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02/26/2014COMPLIANCE WITH THE STORAGE REQUIREMENTS OF 40 CFR 265.17(A) AND 265.176 FOR IGNITABLE OR REACTIVE HAZARDOUS WASTEMemo
 Description: A large quantity generator (LQG) must comply with both 40 CFR 265.17(a) and Part 265, Subpart I, including the 50 foot boundary requirement for containers holding ignitable and reactive hazardous waste in 265.176. Section 265.176 is taken from the National Fire Protection Association’s (NFPA) Flammable and Combustible Code of 1977 (NFPA 30). If a LQG is able to comply with 265.17(a) but unable to comply with the 50 foot boundary requirement for the accumulation of ignitable and reactive hazardous waste in 265.176, EPA recommends that the generator work with the EPA regional office or state inspector to determine if the local fire department or fire marshal will provide a written waiver from having to comply with the 50 foot boundary requirement.
 
11/04/2011CONTAINERS THAT ONCE HELD P-LISTED PHARMACEUTICALSMemo
 Description: For generators that are managing containers that held P-listed commercial chemical products and that are not RCRA empty per 261.7, three suggestions are provided on how to manage the residues remaining in the containers. First, it is only the weight of the residue in the container that needs to be counted toward generator status; the weight of the container does not need to be counted toward generator status (SEE ALSO: Memorandum, November 1, 1983 (RO 12151)). In some cases, we anticipate that this interpretation will mean that some healthcare facilities that have been counting the weight of the container and therefore managing their hazardous waste in accordance with the LQG standards will now be able to manage their hazardous waste in accordance with the CESQG standards of 40 CFR 261.5. Second, a generator can demonstrate that containers are "RCRA empty" in accordance with 261.7(b)(3)(ii), which allows a container that held an acute hazardous waste to be considered "RCRA empty" if it has been cleaned by a method (other than triple rinsing) "that has been shown in the scientific literature, or by tests conducted by the generator, to achieve equivalent removal." In the absence of scientific literature, a generator would need test data to show that it has achieved an equivalent removal method. ""Bag beating"" is an equivalent removal method to triple rinsing only for paper bags and not for other types of containers (SEE ALSO: Memorandum, May 20, 1985 (RO 12407)). Third, for containers that held warfarin, a generator could conduct analysis on the warfarin residues remaining in a fully dispensed container and, if the concentration of the residues is =0.3% warfarin, then the residues would not meet the listing description for the P-listed waste, even if the pills originally in the container did meet the listing description. Instead, the residues remaining in the container would be regulated as U248 hazardous waste.
 
11/03/2011CLOSED CONTAINER GUIDANCE: QUESTIONS AND ANSWERSMemo
 Description: For typical containers, such as 55 gallon drums, EPA recommends that a container cover be properly secured with snap rings tightly bolted, bungholes capped, and, where appropriate, pressure-vacuum relief valves to maintain the container’s internal pressure to avoid explosions. EPA generally considers a container accumulating free liquids or liquid hazardous wastes to be closed when all openings or lids are properly and securely affixed to the container, except when wastes are actually being added to or removed from the container. Containers holding free liquids or liquid hazardous wastes in an SAA would meet the regulatory definition of closed using manually or spring closing lids or other similar devices for closed-head or closed-top drums (e.g., containers that have two bung holes with non-removable lids). Funnels used to add or remove liquid wastes would be screwed tightly to the bunghold and fitted with a gasket, if necessary, to seal the funnel lid firmly closed. Funnel lids for closed-head and closed-top drums may be fitted with a locking mechanism. Alternatively, the generator may use a funnel with a one-way valve that allows hazardous waste to enter the container but prohibits the waste or emissions from exiting the container. Liquid hazardous wastes also can be accumulated in open-head drums or open-top containers (e.g., where the entire lid is removable and typically secured with a ring and bolts or snap ring) and meet the definition of closed provided the rings are clamped or bolted to the container. The container could be considered closed if the lid covers the container top securely. For solid and semi-solid hazardous wastes, EPA considers the container closed as long as there is complete contact between the lid and the rim all around the top of the container. Containers continuously or intermittently receiving solid or semi-solid wastes (e.g., under a baghouse or filter press) should be capable of catching and retaining all of the material during transfer from a device to the container. Containers with covers opened by a foot pedal (e.g., flip-top or spring loaded lid) or with a self-closing swinging door may also be appropriate. For other types of containers, EPA considers them closed when they are sealed to the extent necessary to keep the hazardous waste and associated air emissions inside the container. Large roll-off containers are closed when indoors and the lids and shut and have a good seal around the rim. Large roll-off containers are closed when outdoors and the tarp is closed. EPA grants discretion to inspectors and enforcement staff to allow a container to remain open for extended periods of time if it is necessary to do so to make sure that all of the hazardous waste from the device is captured. Where the deposition of hazardous-waste into containers is a "batch process," a container of hazardous waste must be kept closed during times when the process is not depositing hazardous waste into the container. Strapping containers together should be strapped together only if this can be achieved without rendering any significant portion of the containers inaccessible for inspection.
 
02/13/2007SAFE DELIVERY SYSTEMS (SDS) GAS CYLINDERSMemo
 Description: SDS cylinders contain a carbon-based medium which operates as a “molecular sieve” in which the gas is adsorbed and trapped within the interstitial spaces. As a result, the gas is stored under sub-atmospheric pressure, which avoids safety concerns with high-pressure containment and also allows a greater volume of gas to be stored in the container. The storage and delivery cylinders are containers holding unused CCPs, rather than spent materials, and therefore are not subject to regulation under 40 CFR 261.2(c)(3) as spent materials. Containers that held unused CCPs and any residues generated from CCP recovery must undergo a new hazardous waste determination after the cylinders are emptied. Abandoned CCPs are solid wastes (40 CFR 261.2(i)), and if hazardous, are hazardous wastes.
 
04/12/2004POLICY ON THE MANAGEMENT OF RINSATE FROM EMPTY CONTAINERSMemo
 Description: Even though rinse water from an “empty” container may be non-hazardous, 261.7 does not exempt rinse water because rinse water is not a waste “remaining in” an “empty” container. When residue is removed from an empty container the residue is subject to full regulation under Subtitle C if the removal or subsequent management of it generates a new hazardous waste exhibiting any characteristics identified in Part 261, Subpart C. Rinsing an “empty” container with an agent containing solvent that would be listed when discarded would cause rinsate from an “empty” container to be listed due to the nature of the rinsing agent, not the nature of the waste being rinsed from the “empty” container.
 
03/17/2004FREQUENTLY ASKED QUESTIONS ABOUT SATELLITE ACCUMULATION AREASMemo
 Description: Summary of generator accumulation regulations. Both LQGs and SQGs may establish satellite accumulation areas (SAA). Waste in excess of 55 gallons or 1 quart of acute hazardous waste must be removed within three days. When a generator exceeds 55 gallons or 1 quart acute hazardous waste, the container must be dated. The generator must date container again when it is moved to central accumulation area. Three days means three consecutive days. There is no federal requirement that full containers of hazardous waste be removed from an SAA within three days of being filled. Generators may transfer hazardous waste between containers to facilitate storage, transportation, or treatment. Containers in SAAs do not have to comply with the air emission standards of Part 265 Subparts AA, BB, and CC. Inspections of SAAs are not required if SAA meets 262.34(c) requirements. Personnel working in SAAs not required to have training. It is permissible to have more than one waste in an SAA and more than one container of hazardous waste in an SAA. The regulations do not limit the total number of SAAs at a generator facility. Generators may not move hazardous wastes between SAAs. A single SAA may have multiple points of generation. Generators must include all hazardous waste in their SAAs in monthly quantities for determining their generator status. Containers attached to equipment discharging hazardous waste must comply with SAA regulations and is a point of generation. Small containers (vials or tubes) may be placed in properly labeled larger containers. (SEE ALSO: 75 FR 12989, 12994; March 18, 2010)
 
10/23/2003TREATMENT STANDARDS FOR MERCURY-CONTAINING DEBRISMemo
 Description: D009 mercury wastes have LDR treatment standards for low mercury and high mercury-inorganic subcategories. LDR treatment standards include specified technologies such as RMERC, commonly called retorting. Macroencapsulation and microencapsulation are alternative LDR treatment technologies for D009 debris and do not depend on mercury levels in the debris. If alternative treatment standards are not used, the waste is subject to the non-debris standards in 40 CFR 268.40. The definition of debris is located in 268.2(g). Intact containers of mercury (e.g., thermometers, batteries) are not debris (SEE ALSO: 57 FR 37194, 37225; 8/18/92). Intact containers mixed with debris must be removed and managed separately. Certain mercury-containing items may be universal waste (SEE ALSO: 70 FR 45508; 8/5/05). Mercury-containing CESQG and household hazardous waste is exempt from RCRA regulations. Retorters are capable of accepting mercury-containing debris with certain limitations and exceptions. Source separation involves removing mercury-contaminated material from debris. Macroencapsulation involves mixing waste with reagents and stabilization materials to produce a more stable waste form. Macroencapsulation uses surface coatings or jackets to reduce surface exposure to leaching media.
 
