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Show details for Air Emissions (RCRA)Air Emissions (RCRA)
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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.
 
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.
 
06/26/2000REGULATORY STATUS OF A SUMP ASSOCIATED WITH AN ELEMENTARY NEUTRALIZATION UNITMemo
 Description: Sump which meets definition of tank and is used in conveying hazardous wastewater to elementary neutralization unit (ENU) could be considered ancillary equipment to ENU and exempt from the requirements of Parts 264, 265, and 270. Authorized state program or Region must make site-specific determination.
 
09/14/1995CLARIFICATION OF CIRCUMSTANCES INITIATING EPA'S ""MANIFEST DISCREPANCY"" PROCEDURESMemo
 Description: The manifest discrepancy regulations do not apply to waste which loses the corrosivity characteristic during transit (transportation). The manifest discrepancy regulations are intended for situations where the quantity of waste is unaccounted for. The manifest is not a certification that shipped waste is indeed hazardous. A generator can apply knowledge conservatively, rather than incur the costs of testing each waste batch or stream.
 
09/13/1995IS THE CHEMICAL POTASSIUM HEXACYANOCOBALT (II)-FERRATE (II), USED AT A DOE NUCLEAR PLANT, CONSIDERED A ""MIXED WASTE"" UNDER RCRA?Memo
 Description: Potassium hexacyanocobalt (II) - ferrate (II) that is used as an ion exchange media to remove cesium from a wastestream is not a listed waste. Potassium hexacyanocobalt (II) - ferrate (II) is unlikely to exhibit ignitability (D001) or corrosivity (D002). If it exhibits a characteristic, it may be radioactive mixed waste.
 
06/14/1995INTERPRETATION OF THE PHRASE ""WHICH CAN BE REASONABLY EXPECTED TO BE PRESENT"" FOR SOIL THAT EXHIBITS THE TOXICITY CHARACTERISTICMemo
 Description: When preparing land disposal restrictions (LDR) notification for D001, D002, D012-43 soils, constituents “reasonably expected to be present” would include all constituents above universal treatment standards (UTS) levels. In remediation, the point of generation is the point at which contaminated soil is picked up (SEE ALSO: 63 FR 28556; 5/26/98).
 
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.
 
02/10/1995CLARIFICATION OF THE LDR PHASE II REGULATION THAT APPEARED IN THE FEDERAL REGISTER ON SEPTEMBER 19, 1994Memo
 Description: SW-846 need not be used to demonstrate compliance with the universal treatment standards (UTS). When organic waste are combusted, nondetect values within an order of magnitude of UTS are acceptable. Notification for F001-F005, F039, D001, D002, D012-43 must include the constituents to be monitored if monitoring will not involve all UTS constituents.
 
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.
 
12/01/1994ELEMENTARY NEUTRALIZATION UNITS GENERATING AND STORING NON-CORROSIVE HAZARDOUS WASTESQuestion & Answer
 Description: A tank in which corrosive-only (D002) electroplating wastewaters are treated meets the definition of elementary neutralization unit (ENU), even if the treatment process produces an F006 sludge. F006 is subject to regulation once it is removed from the tank.
 
07/15/1994APPLICABILITY OF HAZARDOUS WASTE CODES TO A CHEMICAL POLISHING SYSTEMMemo
 Description: Discarded chemical polishing bath solution containing the oxidizer hydrogen peroxide may be ignitable (D001) because it is capable of severely exacerbating a fire by yielding oxygen to stimulate combustion. Acid baths may be corrosive (D002) due to sulfuric acid content. The chemical polishing process does not generate a listed waste if no electroplating or cyanides are used (SUPERSEDED: Memorandum, Dellinger to Waterman; May 18, 2007 (RO 14808)). Discarded baths from this process are hazardous wastes only if characteristic. Wastes that exhibit a characteristic at the point of generation may be subject to the Part 268 requirements even if they do not exhibit a characteristic at the point of disposal (261.3(d)(1)).
 
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).
 
