries (battery) that have been fully discharged to zero volts do not exhibit the characteristic of reactivity (D003). Other lithium batteries may exhibit the toxicity characteristic for constituents such as lead (lead-acid batteries), cadmium (nickel-cadmium rechargeable batteries), and mercury (mercuric oxide, and some alkaline batteries), or they may be hazardous due to other characteristic properties.
 
11/08/1993CLARIFICATION ON THE LEVEL OF SULFIDE FOR DETERMINING IF A WASTE IS HAZARDOUS UNDER THE REACTIVITY CHARACTERISTICMemo
 Description: If a waste contains greater than 500 mg/kg total releasable sulfide, then the waste is usually considered to meet the narrative definition of a characteristically reactive(SUPERSEDED: see RPC# 4/21/98-01). Discusses contrasting releasable sulfide methods.
 
10/07/1993REGULATORY STATUS OF USED RESIDENTIAL AND COMMERCIAL/INDUSTRIAL AEROSOL CANSMemo
 Description: EPA is unable to determine if aerosol cans exhibit the characteristic of reactivity (D003). Emptying a steel aerosol can by puncturing and draining it may be exempt as a step in recycling the can as scrap metal. A steel aerosol can qualifies as scrap metal if it does not contain significant liquids (i.e., is fully drained) and is therefore exempt from regulation when sent for recycling. Aerosol cans may be rendered empty in accordance with 261.7. Liquid or gas removed from a can is hazardous waste if it is listed or characteristic. There is no need to determine if a steel aerosol can is empty once it qualifies as scrap metal (i.e., once it no longer contains significant liquids) that is destined for recycling. Aerosol cans generated by households qualify for household hazardous waste exclusion. The exclusion attaches at the point of generation and continues to apply throughout the waste management cycle.
 
10/07/1993REGULATORY STATUS OF USED RESIDENTIAL AND COMMERCIAL/INDUSTRIAL AEROSOL CANSMemo
 Description: Aerosol cans generated by households qualify for the household hazardous waste exclusion. The exclusion attaches at the point of generation and continues throughout the waste management cycle. Steel aerosol cans are scrap metal when they are recycled if they do not contain significant liquids. There is no need to determine if a steel aerosol can is empty once it qualifies as scrap metal. Emptying an aerosol can by puncturing and draining may be exempt as a step in the recycling of the can as scrap metal. EPA is unable to determine if aerosol cans exhibit the characteristic of reactivity (D003). Liquid or gas removed from a can is hazardous waste if it is listed or characteristic. Aerosol cans may be emptied in accordance with 261.7.
 
09/24/1993CLARIFICATION OF THE USED OIL REGULATIONS APPLICABLE TO MIXTURES OF USED OIL AND CHARACTERISTIC WASTEMemo
 Description: Mixtures of used oil and ignitable-only characteristic wastes (D001) are regulated as used oil if they are no longer D001. Mixtures of used oil and other characteristic wastes are hazardous wastes if they are characteristic, and used oil if they are not. Mixtures of used oil and wastes listed solely for ignitability are regulated as used oil if they are no longer ignitable. Mixtures of used oil and wastes listed for corrosivity, reactivity, or characteristic of toxicity are hazardous wastes if they exhibit a characteristic, and used oil if they do not.
 
09/14/1993REGULATORY STATUS OF LITHIUM SULFUR DIOXIDE BATTERIESMemo
 Description: The regulatory determination made in the letter, Williams to Berger (RPC# 3/18/87-01), regarding the potential reactivity of lithium sulfur dioxide (LiSO2) batteries (battery) is still in effect.
 
04/19/1993USE OF PAINT FILTER LIQUIDS TEST TO DETERMINE FREE LIQUIDS IN A WASTEMemo
 Description: The paint filter liquids test Method 9095 was developed to determine free liquids in waste. The test is not intended for use in determining if a waste contains any bound or absorbed liquid or if a liquid is aqueous. The aqueous phase must be present to evaluate waste for pH (SEE ALSO: RPC# 2/16/90-01).
 
03/03/1993AVAILABILITY OF CRITERIA USED TO EVALUATE THE CHARACTERISTIC OF REACTIVITYMemo
 Description: EPA has test procedures to determine the reactivity of wastes that release hydrogen cyanide or hydrogen sulfide gas when they are mixed with weak acid. There is no EPA test for waste that releases hydrogen gas when it is mixed with water. Many reactive properties, such as water reactivity, are difficult to quantify (SUPERSEDED: the test procedures have been withdrawn, see RPC# 4/21/98-01).
 