08/01/2003SMALL QUANTITY GENERATOR TREATMENT IN TANKSQuestion & Answer
 Description: Hazardous waste generators may treat waste on site in accumulation tanks or containers without a permit or interim status provided that they comply with applicable provisions in 40 CFR 262.34 and the treatment is not thermal treatment (SEE ALSO: 56 FR 10146, 10168; 3/24/86). A small quantity generator (SQG) performing on-site treatment in a tank only follows the special standards in 265.201 and not all of the Part 265, Subpart J requirements. Standards in 265.201 supplant Subpart J requirements for SQGs rather than supplement them. Part 265, Subparts I and J, including SQG tank standards in 265.201, apply whether a unit is used for treatment or accumulation. Authorized states can have more stringent requirements.
 
06/01/2003START DATES ON LARGE QUANTITY GENERATOR TANKSQuestion & Answer
 Description: A large quantity generator (LQG) accumulating hazardous waste in a tank must mark the tank with the date upon which the hazardous waste accumulation period begins. The requirement is not cited in 40 CFR 262.34(a)(2), but EPA intended for both tanks and containers to be marked with the accumulation start date (SEE ALSO: 51 FR 10146, 10160; 3/24/86). The requirement ensures that an LQG accumulates hazardous waste in accordance with the 90-day accumulation time limit.
 
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.
 
12/01/2001CABINETS AS SATELLITE ACCUMULATION AREASQuestion & Answer
 Description: Placing a label with the words "Hazardous Waste" on the outside of a cabinet may satisfy the satellite accumulation area marking requirements provided the cabinet meets the definition of container. As a satellite accumulation area, the cabinet must be located at or near the point of generation, must be under control of the operator of the process where the wastes are initially generated, and must be maintained in accordance with the container standards. If the cabinet does not qualify as a satellite accumulation area, each individual container within the cabinet would need to be managed in accordance with the satellite accumulation area provisions.
 
07/18/2000GENERATOR TREATMENT OF SOIL IN A CONTAINERMemo
 Description: Generators may treat wastes in accumulation tanks and containers as long as they comply with the provisions of 262.34. Generator treatment exemption may apply to treatment of hazardous waste cleanups (SEE ALSO: RPC# 10/14/98-01). Authorized state program may have more stringent requirements.
 
04/01/2000APPLICABILITY OF THE SUBPART CC LDR EXEMPTION TO SOILSQuestion & Answer
 Description: Tanks, containers, and surface impoundments storing soils that contain hazardous waste are eligible for land disposal restrictions (LDR) exemption from Subpart CC only when VOCs meet 268.40 numerical concentrations or when soil has been treated by treatment technology in 268.42(a) for organic hazardous constituents. Wastes treated to meet alternative soil treatment standards remain subject to Subpart CC.
 
10/23/1998PERMITTING OF CATALYZED ELECTROCHEMICAL OXIDATION PROCESSMemo
 Description: Non-thermal treatment process may qualify for generator exclusion from permitting provided the system meets the definition of a tank or container, complies with all applicable tank and container management standards, and treats waste generated on-site within the time periods specified in 262.34.
 
02/06/1998STATE OF UTAH REQUEST REGARDING STATUS OF HAZARDOUS WASTE MANAGEMENT UNITS LOCATED WITHIN A CONTAINMENT BUILDINGMemo
 Description: Whether or not tanks, containers, or miscellaneous units are located within a containment building does not change the regulatory status of those units. Containment building could satisfy secondary containment requirements for tanks or containers.
 
11/13/1997USE OF EMULSIFIERS WHEN RENDERING HAZARDOUS WASTE CONTAINERS EMPTYMemo
 Description: Introducing emulsifiers in solution with water into a container to prevent the vaporization of the heels or residues remaining in the container is not regulated hazardous waste treatment. Adding emulsifiers to ensure the safety of the persons removing the residues is part of the overall rinsing process. The rinsing process is not considered treatment as long as the intent is to remove the waste.
 
09/04/1997STATUS OF WASHWATERS FROM BARGE CLEANING OPERATIONSMemo
 Description: The regulatory status of washwater produced from the rinsing of barges that once contained petroleum or chemical products is best determined by an authorized state that is aware of site specific factors.
 
09/01/1997GENERATOR STORAGE OF USED OILQuestion & Answer
 Description: Containers and tanks storing used oil do not need to comply with Parts 264/265, Subparts I or J, provided the used oil has not been mixed with a hazardous waste. Units other than tanks or containers (e.g., surface impoundments) storing used oil must be permitted or operating under interim status.
 
08/01/1997EMPTY CONTAINERS DEVELOPING PRESSUREQuestion & Answer
 Description: Containers of pressurized gas are considered empty when they reach atmospheric pressure. EPA does not intend to regulate containers that experience an incidental rise in internal pressure due to ambient environmental conditions (i.e., a temperature increase caused by the sun).
 
05/13/1997LABELING REQUIREMENTS FOR UNIVERSAL WASTE BATTERIESMemo
 Description: Handlers of universal waste may place labels as prescribed in Section 273.34(a) on shrink-wrapped pallets of batteries rather than on each individual battery. A shrink-wrapped unit is a portable device (i.e., a container) for the purposes of Section 273.34(a). If the batteries show evidence of leakage or spillage after they have been shrink-wrapped, the shrink-wrapped unit must be placed in a container which can prevent release to the environment and the new container must be relabeled. Shrink-wrapped units may not meet DOT packaging specifications.
 
04/11/1997PAINT RECYCLINGMemo
 Description: Paint or coating remixed and used for its intended purpose is not a solid waste. If paint is discarded, the generator must make a hazardous waste determination. Discarded paints generally are not listed wastes, but they may exhibit characteristics such as ignitability or toxicity. Paint generated by a CESQG is not subject to federal regulation provided the waste is discarded at a facility meeting Section 261.5(f) or (g). Paint collected from households is exempt from regulation, even if the paint is subsequently discarded. Household hazardous waste (HHW) mixed with regulated hazardous waste in a collection program is regulated. Paint cans emptied under the empty container provisions are not subject to regulation because they do not hold regulated residues.
 
04/03/1997ATON BATTERIES AS DEBRISMemo
 Description: Intact containers are not debris. Mercury batteries that serve as aid to navigation (ATON) meet the definition of debris if they are deteriorated and ruptured, because they do not meet the definition of intact container. Batteries meeting the definition of debris can be treated in accordance with the alternative debris treatment standards. Non-debris mercury waste requires treatment by roasting or retorting (RMERC) or compliance with a TCLP standard.
 
04/01/1997GENERATOR STORAGE REQUIREMENTS FOR PART 266, SUBPART F, PRECIOUS METALSQuestion & Answer
 Description: Generators accumulating recyclable materials for precious metal recovery are not required to store the materials in RCRA-regulated accumulation units (i.e., tanks, containers, and containment buildings). EPA assumes these materials will be managed carefully due to their economic value. Precious metals being reclaimed must be counted towards generator monthly determination.
 
04/01/1997TREATMENT STANDARDS FOR D008 RADIOACTIVE LEAD TANKS AND CONTAINERSQuestion & Answer
 Description: D008 radioactive lead solids that are tanks or containers must be treated using macroencapsulation. The placement of waste in a container or tank is not considered macroencapsulation. The owner/operator may use an alternative treatment method if demonstrated to be an equivalent technology.
 
02/01/1997DELAY OF CLOSUREQuestion & Answer
 Description: Owners and operators of hazardous waste surface impoundments, landfills, and land treatment units can delay the closure timetable beyond the 90-day period and allow the units to accept nonhazardous waste, if the units meet the conditions of Sections 264.113(d)/265.113(d). Owners or operators of tanks, containers, waste piles, and incinerators are not allowed to delay closure. These units must comply with all applicable closure standards before being able to accept nonhazardous waste.
 
11/26/1996USE OF ALUMINUM CAP LINERS INSTEAD OF TEFLON FOR SOIL SAMPLE CONTAINERSMemo
 Description: Aluminum cap liners may be used instead of teflon for soil sample containers. One must demonstrate that the samples do not contain constituents that corrode the aluminum cap liners.
 