10/20/1993RESPONSE TO SPECIFIC QUESTIONS REGARDING HAZARDOUS WASTE IDENTIFICATION AND GENERATOR REGULATIONSMemo
 Description: The absence of free liquids precludes applicability of the ignitability characteristic (D001) as defined in 261.21(a)(1). The proposed rule change (58 FR 46052; 8/31/93) suggests using the pressure filtration step from TCLP (Method 1311) as a definitive demonstration for the absence of free liquids for D001 and D002.
 
10/13/1993LAND DISPOSAL RESTRICTION INTERIM FINAL RULEMemo
 Description: Discusses the applicability of the interim final rule (58 FR 29884; 5/24/93) to wastes that have one or more numerical treatment standards as well as a deactivation requirement. F001 waste that is also corrosive (D002) must be treated to meet the standards for both waste codes (including treatment for underlying hazardous constituents). Waste mixtures with common constituents of concern must meet the most stringent standard that applies. Ignitable (D001) and corrosive wastes (subject to treatment for underlying hazardous constituents) may be aggregated with other compatible wastes to facilitate treatment. Aggregating wastes for other purposes may be impermissible dilution.
 
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.
 
05/15/1993Environmental Fact Sheet: EPA Issues New Treatment Standards for Certain Ignitable and Corrosive WastesPublication
 Description: This fact sheet announces an interim final rule that replaces the treatment standard of deactivation for certain ignitable and corrosive wastes and new standards that include numerical treatment standards for hazardous constituents of these wastes. The ruling is intended to bring the deactivation standard for ignitable and corrosive wastes into full compliance with RCRA.
 
04/23/1993INTERPRETATION OF ""AQUEOUS"" AS APPLIED TO THE CORROSIVITY CHARACTERISTICMemo
 Description: Aqueous means amenable to pH measurement. The corrosivity characteristic (D002) references Method 9040. The scope and application of 9040 notes that it applies only to aqueous wastes and those wastes where the aqueous phase constitutes at least 20% of the total volume of the waste.
 
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).
 
01/07/1993APPLICABILITY OF CORROSIVITY PH AND STEEL CORROSION TESTSMemo
 Description: Nonaqueous liquids need only be tested using the steel corrosion test, whereas aqueous nonliquids (e.g., gels) need only be evaluated for pH. Aqueous liquids are subject to pH measurement and the steel corrosion test. Aqueous waste is defined as a waste that is amenable to pH measurement.
 
09/01/1992“AQUEOUS” AS APPLIED TO THE CORROSIVITY CHARACTERISTICQuestion & Answer
 Description: Aqueous liquid wastes must be tested for both pH and the rate of steel corrosion to determine corrosivity. For D002, aqueous defined as waste for which the pH is measurable. Aqueous nonliquids subject to pH test only. Provides examples of aqueous nonliquids.
 
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.
 
03/31/1992MANAGEMENT OF MIXED WASTEMemo
 Description: Low-level radioactive mixed waste typically consists of organic liquids, oil mixtures, heavy metal-contaminated wastes, and corrosive liquids. Generators, and TSDFs must include mixed waste information in their biennial report. Discusses mixed waste permitting authority. Mixed waste is a subset of low level waste.
 
03/09/1992CORROSIVITY CHARACTERISTIC AS IT APPLIES TO SOLIDSMemo
 Description: corrosive solids (i.e., lye, and solid acids) are not covered under the corrosivity characteristic (D002). Aqueous is not defined (SUPERSEDED: see RPC# 1/7/93-02; RPC# 4/23/93-01). A test method for corrosive solids is proposed.
 
12/01/1991SW-846 TEST METHODSQuestion & Answer
 Description: The test methods found in SW-846 are generally not required, but are intended as guidance for both hazardous waste identification and compliance with the land disposal restrictions (LDR) treatment standards. In certain instances, such as delisting and characteristic testing, EPA requires the use of the SW-846 methods.
 
08/01/1990POINT OF GENERATIONQuestion & Answer
 Description: Co-mingled corrosive wastes (D002), which neutralize each other subsequent to the point of generation are individually subject to land disposal restrictions (LDR) (SUPERSEDED: wastes discharged under the CWA are not subject to land disposal restrictions; SEE ALSO: 61 FR 15660; 61 FR 33681).
 