11/03/1992TRANSPORTATION AND DISPOSAL OF SHOCK SENSITIVE OR EXPLOSIVE MATERIALSMemo
 Description: Picric acid and ethyl ether may be hazardous due to reactivity. The removal, and transportation of old lab chemicals to eliminate imminent and substantial danger qualifies for Section 270.1(c)(3) permit exemption. Emergency permit regulations can also be used. A RCRA permit is necessary if a safety official determines no immediate safety threat exists.
 
06/16/1992DESIGNATION OF AMERICIUM BERYLLIUM SOURCES UNDER RCRAMemo
 Description: Discusses the tentative determination that americium beryllium (AmBe) sealed source wastes are not RCRA hazardous wastes. AmBe sealed sources are not P015, and are not ignitable (D001), corrosive (D002), or reactive (D003). EPA does not expect stainless steel casings to fail the toxicity characteristic. Beryllium residues discarded during sealed source manufacturing process may be P015. Solder from sealed sources may be evaluated using a combination of testing and mass balance approaches. The theoretical TCLP concentration can be based on solder composition or by testing.
 
05/29/1991ELECTROPLATING WASTESMemo
 Description: Anode bags are spent materials when removed from electroplating bath for reclamation. Spent anode bags are both reactive (D003) and F007. Bags can be washed in an accumulation tank/container without a permit under Section 262.34. Filter media, and residue from the apparatus used to filter cyanide plating bath are D003 (reactive) and F008, but not F007. A cleaning bath that does not contain cyanides is not F009.
 
05/21/1991APPLICABILITY OF THE TCLP TO WASTE MUNITIONSMemo
 Description: The mandatory hazardous waste determination should be based on knowledge when the application of TCLP to discarded munitions would result in an inherently unsafe situation due to the particle reduction step. The exemption from TCLP is unwarranted because generators can apply their knowledge.
 
10/01/1990REGULATORY STATUS OF PETROLEUM CONTAMINATED MEDIA AND DEBRIS UNDER THE TOXICITY CHARACTERISTIC UST TEMPORARY DEFERRALQuestion & Answer
 Description: The Section 261.4(b)(10) exclusion applies to media and debris from UST corrective action. The exclusion does not apply to sludge removed from UST during remediation. The exclusion does not apply to media and debris that exhibit the toxicity characteristic for D003-D017.
 
08/25/1989CLARIFICATION ON THE SCOPE OF K088Memo
 Description: K088 only applies to the carbon portion of the aluminum potliner inside an electrolytic reduction cell. Other portions of the pot containing "significant levels of free cyanide" may be reactive (D003).
 
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)).
 
02/22/1989REGULATORY STATUS OF SOLVENT, “ULTIMA-GOLD”Memo
 Description: Unused solvent is only subject to regulation as a discarded material when abandoned (i.e., disposed or incinerated) or recycled by being burned for energy. A CCP that is abandoned is a solid waste, while a CCP being reclaimed is not a solid waste. The transportation and sale of unused solvent, Ultima-Gold, is not subject to Subtitle C because it is a product rather than a discarded material. The material safety data sheet for solvent product "Ultima-Gold" indicates potential to be corrosive (D002) and reactive (D003). The product "Ultima-Gold" does not exhibit ignitability (D001) or extraction procedure (EP) toxicity (SUPERSEDED: See 261.24). A product solvent only meets P-listing or U-listing if the chemical on the P-list or U-list serves as the product's sole active ingredient.
 
11/04/1988GENERATION AND TREATMENT OF K044 WASTEMemo
 Description: K044 (listed solely for exhibiting a characteristic) that no longer exhibits the reactivity characteristic after being treated in a facility’s wastewater treatment system is no longer K044, but must be designated as a hazardous waste if it exhibits another characteristic (SEE ALSO: 268.3; 66 FR 27266; 5/16/01).
 
09/19/1988QUESTIONS AND ANSWERS REGARDING THE HANDLING OF EXPLOSIVES AND COMMERCIAL FUELSMemo
 Description: Off-specification fuel (i.e., jet fuel, kerosene, gasoline) used to burn planes during a fire training exercise is not subject to regulation. The resulting soil contamination may later be subject to federal cleanup authorities. Law enforcement agents (BATF) transporting and detonating bombs and other reactive wastes may be exempt from RCRA Subtitle C regulation if the action is an immediate response. If it is not an immediate response, an emergency permit may be required (SEE ALSO: 62 FR 6622; 2/12/97). Dropping munitions on land and detonating bombs is not discard and is not regulated because it is the normal pattern of use. Unexploded ordnance or bullets removed from a firing range and sent for destruction via open burning/open detonation (OB/OD) are wastes subject to regulation. The open burning of hazardous waste (other than explosives) is prohibited (SEE ALSO: 62 FR 6622; 2/12/97).
 