11/20/1996HAZARDOUS WASTE CONTAINER STORAGE REQUIREMENTSMemo
 Description: Containers of hazardous waste must be kept closed when not in use. Safety Kleen will distribute replacement rings for containers which are difficult to close and that have been sold to their customers.
 
09/23/1996APPLICABILITY OF RCRA REGULATIONS TO CHEMICAL FLOCCULATION UNITS WHEN USED TO TREAT WASH WATER FROM AIRCRAFT ENGINESMemo
 Description: A chemical flocculation unit treating cadmium contaminated wash water requires a hazardous waste treatment permit, unless the unit meets an exemption. If the unit is a tank meeting the definition of a wastewater treatment unit (WWTU), or a tank or container regulated as a generator accumulation unit, the unit is exempt from permitting. Treatment sludge generated in the unit must be managed as a hazardous waste if it exhibits a characteristic. Land disposal restrictions (LDR) apply to the treatment sludge and the original wash water.
 
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.
 
01/26/1996LAND DISPOSAL RESTRICTIONS; PHASE IV SUPPLEMENTAL PROPOSAL ON MINERAL PROCESSING WASTESMemo
 Description: The Phase IV Bevill proposal (61 FR 2338; 1/25/96) would clarify the distinction between in-process materials and wastes in the Bevill exemption for mining and mineral processing wastes. The notice proposes retaining the TCLP and the classification of several wastes, including five smelting wastes that were previously lifted, iron chloride waste acid, and wastes from lightweight aggregate production. The notice proposes to exclude processed scrap metal and shredded circuit boards that are destined for metal recovery and managed in containers. The notice proposes to significantly reduce the land disposal restrictions (LDR) paperwork requirements that apply to hazardous waste generally (SEE ALSO: Phase IV Final Rule, 63 FR 28556; 5/26/98).
 
10/12/1995CLARIFICATION OF TREATMENT, AS DEFINED AT 40 CFR SECTION 260.10, AS IT RELATES TO HAZARDOUS WASTE FUEL BLENDING ACTIVITIESMemo
 Description: Consolidation of compatible bulk or containerized wastes to facilitate efficient transportation or disposal is not treatment. Blending hazardous waste fuels to meet a specification is treatment and requires a permit.
 
09/19/1995EPA'S DETERMINATION ON WHETHER MACROENCAPSULATION PROCESS ADDRESSES THE REQUIREMENTS OF 40 CFR SECTION 268.45, TABLE 1Memo
 Description: The definition of “macroencapsulation” is different for radioactive lead solids and debris. Debris macroencapsulation may include a tank or container. Merely placing debris in a container is not “macroencapsulation” unless the container is of non-corroding material (stainless steel).
 
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.
 
06/30/1995CLARIFICATION OF REGULATORY LANGUAGE WITH RESPECT TO PERMITTED HAZARDOUS WASTE CONTAINER STORAGE FACILITIESMemo
 Description: Bare concrete can serve as a container storage pad for secondary containment. No regulatory definition of sufficiently impervious is available. Bare concrete is insufficiently impervious for primary containment when in continuous contact with waste (e.g., in surface impoundments or waste piles). Secondary containment regulations are performance standards that allow for the use of materials other than concrete or asphalt.
 
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.
 
01/01/1995THE LIQUIDS IN LANDFILLS PROHIBITION AND SORBED FREE LIQUIDSQuestion & Answer
 Description: Wastes which contain free liquids and are containerized may be treated with a nonbiodegradeable sorbent and placed in a landfill. A non- containerized waste containing free liquids must be treated without absorbents before landfilling. Discusses chemical stabilization v. absorption criteria.
 
12/05/1994CLARIFICATION OF REGULATION OF FUEL BLENDING AND RELATED TREATMENT AND STORAGE ACTIVITIESMemo
 Description: Eligibility for the Bevill exemption for cement kiln dust (CKD) residues is contingent upon the composition of the residue, not upon the purpose of burning waste. If no treatment or blending occurs, bulking, containerizing, consolidating, and de-consolidating are allowed at transfer facilities.
 
09/12/1994CLARIFICATION OF THE REBUTTABLE PRESUMPTION PROVISIONS CONTAINED IN THE RECYCLED USED OIL MANAGEMENT STANDARDSMemo
 Description: Documentation that a used oil contains halogens in excess of 1,000 ppm due to the unintentional mixing with residuals from "RCRA empty" containers is sufficient to rebut hazardous waste presumption.
 
09/02/1994APPLICABILITY OF A PROPOSED HAZARDOUS WASTE REGULATION TO CERTAIN DOE RADIOACTIVE MIXED WASTESMemo
 Description: One or more safety devices that is vented directly to the atmosphere may be used on a container. A safety device should not be used for planned or routine venting, and must remain in a closed sealed position, except in an unplanned event (SUPERSEDED: see 59 FR 62896, 62903; December 6, 1994).
 
09/01/1994CONTAINMENT BUILDINGS AS GENERATOR ACCUMULATION UNITSQuestion & Answer
 Description: Small quantity generators (SQGs) who accumulate waste in a containment building without a permit are subject to the more stringent standards of Section 262.34(a), including the 90 day time limit. SQGs who accumulate under Section 262.34(d) are limited to the use of tanks and containers.
 
05/09/1994REGULATORY REQUIREMENTS FOR ON-SITE TREATMENT OF OXYGEN BREATHING APPARATUS (OBA) CANISTERSMemo
 Description: Oxygen breathing apparatus (OBA) used by firefighters could qualify as exempt scrap metal when recycled. There is no need to determine if recycled scrap metal is a hazardous waste (HW). Emptying a steel OBA canister could be an exempt scrap steel recycling process if the canisters are to be recycled (SEE ALSO: 261.4(a)(13) exclusion for processed scrap metal). Emptying canisters to render them nonhazardous prior to disposal may be regulated treatment. HW canisters may be accumulated on-site without a permit under 262.34. Tanks meeting the wastewater treatment unit definition are exempt from permitting requirements.
 
02/16/1994ACCEPTABILITY UNDER THE RCRA LAND DISPOSAL RESTRICTIONS OF TWO METHODS OF MACROENCAPSULATION FOR MIXED WASTES AT ROCKY FLATSMemo
 Description: The definition of macroencapsulation entails the use of a jacket or inert inorganic material and not merely placement in a tank or container because of the void spaces between the debris and the container. Discusses possible placement with variance from treatment standard, equivalent method variance, or no-migration variance. Discusses the performance standards for immobilization technologies.
 
02/04/1994REGULATORY STATUS OF MERCURY BATTERIESMemo
 Description: Containers as debris. Mercury battery (batteries) carcasses containing hazardous waste liquid or sludge may be hazardous debris based on a case-by-case determination.
 
12/23/1993REQUIREMENTS FOR DISPOSAL OF DISCHARGED M-44 CYANIDE CAPSULES THAT ORIGINALLY CONTAINED A SODIUM CYANIDE PESTICIDEMemo
 Description: A person generating less than one kilogram of acute hazardous waste per calendar month is a CESQG. The weight of containers holding hazardous waste need not be counted towards the category limits. Both on- and off-site facilities managing a CESQG's acute hazardous waste must meet the criteria of 261.5(f)(3). There is no formal EPA approval needed in order to use alternative and equivalent method instead of triple rinsing when emptying containers holding acute hazardous waste. Cyanide-containing capsules can become empty and exempt according to 261.7.
 
11/10/1993REGULATORY STATUS OF BATTERY CARCASSESMemo
 Description: Intact containers are not debris. Because batteries are a type of container, battery carcasses are not debris and are not eligible for the alternate debris treatment standards.
 
11/01/1993CONTAINMENT BUILDINGS AS INDEPENDENT HAZARDOUS WASTE MANAGEMENT UNITSQuestion & Answer
 Description: A containment building is intended to be an independent hazardous waste management units. Existing tanks, containers, and drip pads do not need to be within a containment buildings. Containment buildings can serve as secondary containment for tanks.
 
11/01/1993GENERATOR MANAGEMENT OF HAZARDOUS WASTE AND THE 90-DAY TREATMENT EXEMPTIONMemo
 Description: The transfer of waste to different tanks or containers does not affect the 262.34 generator accumulation unit treatment exemption. Although treatment may remove the hazardous characteristic, land disposal restrictions (LDR) requirements still apply, including 268.7(a)(4).
 
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.
 
10/05/1993RESPONSE REGARDING NEEDLESTICK INJURIES IN THE SHARPS RECYCLING INDUSTRYMemo
 Description: EPA plans to update Disposal Tips for Home Health Care to emphasize that containers in which sharps are disposed should not be recycled.
 
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.
 
07/28/1993TRIPLE-RINSING REQUIREMENT APPLICABLE TO CONTAINERS HOLDING RESIDUES FROM THE INCINERATION OF ACUTE HAZARDOUS WASTESMemo
 Description: Incinerator ash and other residues from the treatment of P-listed acutely hazardous waste remain P-listed and acutely hazardous. Containers holding such residues must be rendered empty by triple rinsing. No formal EPA approval is necessary in order to use an alternative and equivalent method as a substitute for triple rinsing.
 
02/04/1993PURPOSE OF HOME HEATH CARE BOOKLETMemo
 Description: Containers that are made of recyclable materials that hold sharps (i.e., syringes and needles) cannot be recycled (SEE ALSO: 60 FR 33912; 6/29/95).
 
10/29/1992RECYCLING OF COKE BY-PRODUCT RESIDUESMemo
 Description: The use of open pits, or flat or low-walled concrete pads to store coke by-product residues is land disposal. Therefore, management of wastes in these units is not exempt under 261.4(a)(10). Wastes managed on the ground or in units constructed so that waste spills or is otherwise disposed are not exempt. Tanks, containers, and containment buildings are units that qualify for the recycling exclusion.
 
07/21/1992TREATING WASTES IN GENERATORS ACCUMULATION TANKS AND CONTAINERSMemo
 Description: Generators may conduct treatment of used oil (e.g., mixing characteristic used oil with another material to render the used oil nonhazardous) in accumulation tanks or containers without a permit or interim status provided that the units conform to the standards in Part 265, Subparts I or J, and 262.34.
 
05/01/1992LEAD USED AS SHIELDING IN LOW-LEVEL RADIOACTIVE WASTE DISPOSALQuestion & Answer
 Description: Lead and lead-lined containers used to dispose of low level radioactive waste are not solid wastes and are not regulated as mixed waste if their primary use is for shielding in the disposal operations.
 
10/22/1991INDUSTRIAL EQUIPMENT THAT FORMERLY CONTAINED HAZARDOUS WASTEMemo
 Description: An out-of-service pump that contains mercury could qualify as a container if it is portable. The empty container provisions in 261.7 may apply to a pump meeting the definition of container.
 
09/20/1991TREATMENT OF HAZARDOUS WASTE FROM LARGE QUANTITY GENERATORSMemo
 Description: Both LQGs and SQGs can treat in accumulation tanks or containers without a permit if the treatment is in compliance with the 262.34 generator accumulation requirements. Generators who accumulate waste in 262.34 units must comply with the waste analysis plan (WAP) requirements per 268.7(a)(4). Treatment in generator accumulation units cannot violate the dilution prohibition.
 
07/03/1991TCLP AND LEAD PAINT REMOVAL DEBRISMemo
 Description: Provides general guidance for the representative sampling of lead-based paint abatement wastes (debris and abrasives) from drums, roll off boxes, and other containers. Shipments of LBP abatement wastes from a field site (bridge repair) to a central accumulation point must generally be accompanied by a manifest. The central accumulation point must be a transfer facility or a TSDF to accept manifested hazardous waste. Generators conducting lead-based paint (LBP) abatement must test the wastes using TCLP unless they can apply knowledge to determine characteristics (SEE ALSO: 63 FR 70233, 70241; 12/18/98). If an LBP waste first tests nonhazardous in TCLP due to the masking effect of an iron abrasive but exhibits the characteristic prior to disposal, all hazardous waste regulations apply. LBP abatement wastes that are characteristic for lead may be stabilized on site during accumulation in tanks or containers without a permit.
 
05/21/1991COMPACTING HAZARDOUS WASTE INSIDE STEEL DRUMS AS TREATMENTMemo
 Description: Compacting hazardous waste in a steel drum is treatment if the reduction in volume results in a change in the physical, chemical, or biological character or composition of the waste. Compacting in generator accumulation containers would not require a permit.
 
04/30/1991LEAD SHIELDING FOR RADIOACTIVE WASTE IS A RCRA SOLID WASTEMemo
 Description: Clarification of when lead shielding for radioactive waste is solid waste. Lead containers or container liners are not solid wastes when radioactive waste is disposed of if the lead shielding continues to fulfill intended use after disposal of radioactive waste.
 
04/16/1991LAND DISPOSAL RESTRICTIONS APPLICABILITY TO INVESTIGATIVE DERIVED WASTEMemo
 Description: The temporary container storage of investigative-derived wastes within an area of contamination (AOC) followed by disposal within the original AOC does not trigger land disposal restrictions (LDR). The movement to separate storage and/or treatment area followed by replacement may trigger treatment. A single drum is not considered a unit. Drums and land on which drums are placed may constitute container storage areas.
 
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).
 
12/27/1990TREATMENT STANDARDS FOR CERTAIN MIXED RADIOACTIVE WASTESMemo
 Description: Merely placing waste in a tank or a container is not macroencapsulation (MACRO). A plastic or steel coating that provides reduction in surface exposure to leaching media, and jackets of inorganic materials are MACRO. Macroencapsulation does not comply with existing land disposal restrictions (LDR) standards for metals. Waste could be macroencapsulated and disposed of via a variance from a treatment standard, no-migration petition, or national capacity variance.
 
12/20/1990THIRD THIRD LAND DISPOSAL RESTRICTIONS FINAL RULEMemo
 Description: Lab packs going for incineration can be packed in fiber drums, not just metal drums. Discusses the definition of inorganic solid debris. Empty containers may be hazardous if characteristic. A treatment facility must support the determination that waste meets the treatment standard with analytical data. Piped transfers from a recycling facility to an off-site TSDF is subject to land disposal restrictions (LDR) notification (SEE ALSO: 62 FR 25997; May 12, 1997).
 
11/20/1990LDR RULES REGARDING ALTERNATIVE TREATMENT STANDARDS FOR LAB PACKSMemo
 Description: A person who incinerates lab packs may use fiber drums in place of metal outer containers. Fiber or wood boxes or other containers that do not meet the DOT specifications for fiber drums may not be used as outer containers for lab packs.
 
10/30/1990USED OIL FILTERS - REGULATION; USED OIL FILTERS, REGULATORY DETERMINATIONMemo
 Description: Crushing a filter to remove used oil (UO) is exempt if the removed UO is recycled (SUPERSEDED: see 261.6(a)(4) and 279.10(c)). Generally, used auto oil filters are not containers because they are not storing oil. Filters are not empty containers. A filter with UO removed is exempt scrap metal if it is recycled. Undrained, uncrushed filters have too much oil for the scrap metal exemption (SEE ALSO: 261.4(b)(13)). TCLP is performed on UO filters by crushing, cutting, or grinding filters and their contents until the pieces are smaller than one cm in the narrowest dimension. A characteristic UO filter that is sent for disposal is subject to regulation (SUPERSEDED: see 261.4(b)(13)).
 
09/13/1990EMPTY CONTAINERS REGULATORY STATUSMemo
 Description: In some instances, 261.7 allows an "empty" and unregulated container to hold up to one inch of hazardous waste (HW). The "one inch" criterion is not the sole factor governing whether or not a container is legally empty and exempt from regulation.
 
09/05/1990DEFINITION OF CONTAINER UNDER PART 259Memo
 Description: Discusses the regulated medical waste packaging requirements. A needle sheath for used sharps does not meet the Part 259 definition of container (SUPERSEDED: see 60 FR 33912; 6/29/95).
 
08/15/1990TANK TREATMENT PROCESSESMemo
 Description: Circuit board manufacturing wastes can be F006 if electroplating is involved. Anodizing is electroplating. Chemical conversion coating is a non-electrical process and is not anodizing or electroplating for F006, F007, F008, F009. Wastewater is defined only for the land disposal restrictions (LDR). Containers and tanks storing hazardous waste (HW) before an off-site shipment are not wastewater treatment units (WWTUs). EPA did not intend to include containers in the definition of ancillary equipment. Generator accumulation starts when the waste first enters the container. HW sludge that is removed from a WWTU is subject to full regulation. A unit can be both a WWTU and an elementary neutralization unit (ENU). A wastewater treatment sludge is anything that precipitates or separates during treatment. F006 may be formed in an exempt unit.
 
08/08/1990LAB PACKS - LAND DISPOSAL RESTRICTIONS ASPECTSMemo
 Description: P046, P111, and U163 may be incinerated in lab packs. Lab packs destined for incineration in fiber drums are not required to be placed in metal containers.
 
07/01/1990ADDING ABSORBENT TO WASTE CONTAINERSQuestion & Answer
 Description: An absorbent does not have to be added when the waste is first containerized to meet the absorbent exemption. Generators can accumulate waste in other containers before adding the waste to a container along with the absorbent.
 