09/13/1988REACTIVE WASTE - EXPLOSIVITYMemo
 Description: Reactive characteristic hazardous wastes (D003) fall under DOD Hazard Classes 1.1, 1.2, and 1.3, not 1.4.
 
06/02/1988DISCARDED CLASS C EXPLOSIVESMemo
 Description: Only class C explosives designated as off-specification small arms ball ammunition (=.50 caliber) are not reactive (D003). Any other class C explosives, including small arms non-ball ammunition, may be hazardous waste. The generator is responsible for characterization.
 
03/24/1988REGULATORY STATUS OF ECOSCINT A AND ECOSCINT OMemo
 Description: Liquid scintillation cocktails Ecoscint A and O are not listed, EP (extraction procedure) toxic (SUPERSEDED: See 261.24) or ignitable (D001), but data provided are not sufficient to make corrosivity (D002) or reactivity (D003) determination (SEE ALSO: RPC# 3/1/89-04). The generator is responsible for the hazardous waste determination.
 
02/10/1988RESIDUALS GENERATED BY PROCESS FOR SEWAGE SLUDGE TREATMENTMemo
 Description: The generator of residuals from treating sewage sludge must determine if the residuals are characteristic hazardous waste. The determination can be made by testing or by applying knowledge of the materials and processes. EPA does not endorse or support specific processes.
 
12/07/1987HYDROGEN SULFIDE WASTE IN SURFACE IMPOUNDMENT - REACTIVITY CHARACTERISTICMemo
 Description: Addresses the narrative definition for reactive sulfide waste. Discusses interim guidance that wastes releasing more than 500 mg H2S/Kg of waste should be considered hazardous for the reactivity characteristic (D003) (SUPERSEDED: see RPC# 4/21/98-01).
 
11/30/1987DETONATING EXPLOSIVE WASTESMemo
 Description: The detonation of seized explosives for disposal rather than for use constitutes discarding, so explosives must be managed as solid wastes (SW). If the explosives are characteristic for reactivity (D003), Subtitle C regulations apply to these Bureau of Alcohol, Tobacco, and Firearms (BATF) activities. Seized explosives must be managed as SW and potentially hazardous waste from the moment the decision is made to destroy the explosives. The detonation of reactive waste is thermal treatment.
 
09/16/1987SW-846 METHODS MANUALMemo
 Description: The use of SW-846 methods is generally not required except for quality assurance/quality control procedures and determining if the waste is characteristic. Discusses sampling, analysis for delisting petitions, incinerator trial burns, and determining if bulk or containerized waste contains free liquids prior to disposal in a landfill.
 
09/01/1987AEROSOL PAINT AND SOLVENT CANS DEMONSTRATION OF REACTIVITYQuestion & Answer
 Description: An aerosol can emptied according to 261.7 is still hazardous waste if it exhibits the reactivity characteristic (D003) (SEE ALSO: RPC# 1/4/94-02).
 
08/12/1987WASTE CHARACTERIZATION: LITHIUM BATTERIESMemo
 Description: Lithium sulfur dioxide batteries tend to exhibit the reactivity characteristic (D003).
 
03/18/1987REACTIVE CHARACTERISTICS OF DISCHARGED LI/SO2 BATTERIESMemo
 Description: Based on the supplied data, EPA agrees that Li/SO2 (lithium-sulfur dioxide) batteries are unlikely to exhibit the reactivity characteristic when they are fully discharged to zero volts. Fully-charged and duty-cycle Li/SO2 batteries are reactive. The generator is responsible for the hazardous waste determination. The placement of ignitable (D001) or reactive (D003) waste into a landfill is prohibited unless it is treated, rendered, mixed before, or immediately after, placement in the landfill so that it is no longer characteristic (SEE ALSO: Part 268).
 
03/11/1987SCINTILLATION COUNTING COCKTAILMemo
 Description: The liquid scintillation cocktail, Bio-Safe II, does not appear to be a hazardous waste, provided that it is not reactive (D003) or corrosive (D002), since it is not ignitable (D001) and does not exhibit the toxicity characteristic (D018-D043). Neither scintillation cocktails, nor lab wastes in general, are listed (SEE ALSO: RPC# 3/1/89-04). Hazardous waste identification is the generator's responsibility.
 