06/24/1990NO TECHNICAL STANDARDS FOR SHARPS CONTAINERSMemo
 Description: Discussion of OSHA jurisdiction over medical waste management within facilities versus EPA jurisdiction over disposal. EPA has established performance standards for leak- and puncture-resistant containers, rather than test methods (SEE ALSO: 60 FR 33912; 6/29/95).
 
05/01/1990SAMPLE EXCLUSIONQuestion & Answer
 Description: The sample exclusion applies to listed and characteristic waste. The contained-in policy applies to laboratory equipment contaminated during waste testing. Pipets (or pipettes) can qualify as containers and be rendered empty under Section 261.7.
 
04/10/1990STEAM-SPRAYING OF AN EMPTY TANKMemo
 Description: If rinsing is conducted on non-empty container or to render container empty, rinsate is subject to all hazardous waste regulations. If a container empty per 261.7 is rinsed, the rinsate is exempt, including from requirement to determine if the rinsate is characteristic. (SUPERSEDED: see RPC# 4/12/04-02)
 
02/27/1990APPLICABILITY OF MEDICAL WASTE REGULATIONSMemo
 Description: Roll-off receptacles meet medical waste packaging requirements in 259.41(a), but not container requirements for sharps and fluids (e.g., single secondary receptacle). Each package must be labeled with shipment date. Discussion of paperwork requirements (SUPERSEDED: see 60 FR 33912; 6/29/95).
 
11/17/1989RECYCLING OF LEAD-ACID BATTERIESMemo
 Description: Restricted wastes, like lead-acid batteries, may be stored on the land in tanks or containers (i.e., land disposed) without meeting treatment standards if done solely to accumulate as necessary to facilitate proper recovery, treatment, or disposal. Storage must comply with all storage standards, such as secondary containment. the Battery shell (casing/housing) is the container (SEE ALSO: Part 273).
 
09/28/1989OFF-SPEC COMMERCIAL CHEMICAL PRODUCTS AT BOTTLING FACILITYMemo
 Description: Product solvent that is discarded because it was contaminated with another product while being containerized is an off-specification CCP and is a P-listed or U-listed waste if the solvent is listed in 261.33. RCRA waste codes and regulations applicable to wastes do not necessarily correspond to DOT hazardous material descriptions. Wwastes are defined as hazardous under RCRA, in part, based on characteristics, such as ignitability (D001) and corrosivity (D002).
 
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).
 
08/02/1989SATELLITE ACCUMULATION PROVISION, CLARIFICATIONMemo
 Description: The 55-gallon limit applies to the total of all non-acutely hazardous waste in a satellite accumulation area. There is no limit on total number of satellite accumulation areas at a facility. There is no specific size of containers required for satellite accumulation.
 
07/21/1989ACETONE AND METHANOL CONTAMINATED WASHWATERSMemo
 Description: When toluene is used as solvent in a production process and then recovered, trace quantities of toluene found in facility's washwaters are not normally F-listed spent solvents and do not render all facility wastewaters and sludges hazardous via the mixture rule. Using pure methanol and acetone as a drying agent to extract water from a product is solvent use, and resulting wastes are F003. If a product contains only F003 solvents before use, wastes from solvent use are F003. F003 that is nonignitable when generated is still F003 until mixed with solid waste and qualifies for 261.3(a)(2)(iii) mixture rule exemption (SEE ALSO: 66 FR 27266; 5/16/01). If a tanker truck holding P- and U-listed hazardous waste is rendered empty according to 261.7 (contents removed using "reasonable" means and less than one inch or 0.3% of tanker volume remains), water from subsequent rinsing is not regulated, even if it contains traces of P- or U-listed chemicals.
 
07/20/1989TRANSPORTERS MOVING WASTE FROM LARGE CONTAINERS TO SMALLER CONTAINERS AT TRANSFER FACILITIESMemo
 Description: A transporter repackaging waste from one container to another (e.g., consolidating) or mixing hazardous waste at a transfer facilities does not need a permit, unless the transporter is conducting treatment.
 
07/13/1989SATELLITE ACCUMULATIONMemo
 Description: Portable roll-off boxes meet the 260.10 definition of container and may be used for satellite accumulation as long as quantity limits, time limits, and other conditions of 262.34(c) are met. Any device meeting the definition of a container may be used for satellite accumulation.
 
06/05/1989REGULATORY STATUS OF RESIDUES REMOVED FROM EMPTY CONTAINERSMemo
 Description: Residues remaining in or removed from containers that have already been rendered "empty" according to 261.7 are not regulated. Such residues from empty containers are regulated if subsequent management (i.e., incineration) causes them to exhibit a new characteristic. (SEE ALSO: RPC# 4/12/04-02)
 
03/17/1989BERYLLIUM WASTE DUSTMemo
 Description: Solidified and containerized beryllium dust and other filtration elements collected by a vacuum hood and directed through a two stage filtration system are solid waste if they are abandoned by land disposal. The waste is not P015 or listed, but is hazardous if characteristic.
 
01/03/1989REGULATORY STATUS OF PERSONNEL PROTECTIVE EQUIPMENTMemo
 Description: Contaminated clothing and similar debris are not solid wastes, but may be regulated under the contained-in policy. If contamination cannot be removed, clothing must be treated to meet the land disposal restrictions (LDR) treatment standards prior to disposal. The empty container rule does not apply to contaminated clothing and personal protective equipment (PPE).
 
10/27/1988PESTICIDE RINSEATE TREATMENT/RECYCLING SYSTEMMemo
 Description: Tanks with no discharge because effluent is recycled or otherwise handled cannot be wastewater treatment units (WWTU). Tanks that have eliminated discharge of effluent as direct result of CWA rules and limits (zero dischargers) can qualify as WWTUs. Reclaimed wastewaters are generally not products. In certain cases, treated wastewater that is legitimately reused is considered "reclaimed" and loses its solid waste status. Listed rinsewater destined for filtering and reuse is a spent material and a solid waste prior to reclamation. Rinsing nonempty containers that held P-listed or U-listed pesticide CCPs renders rinsate listed hazardous waste.
 
09/30/1988AEROSOL CANS, ON-SITE DEPRESSURIZATION OFMemo
 Description: The region is in the best position to determine if aerosol cans are hazardous waste. Generally, cans are hazardous if they contain a listed or characteristic CCP and are not empty per 261.7 and/or if the cans themselves exhibit a characteristic. The region determines if depressurizing aerosol cans meets the definition of treatment. Waste aerosol cans generated in military housing are exempt household hazardous waste (HHW).
 
07/01/1988TANK REPLACEMENTQuestion & Answer
 Description: The replacement of a hazardous waste storage tank would not constitute final closure. There is no notification for the partial closure of a tank, container, or incinerator. While not specifically required, the tank and equipment should be decontaminated and the region or state implementing agency should be notified.
 
06/24/1988DRUM SHREDDER REGULATIONMemo
 Description: A drum shredder that processes containers filled with hazardous waste is a miscellaneous unit requiring a permit. Certain tank requirements may be appropriate for inclusion in the Subpart X permit.
 
06/01/1988HAZARDOUS WASTE TANKS/CONTAINERS - CAPACITY OF SECONDARY CONTAINMENTQuestion & Answer
 Description: A vault containing both tanks and containers must be able to contain 100% of the largest tank. If that volume is greater than 10% of the containers’ volume, then no additional capacity is needed. 110% capacity is not required.
 
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)).
 
04/19/1988CALL-IN OF STORAGE AND TREATMENT APPLICATIONSMemo
 Description: Pursuant to 3005(c)(2)(C), interim status treatment and storage facilities that were in existence on 11/8/84 must submit their Part B permit applications by 11/8/88, or their interim status will terminate on 11/8/92. A facility with only tanks, containers, or incinerators must submit a closure plan 45 days prior to the date that closure will begin.
 
04/19/1988CALL-IN OF STORAGE AND TREATMENT APPLICATIONS PRIOR TO 11/08/88 DEADLINEMemo
 Description: Pursuant to 3005(c)(2)(C), interim status treatment and storage facilities that were in existence on 11/8/84 must submit their Part B permit applications by 11/8/88, or their interim status will terminate on 11/8/92. A facility with only tanks, containers, or incinerators must submit a closure plan 45 days prior to the date that closure will begin.
 
02/02/1988CLOSURE REQUIREMENTSMemo
 Description: EPA recognizes the inconsistencies between the tank and container closure requirements and plans to revise Subpart I to ensure consistency. The 3/19/87 clean closure guidance (52 FR 8704) should be applied to closure by the removal of wastes from any RCRA unit. EPA plans to allow interim status and permitted landfills to defer closure to manage nonhazardous wastes. Characteristic waste must be managed as hazardous unless it no longer exhibits any of the four characteristics. Discusses the more protective clean closure action levels v. hazardous waste identification levels. Listed wastes and any waste residues or contaminated soil or debris removed during closure are hazardous unless delisted. The concentrations of total organic carbon (TOC) and total organic halogens (TOX) cannot be used to determine if decontamination wastewater is hazardous.
 