03/06/1987AUTOMOTIVE FLUIDS, REGULATION OFMemo
 Description: Automotive fluids are not listed hazardous waste, but they may be characteristic. Some brake and automatic transmission fluids are ignitable (D001). Used crankcase oil may be ignitable and may exhibit EP (extraction procedure) for lead (SUPERSEDED: see 261.24). Used oil (UO) that is recycled by burning is subject to 266 Subpart E; other UO recycling is exempt (SUPERSEDED: see Part 279). Brake fluid, power steering fluid, and automatic transmission fluid would all be considered UO. Antifreeze and windshield wiper fluid are not UO (SEE ALSO: 279.1).
 
03/06/1987AUTOMOTIVE FLUIDS, STATUS OFMemo
 Description: Automotive fluids are not listed hazardous waste, but they may be characteristic. Some brake and automatic transmission fluids are ignitable (D001). Used crankcase oil may be ignitable and may exhibit EP (extraction procedure) for lead (SUPERSEDED: see 261.24). Used oil (UO) that is recycled by burning is subject to 266 Subpart E; other UO recycling is exempt (SUPERSEDED: see Part 279). Brake fluid, power steering fluid, and automatic transmission fluid would all be considered UO. Antifreeze and windshield wiper fluid are not UO (SEE ALSO: 279.1).
 
03/03/1987ASH RESIDUE GENERATED FROM INCINERATION OF K045Memo
 Description: The mixture rule exclusion applies only to mixtures of solid waste (SW) and hazardous waste listed solely for characteristic, not residues from treating wastes listed for characteristic. K045 incineration residue is K045 even if the ash is not reactive (SEE ALSO: 66 FR 27266; 5/16/01).
 
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.
 
01/17/1986SPENT IRON SPONGE REGULATION AND TREATMENTMemo
 Description: A spent iron sponge which produces more than 500 mg/kg hydrogen sulfide is reactive (D003) (SUPERSEDED: see RPC# 4/21/98-01).
 
10/21/1985EP TOXICITY TEST EXTRACTION MEDIUM, REQUESTED CHANGE INMemo
 Description: The extraction medium in the extraction procedure (EP) (SUPERSEDED: see 261.24) may not be appropriate for determining the hazardousness of oil shale. A listing process may be used if the data indicates a sufficient threat.
 
07/16/1985SULFIDE REACTIVITY CHARACTERISTICMemo
 Description: There is no approved test method for the reactivity characteristic (D003). 500 mg/kg available sulfide is adopted as the interim action level (SUPERSEDED: see RPC# 4/21/98-01). A surface impoundment which is a neutralization pond receiving only corrosive waste (D002) is exempt from groundwater monitoring.
 
07/12/1985INTERIM THRESHOLDS FOR TOXIC GAS GENERATION REACTIVITY (261.23(A)(5))Memo
 Description: EPA provides interim thresholds of 250 mg HCN/Kg and 500 mg H2S/Kg respectively for solid waste that merit designation as reactive hazardous waste (D003) per 261.23(a)(5) for their potential to release toxic cyanide and sulfide gases (SEE ALSO: RPC# 11/8/93-01) (SUPERSEDED: see RPC# 4/21/98-01).
 
06/30/1985RCRA METHODS AND QA ACTIVITIES (NOTES)Memo
 Description: A discussion of metal determination in groundwater (total recoverable, dissolved metals). Organic determinations are made only on groundwater samples that have not been filtered. An overview of dioxin method 8280. Discusses the performance audits on gas samplers (organic cylinder gases). An overview of Method 3540 validation. Discusses the reactivity test methods.
 
12/20/1984RCRA METHODS AND QUALITY ASSURANCE ACTIVITIES (NOTES)Memo
 Description: The RCRA Laboratory Evaluation Program is outlined. The rationale for the proposal of standard methods for testing groundwater at hazardous waste facilities is discussed (49 FR 38786; 10/1/84). The analytical report on Method 3030 - acid digestion of oils, greases, and waxes as well as the Waste Analysis Plans Guidance Manual, including “boundary conditions” and “tolerance limits,” are discussed. The U.S. Gap Test and U.S. Internal Ignition Test are under evaluation to determine if a solid waste is explosive.
 