01/01/1988“LAB PACKS” AT GENERATOR SITESQuestion & Answer
 Description: A service company may act on behalf of a generator and re-package waste into larger containers (lab packs) with absorbents without a permit. Generators may treat in accumulation tanks or containers provided the treatment is not thermal treatment or incineration. The addition of absorbents to waste is exempt from permitting.
 
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).
 
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).
 
08/31/1987MIXTURES OF WASTES AND LEGITIMATE BURNING FOR ENERGY RECOVERYMemo
 Description: A sham recycling of waste by burning (less than 5000 Btu heating value) determination is site-specific. The blending of high and low Btu value waste may not render subsequent burning a sham (SUPERSEDED: RPC# 11/8/94-01; 266.100). A listed waste treatment residue retains its listing. EPA waste codes are not required on the manifest by EPA, but states or DOT may require them (SEE ALSO: RPC# 11/17/89-02).
 
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.
 
08/01/1987EXPORTING 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)
 
07/30/1987AIDS TO NAVIGATION (ATON) BATTERIES AND RCRA REQUIREMENTSMemo
 Description: Each ATON unit service area (landbased or tender vehicle) is a point of generation (ships as generators) that is subject to the applicable generator standards (SEE ALSO: Federal Facility Compliance Act (FFCA) section 3022)). Aids to navigation batteries (ATON) that are removed from service must be manifested. The location where the battery is removed from service is a waste generation site. Batteries may be held for up to 10 days at a transfer facility (SEE ALSO: Part 273). The entire aid to navigation (ATON) battery is counted in weight calculations. Each ATON unit service area (landbased or tender vehicle) is a point of generation that is subject to the applicable generator standards. The satellite accumulation area provisions do not apply to ATON service locations (SEE ALSO: Part 273).
 
07/29/1987TRD INDICATING THAT ETHANOL AND STAINLESS STEEL ARE COMPATIBLEMemo
 Description: Ethanol is compatible with stainless steel equipment used for tanks and containers.
 
07/01/1987ON-SITE TREATMENT BY GENERATORS UNDER 262.34Memo
 Description: Generators can treat in accumulation tanks or containers without a permit provided the treatment occurs in units complying with Subparts I or J of 265. Open burning in drums or tanks is not allowed under 262.34. Subparts I and J limit the type of treatment that can occur. Burning in open drums is not allowed because open burning (defined in 260.10) is a method of disposal. Open burning (thermal treatment) of waste, except for explosives, is prohibited under 265.382.
 
06/26/1987TREATMENT AND DISPOSAL METHODS FOR LOW-LEVEL WASTES THAT CONTAIN UNCONTAMINATED OR RADIOACTIVE LEADMemo
 Description: Activated lead may be stored to allow radioactive decay prior to disposal as a hazardous waste. Mixed waste storage requires a permit. Surface-contaminated lead may be decontaminated. EPA may establish below regulatory concern (BRC) levels for radiation. Container liners used as shielding in low-level waste disposal are not RCRA-regulated. Encapsulation may be a viable treatment for lead wastes if the process results in a product that will not degrade after disposal (SEE ALSO: 64 FR 63464; 11/19/99).
 
06/16/1987CONTAINERS 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.
 
04/15/1987EMPTY CONTAINER REGULATIONSMemo
 Description: Emptying containers per 261.7 requires that all wastes be removed from the container using commonly-employed emptying practices and that the container meets the "1 inch" or "3 percent" criterion. Containers that held P-listed products need triple rinsing.
 
04/09/1987F027 LISTING - USED AND UNUSED FORMULATIONS IN WOOD PRESERVINGMemo
 Description: In regards to the F027 listing, the word 'used' includes formulations that have contacted wood or which remain in a dip or process tank after preservation. The formulations do not have to be spent to be classified as used; even after one treatment, a formulation is considered to be used. Dipping a piece of wood in a container of unused preservative in order to claim it as used is sham use.
 
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 .
 
03/04/1987FOUNDRY SANDS RECYCLED AND RETURNED TO THE FOUNDRYMemo
 Description: Foundry sands that are accumulated for 90 days or less in tanks or containers prior to recycling are subject to 262.34. A storage permit is required if the foundry sands are stored on site for greater than 90 days.
 
02/11/1987SATELLITE ACCUMULATION AREA AND REGULATIONSMemo
 Description: A generator may accumulate up to 55 gallons of hazardous waste, or one quart of acutely hazardous waste, at a satellite accumulation area. EPA believes that only one waste would normally be accumulated at each area. There is no limit to the number of satellite areas at a generator site. A container in a satellite area does not have to be a specific size. There is no limit on the number of containers at a satellite area.
 
02/01/1987LAND DISPOSAL RESTRICTIONSQuestion & Answer
 Description: The one-year storage prohibition period for a generator with interim status for storage begins on the date when waste is first placed in the tank or container. An owner/operator bears the burden of proof for storing waste longer than one year. Wastes initially accumulated prior to the land disposal restrictions (LDR) are not subject to storage prohibitions.
 
12/31/1986SPECIAL MATERIALS DISPOSED OF IN LANDFILLS: BATTERIES, CAPACITORS, LAB PACKSMemo
 Description: Batteries and capacitors are exempt from the landfill containerized liquid requirements. They do not need to be 90% full, crushed, or shredded before disposal (SEE ALSO: Part 273).
 
12/22/1986GENERATOR TREATMENT IN ACCUMULATION TANKS AND CONTAINERSMemo
 Description: Generators can treat hazardous waste in accumulation tanks or containers without a permit, provided treatment performed strictly in accordance with 262.34.
 
12/22/1986TREATMENT OF HAZARDOUS WASTE IN A GENERATOR'S ACCUMULATION TANKS AND CONTAINERSMemo
 Description: Generators can treat hazardous waste in accumulation tanks or containers without a permit, provided treatment is performed strictly in accordance with 262.34.
 
12/05/1986TREATMENT IN ACCUMULATION TANKS AND CONTAINERS ALLOWED FOR ALL GENERATORS SUBJECT TO 262.34Memo
 Description: All generators accumulating waste in compliance with 262.34 may treat waste in on-site tanks and containers.
 
12/01/1986LAND DISPOSAL RESTRICTIONS - LAND DISPOSAL DEFINITION, LAB PACKS, CONDITIONALLY EXEMPT SQG WASTE, EMPTY CONTAINERSQuestion & Answer
 Description: An explanation of the section 3004(k) definition of land disposal. Because open burning and open detonation (OB/OD) are not land disposal, the land disposal restrictions (LDR) program does not apply to open burning/open detonation. The placement of wastes in vaults/bunkers for disposal is land disposal. If a lab pack contains a restricted waste, the entire lab pack is subject to the land disposal restrictions (LDR). CESQG waste is not subject to the land disposal restrictions (LDR). A container emptied in accordance with section 261.7 is not subject to the land disposal restrictions (LDR).
 
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.
 
08/28/1986SOLVENT-LADEN CLEANING RAGS UNDER RCRAMemo
 Description: EPA is considering a petition to exempt solvent-contaminated shop towels and disposable industrial wipers from the definition of hazardous waste under the mixture rule (SUPERSEDED: see RPC# 2/14/94-01). Evaporation in a generator accumulation container is not exempt as a condition of the exemption is that containers remain closed except to add or remove waste (SEE ALSO: Part 264/Part 265, Subpart CC).
 
07/25/1986PERMITTING OF TREATMENT ACTIVITIES IN A GENERATOR'S ACCUMULATION TANKS OR CONTAINERSMemo
 Description: All generators accumulating waste in compliance with section 262.34 may treat in on-site tanks and containers. Treatment in other units requires permit. EPA does not distinguish between accumulation for handling other than treatment and accumulation for the sole purpose of treatment.
 
06/17/1986PERMITTING OF TREATMENT ACTIVITIES OCCURRING IN A GENERATOR'S ACCUMULATION TANKS OR CONTAINERSMemo
 Description: Detailed discussion of the EPA policy allowing generators to treat hazardous waste in accumulation tanks or containers without obtaining a permit or interim status (SEE ALSO: 51 FR 10168; 3/24/86). If a facility has interim status, and should withdraw permit application, Region or State will determine residual interim status obligations (e.g., closure requirements).
 
05/23/1986USED X-RAY FILMSMemo
 Description: Based on trade association data, x-ray film does not appear to be hazardous waste (HW). Nonetheless, each generator is responsible for making this determination. If HW x-ray film is sent for precious metal recovery, the generator must manifest the waste and get an D number.
 
05/01/1986TREATMENT WITHOUT A PERMITQuestion & Answer
 Description: Dilution is treatment, but the treatment in an accumulation tank or container under section 262.34 does not require a permit (SEE ALSO: 268.3, 268.7(a)(4)). A characteristic waste treated so it no longer exhibits a characteristic can be disposed of in a Subtitle D landfill (SEE ALSO: 268.9).
 
04/28/1986COMMERCIAL CHEMICAL PRODUCTS, RECYCLING A MIXTURE OFMemo
 Description: CCPs or mixtures of CCPs (e.g., methyl isocyanate and methylene chloride) reclaimed or used for their intended purpose (e.g., in manufacturing process) are not solid waste, and are not regulated. The mixture does not need to be manifested and the receiving facility does not need a storage permit.
 
04/16/1986ACCUMULATION AND TREATMENT OF WASTES ON-SITE/PERMIT REQUIREMENTSMemo
 Description: A generator who solidifies or fixes hazardous waste in an accumulation tank or container does not need a permit or interim status.
 
04/07/1986ENVIRONMENTAL RELEASES FROM WOOD PRESERVING PLANTSMemo
 Description: A summary of EPA regulations applicable to releases from wood preserving facilities. The wood preserving process wastewater effluent is subject to the CWA (SEE ALSO: 261.4(a)(9)). The storage or mixing tanks, kraft bags can be empty containers under section 261.7. Discusses the applicability of the F020, F021, F026, F027 listings. Dioxin wastes are acutely hazardous and are subject to the 1 kg threshold. Wastewater treatment sludges from creosote and pentachlorophenol (PCP) are K001. An explanation of the closure of units used to treat these process wastewaters. The applicability of the EP (extraction procedure) toxicity characteristic (SUPERSEDED: see 261.24) to wood preserving wastes. A discussion of section 3004(u) and (v) corrective action at wood preserving facilities.
 
04/07/1986WOOD PRESERVING AND SURFACE PROTECTION FACILITIES, CONTROLLING ENVIRONMENTAL RELEASES FROMMemo
 Description: A summary of EPA regulations applicable to releases from wood preserving facilities. The wood preserving process wastewater effluent is subject to the CWA (SEE ALSO: 261.4(a)(9)). The storage or mixing tanks, kraft bags can be empty containers under section 261.7. Discusses the applicability of the F020, F021, F026, F027 listings. Dioxin wastes are acutely hazardous and are subject to the 1 kg threshold. Wastewater treatment sludges from creosote and pentachlorophenol (PCP) are K001. An explanation of the closure of units used to treat these process wastewaters. The applicability of the EP (extraction procedure) toxicity characteristic (SUPERSEDED: see 261.24) to wood preserving wastes. A discussion of section 3004(u) and (v) corrective action at wood preserving facilities.
 
03/26/1986ABOVE-GROUND LAND EMPLACEMENT FACILITIES, N.J. LAWMemo
 Description: Above ground long-term storage or disposal is land disposal. Section 3004(c)(1) prohibits the addition of absorbent to bulk liquid hazardous waste for disposal in a landfill. Section 3004(c)(2) allows the addition of non-biodegradable absorbent to containerized hazardous liquid (SEE ALSO: RPC# 11/17/93-02), current 264.314, 265.314).
 
02/12/1986UNRINSED CONTAINERS WHICH FORMERLY CONTAINED AN UNUSED FORMULATION OF PENTACHLOROPHENOLMemo
 Description: Discussion of the treatment, storage, and disposal options for dioxin wastes. An unrinsed container which contained unused pentachlorophenol (PCP) is F027 subject to all regulations applicable to acute hazardous waste (HW). Residues from the incineration of an acute HW remain acutely hazardous (SUPERSEDED: See F028 listing in 261.31). Incinerators burning dioxin wastes must meet 99.9999% Destruction and Removal Efficiency (DRE).
 
01/21/1986CONTAINERS STORING HAZARDOUS WASTE, REQUIREMENTSMemo
 Description: There are no specific container design requirements, instead there are general performance standards. Containers that meet the DOT standards are acceptable hazardous storage containers. Manufacturers of containers cannot obtain a permit in lieu of the facility owner or operator.
 
01/07/1986EMPTY CONTAINER RULE APPLIED TO TANKER OR VACUUM TRUCKSMemo
 Description: The section 261.7 definition of “empty” applies to tanker vehicles/trucks as well as containers. Trucks emptied by normal means and with less than one inch or equivalent volume remaining are empty.
 
01/07/1986RESIDUES REMAINING IN EMPTY CONTAINERS, BURNING OFMemo
 Description: The burning of residues in empty containers is not hazardous waste incineration. Ash from burning residues is not hazardous.
 
12/12/1985EMPTY TANK CARS THAT CONTAINED COMMERCIAL CHEMICAL PRODUCTMemo
 Description: Tank cars are containers. Residues rinsed from empty tank cars are not hazardous waste. Rinsewaters are exempt unless characteristic. (SEE ALSO: RPC# 4/12/04-02)
 
12/03/1985REQUIREMENTS FOR CHANGING STATUS OF A TANK FROM TSD TO GENERATOR ACCUMULATIONMemo
 Description: A generator who is also an operator of a TSDF can convert an interim status tank or container to a generator accumulation unit under 262.34. The enforcement agency will determine applicable closure requirements. If a Part B was submitted, the applicant should notify the Region of the change.
 
11/26/1985CONTAINERS FOR SAFE AND ECONOMICAL STORAGE, TRANSPORT, AND DISPOSAL OF HAZARDOUS WASTE, DEVELOPMENT OFMemo
 Description: Hazardous waste cannot be stored in containers that leak. The waste must be compatible with the container. Containers meeting DOT standards are acceptable hazardous waste storage containers.
 
10/01/1985SMALL QUANTITY GENERATORS, 100-1000 KG/MONTH GENERATORS, AND THE MANIFESTQuestion & Answer
 Description: CESQG wastes accumulated by a storage facility in quantities greater than 1000 kg do not need to manifest when sent off-site. The final disposal site need not be RCRA-permitted. If waste was generated by a SQG, the waste must be manifested to a state-registered facility, and from the facility to the disposal site. After 3/31/86, waste generated by a 100-1000 kg/month generator (SQG) must be disposed in a RCRA-permitted or an interim status facility .
 
09/20/1985PERFORMANCE AND PERMITTING STANDARDS IN 3004(B), PROHIBITION OF PLACEMENT OF HAZARDOUS WASTE IN SALT DOMESMemo
 Description: Section 3004(b) prohibits noncontainerized or bulk waste that fails the paint filter liquid test from placement in salt dome. Other hazardous waste may be placed in a salt dome with a RCRA permit. Nonfluid or containerized liquid wastes are covered under Subpart X (SEE ALSO: 52 FR 46946; 12/10/87).
 
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.
 
09/10/1985DIOXIN-CONTAINING WASTE RINSEATES, DISPOSAL BY DEEP WELL INJECTIONMemo
 Description: Rinsate from containers that held 2,4,5-T and other pesticide formulations is an acute hazardous waste. A deep well injection facility must be permitted to handle dioxin-containing wastes in order to dispose of these wastes. A generator may petition EPA to exclude waste if the waste does not meet listing criteria (SEE ALSO: 261.7).
 
07/10/1985REVISED DEFINITION OF SOLID WASTE PURSUANT TO HSWAMemo
 Description: Carbon regeneration facilities storing carbon before recycling need a permit for storage if they are an incinerator. If they are not an incinerator, they are exempt (may be BIF). Drum recyclers handling empty containers do not need a storage permit. The storage of non-empty containers would require at least a permit for hazardous waste storage. Spent activated charcoal or carbon is usually a spent material. If for pollution control, it would be a sludge. Carbon is hazardous waste (HW) if it contains a listed waste (contained-in policy) or exhibits a characteristic(SEE ALSO: 66 FR 27266; 5/16/01). Carbon is unlikely to exhibit a characteristic. Generators storing HW spent activated carbon are subject to accumulation time regulations. A closed municipal solid waste landfill (MSWLF) suspected of holding HW is subject to corrective action if the facility requires a permit or interim status and is subject to CERCLA.
 
06/06/1985BRASS DROSS SKIMMINGS, SEPARATION OF METALS AND OXIDES, BY-PRODUCTMemo
 Description: Brass dross skimmings are by-products, not scrap metal, and are not solid waste (SW) if reclaimed. Secondary material (by-product, spent material, sludge, CCP, scrap metal) placed on the land or in a product placed on the land is a SW. Hazardous waste (HW) sent to a fertilizer company (either directly or through a processor) for reuse must be manifested. The fertilizer company and the processor need storage permits for the HW. A material used or reused as an ingredient in a product not is SW if not speculatively accumulated, used for fuel, or use in manner constituting disposal.
 