11/30/1984SMALL ARMS AMMUNITION REACTIVITY, OFF SPECIFICATIONMemo
 Description: Off-specification small arms ammunition (ball and sport ammunition) is not a reactive hazardous waste (D003).
 
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).
 
09/11/1984BLASTING CAPS AS REACTIVE WASTESMemo
 Description: Off-specification blasting caps are reactive (D003). Note 5 in 2.1.3 of SW-846 incorrectly states that blasting caps in quantities less than 1000 are not hazardous waste.
 
09/04/1984RESPONSIBILITY OF GENERATOR IN HAZARDOUS WASTE DETERMINATIONSMemo
 Description: The applicability of hazardous waste regulations to SULFA-CHECK spent slurry is discussed. The suggested cyanide and sulfide concentrations for reactivity are less than 10 ppm (SUPERSEDED: see RPC# 4/21/98-01). A generator does not perform determinations in 261.11(a)(2) to classify a waste as hazardous, but rather uses the process established in 262.11 to make a hazardous waste determination.
 
06/04/1984CHEMICAL AGENTS GB, VX, AND HD AT MUNITIONS DISPOSAL FACILITYMemo
 Description: The chemical agents GB (isopropyl methyl phosphonofluoridate), VX (Ethyl-S-diisopropyl aminoethyl methyl phosphonothidoate), and HD (Bis-2-chloroethyl sulfide) are reactive (D003) due to gas/vapor emissions when mixed with water.
 
04/04/1984ANALYTICAL METHODS/EP TOXICITY TEST/REFERENCE STDS.Memo
 Description: The adjustment of pH during the extraction procedure (EP) toxicity test should be conducted with a pH meter, not pH paper (SUPERSEDED: see current 261.24). Extract digestion, testing manufactured articles that are structurally resistant to crushing, and methods evaluation are discussed. EPA is developing methods for ignitable (D001) solids (SEE ALSO: SW-846 method 1030 finalized in 6/13/97; 62 FR 32451), liquids with flash points less than 60 degrees C, and reactive gases - cyanide and sulfide. EPA is developing a “Waste Analysis Plans Guidance Manual.” The use of reference standards is discussed.
 
03/07/1984REGULATORY STATUS OF SPENT/DISCARDED LITHIUM-SULFUR DIOXIDE BATTERIESMemo
 Description: Lithium-sulfur dioxide batteries (battery) clearly exhibit the characteristic of reactivity (D003) because of their potential to generate toxic gas. There is insufficient information to make a blanket determination for all lithium batteries. There is no determination whether lithium batteries with other cathode materials (e.g., thionyl chloride, polycarbon monofluoride, manganese dioxide, iodine, silver oxide, silver chromate, vanadium pentoxide, iron sulfide, copper oxide, and lead bismuthate) are reactive.
 
06/08/1983POPPING FURNACES-DOD DISPOSAL OF OUTDATED ORDNANCE BY INCINERATION - METALS RECOVERYMemo
 Description: An outdated ordnance is reactive (D003). The primary purpose of “popping” furnaces used by the DOD to dispose of waste ordinances is waste disposal, not metal recycling. Therefore, the furnaces are not exempt under 261.6, unless they can substantiate a claim of recycling (SUPERSEDED: 50 FR 614; January 4, 1985).
 
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.
 
01/01/1983REGULATORY STATUS OF UNIT AND WASTE IF NONHAZARDOUS WASTE BECOMES REACTIVE WHEN DEWATEREDQuestion & Answer
 Description: Nonhazardous wastewater that becomes reactive (D003) when it is dewatered may cause a surface impoundment to be subject to regulation unless the waste is immediately removed.
 
12/01/1982USING LEASED PROPERTY AS BUFFER ZONEQuestion & Answer
 Description: Owners or operators of facilities that use leased property as part of the 50 foot buffer zone for containers holding ignitable (D001) and reactive (D003) wastes should ensure that the lease will continue in force if the land is sold. The Part B permit should note that part of the buffer area is leased.
 
05/02/1980Reactivity Characteristic (40 CFR 261.23); Identification and Listing of Hazardous Waste Under RCRA, Subtitle C, Section 3001Publication
 Description: This document explains EPA's definition of reactive wastes, discusses the comments received on the proposed definition of reactive waste, and the subsequent changes made.
 
01/10/1980APPLICABILITY OF 40 CFR 261.5 TO K047Memo
 Description: K047 (pink/red water from TNT operations) is listed for its potential to dewater over time and become reactive.
 
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