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.
 
05/29/1985BAN ON DISPOSAL OF LIQUIDS IN LANDFILLSMemo
 Description: RCRA section 3004(c) prohibits the disposal in landfills of containerized liquids absorbed in materials, that when compressed, release liquids. The use of chemical stabilization to convert a liquid to a solid is not the only option for dealing with bulk liquid hazardous waste.
 
05/20/1985CONTAINERS CLEANING OTHER THAN TRIPLE RINSING - PAPER BAGSMemo
 Description: The use of bag beating in order to render empty is an acceptable alternative to the triple rinsing of containers that have held acutely hazardous waste. The burning of bags is treatment and subject to Parts 264 and 265.
 
01/22/1985NONHAZARDOUS LIQUID WASTEWATERS AND SLUDGES IN SANITARY LF UNDER RCRA AND HSWA, DISPOSAL OFMemo
 Description: There are no federal regulatory provisions on the disposal of bulk or containerized nonhazardous liquid wastes in a nonhazardous solid waste landfill or a municipal solid waste waste landfill (MSWLF). Disposal of nonhazardous liquid waste in hazardous waste landfills is prohibited (SUPERSEDED: see 56 FR 50978; 10/9/91).
 
12/17/1984GASES VENTED FROM COMPRESSED CYLINDERS - TREATING OF FLUORINE AND OTHERSMemo
 Description: Liquid or physical solid wastes removed from compressed gas cylinders are solid wastes. Gaseous residues are not solid wastes.
 
12/01/1984EMPTY CONTAINER DEFINITIONQuestion & Answer
 Description: A container is only RCRA empty per 261.7 if after pouring, pumping, and aspirating, it then holds less than one inch of residue.
 
11/28/1984TANK CARS AND DRUMS, DEFINITION OF EMPTYMemo
 Description: A container is not "empty" unless any and all industry practices normally used to achieve maximum possible removal are used. Tank cars qualify as containers.
 
09/11/1984CONTAINERS THAT HELD COMMERCIAL CHEMICAL PRODUCTS, DEFINITION OF EMPTYMemo
 Description: A container which is a bag can be emptied by bag beating. Bags containing phthalic anhydride (U190) and maleic anhydride (U147) can be emptied by pouring, shaking and tapping. Containers are empty when commonly employed practices have been applied AND no more than one inch or 3% of the contents remain.
 
09/10/1984CONTAINERS, TYPES OF EMPTY - RESIDUE HANDLINGMemo
 Description: Rinsate from containers that held acutely hazardous waste are hazardous by the mixture rule. Residues from an empty container are hazardous if they exhibit a characteristic (SUPERSEDED: see current 261.7, RPC# 5/13/87-01).
 
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.
 
08/01/1984CONTAINERS, TRIPLE RINSING FOR FERTILIZERMemo
 Description: The empty container regulations apply only if a product is listed in 261.33 (SUPERSEDED: see 261.7).
 
07/01/1984WASTE AS LIQUID OR SOLID, DETERMINATION OFQuestion & Answer
 Description: The phase of a waste should be determined just prior to landfill disposal. If a waste liquefies during transportation, it is proper to allow a shipment of containers to stabilize or solidify before performing the free liquids test (SEE ALSO: 40 CFR 268.3).
 
06/30/1984COMBINED STORAGE OF PESTICIDE WASTESMemo
 Description: Storage of different herbicide and pesticide wastes together is an acceptable procedure provided that the wastes are compatible with each other and the container.
 
06/01/1984 EMPTY CONTAINER RULEQuestion & Answer
 Description: A container with less than one inch of residue is not empty unless an attempt has been made to empty it using practices commonly employed to remove materials from that type of container. RCRA 7003 may apply when the container is dangerous.
 
04/26/1984DECANNING AND CRUSHING OPERATIONSMemo
 Description: Decanning and crushing operations meet the definition of treatment and are subject to permitting. The addition of wastewater to clean gears or containers may be treatment. Aggregation of waste in larger containers with incidental treatment does not meet the definition (SEE ALSO: RPC# 11/26/84-01).
 
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.
 
01/10/1984HAZARDOUS WASTE CONTAINER LABELING REQUIREMENTSMemo
 Description: Container labels must be durable. Typed or written labels must not smear. Information must be displayed in accordance with DOT regulations.
 
12/13/1983CONTAINERS, TRIPLE RINSING OF EMPTYMemo
 Description: For purposes of 261.7, containers are divided into those that have held acutely hazardous waste and those that have not. Those that have held acute wastes must be triple rinsed with a suitable solvent. Other containers must be emptied by a normal manner, but not necessarily rinsing. Emptying and rinsing are not treatment. Residues remaining in an empty container are exempt.
 
12/01/1983FLATTENED DRUMSQuestion & Answer
 Description: If a drum is found at an abandoned site, it is impossible to determine if it has been fully emptied using “all practices commonly employed.” The container can be determined to be empty using the three percent weight difference criterion in 261.7(b)(1)(iii)(A).
 
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.
 
09/01/1983WHEN RESIDUE IN AN EMPTY CONTAINER IS NO LONGER REGULATEDQuestion & Answer
 Description: Provides a summary of the empty container regulations. If the waste is a compressed gas, then the container is empty when the pressure in the container approaches atmospheric pressure.
 
06/01/1983ADDING ABSORBENTS TO HAZARDOUS WASTE IN CONTAINERSQuestion & Answer
 Description: Transferring waste from one container to another while simultaneously adding absorbent material does not require a treatment permit.
 
02/01/1983CONTAINER STORAGE IN PART BQuestion & Answer
 Description: The part B permit application for a container storage area does not need certification of technical data. The certification of other units, such as tanks, is not limited to state-certified professional engineers.
 
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.
 
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.
 
08/31/1982ACCUMULATION OF HAZARDOUS WASTE IN TANKS (90-DAY)Memo
 Description: Generators may accumulate hazardous waste in tanks or containers for 90 days or less without a permit or interim status. EPA considers generator accumulation to be incidental to their operations. Provides guidance on defining an empty tank.
 
02/01/1982RELEASE FROM EMPTY CONTAINERMemo
 Description: A release of waste from an “empty container” escapes CERCLA control because RCRA does not consider material in an empty container a hazardous waste. (SUPERSEDED: See RPC # 4/12/04-02)
 
11/06/1981RESIDUES REMOVED FROM COMPRESSED GAS CYLINDERSMemo
 Description: Discarded compressed gas cylinders containing gaseous, liquid, or physically solid (i.e., non-empty containers) the residues in the cylinders become hazardous wastes because they are being discarded and the residues and cylinders must be handled in compliance with the RCRA regulations. Wastes removed from or derived from the treatment of the cylinders may also be regulated as hazardous waste. Any gas cylinder handling facility is not subject to RCRA regulations in the handling, neutralization, scrubbing, flaring, or venting of gaseous residues removed from compressed gas cylinders.
 
07/10/1981SOLIDIFICATION AS TREATMENTMemo
 Description: A totally enclosed treatment unit (TETU) must preclude the possible escape of hazardous constituents, even with human or equipment failure. A container that could overfill is not a TETU. Solidifying liquid hazardous waste by pouring it into a container containing inert sorbents is treatment (SEE ALSO: 264.1(g)(10), 265.1(c)(13), and 270.1(c)(2)(vii)).
 
12/30/1980AEROSOL CANS, RCRA REGULATON OFMemo
 Description: Puncturing, crushing, or shredding of non-empty aerosol cans is not treatment since the materials inside, not the cans, are hazardous. The residues inside are regulated if they are listed or characteristic. The cans themselves are not regulated unless they are mixed with waste (SUPERSEDED: see RPC# 10/7/93-05).
 
11/18/1980REGULATION OF RINSATE FROM TRIPLE RINSING OF CONTAINERSMemo
 Description: Mixture created by rinsing listed CCP from container with washwater is hazardous waste via the mixture rule. Container rinsewater is solid waste because it is discarded. (SEE ALSO: RPC# 7/21/89-01)
 
11/03/1980DISCARDED RESIDUAL GASES IN COMPRESSED GAS CYLINDERSMemo
 Description: Residual gases in a cylinder transported with minimum pressure as a matter of safety are not regulated as hazardous waste because it has not been discarded. The material is not discarded until the cylinder reaches the supplier and a decision is made whether to discard the residual gas. Returning the cylinder to the supplier does not make the customer a hazardous waste generator.
 
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