06/29/1990AGITATE SAMPLES EVALUATED USING METHOD 1110Memo
 Description: No quantitative guidance on when and to what extent waste should be agitated to ensure homogeneity during the steel coupon test for corrosivity. Non-homogeneous liquids should be agitated by mechanical means. For homogeneous liquids of low viscosity, thermal currents may be sufficient.
 
06/27/1990SECONDARY MATERIALS RECYCLED IN PHOSPHORIC ACID RECIRCULATING SYSTEMSMemo
 Description: Corrosive (D002), low-volume secondary materials (e.g., precipitates and spilled materials) that are recycled in a phosphoric acid plant’s recirculating water systems may cause entire system to be regulated if there is continued circulation of corrosive secondary materials.
 
02/16/1990IGNITABILITY OR CORROSIVITY TESTING-LIQUID AND AQUEOUS DEFINITIONMemo
 Description: No mandatory test for determining liquid and aqueous for ignitability (D001) and corrosivity (D002) characteristic testing. Paint filter liquid test (PFLT) Method 9095 may be used. Method 9095 is not appropriate for toxicity characteristic.
 
11/17/1989NITRIC ACID WASTE CHARACTERIZATIONMemo
 Description: While Federal regulations do not require waste codes on the manifest, nitric acid waste that is both ignitable (D001) (i.e., an oxidizer) and corrosive (D002) must be managed in compliance with all special requirements for D001 (e.g., 264.17) and D002 wastes. A waste exhibiting two characteristics carries two waste codes.
 
10/05/1989DEFINITION OF A LIQUID AS IT APPLIES TO IGNITABLE AND CORROSIVE WASTES; LIQUID AS IT APPLIES TO IGNITABLE OR CORROSIVE WASTESMemo
 Description: The definition of liquid depends on the specific regulatory application for ignitable (D001), corrosive (D002), and extraction procedure (EP) (SUPERSEDED: see 261.24). For toxic wastes, liquid is defined as the material expressed from the waste in Step 2 of Method 1310. Liquids produced from paint filter test are generally also liquids under Method 1310 (SEE ALSO: 60 FR 3092; January 13, 1995). Only wastes containing a liquid component are subject to the flash point test (ignitability (D001)) and the pH test (corrosivity (D002)). Method 9095 is used to determine if a waste is prohibited from disposal in a landfill for containing free liquids. Method 9096 is a draft procedure for determining if adsorbents contain releasable liquids. Adsorbents containing releasable liquids are prohibited from disposal in a landfill by HSWA.
 
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).
 
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)).
 
07/20/1989LIQUID, FREE LIQUID, RELEASABLE LIQUID DEFINITIONSMemo
 Description: Liquid for purposes of corrosivity (D002) determined by Method 1310 (extraction procedure (EP)). The definition of free liquid applies to the prohibition of liquids in landfills. Definition of releasable liquid applies to absorbent materials that might release liquids (SEE ALSO: current Sections 264.314(e), and 265.314(f)).
 
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.
 
07/29/1988CEMENT KILN DUST WASTEMemo
 Description: Cement kiln dust (CKD) is not a hazardous waste (SEE ALSO: 60 FR 7366; 2/7/95). A mixture of exempt cement kiln dust with corrosive liquid (D002) will result in a nonhazardous waste if the mixture no longer exhibits any characteristic (SEE ALSO 261.3(d)(1)). Mixing is considered treatment. No permit is required for treatment performed in generator accumulation tanks subject to 262.34.
 
07/21/1988CHLOROFLUOROCARBON RECYCLINGMemo
 Description: Used refrigerants meet the definition of a spent material. Used CFC refrigerant is not F-listed spent solvent but may exhibit a characteristic. Used refrigerant is not U121 or U075 because it has been used. The P-listings and U-listings do not apply to used chemicals. Cylinders containing used refrigerants to be reclaimed are solid waste (SW). Generators may use knowledge of similar operations at different facilities to characterize waste (SEE ALSO: 261.4(b)(12)). An owner of refrigeration equipment and a company or individual performing servicing may be generators of used refrigerant waste (i.e., cogenerators).
 
05/02/1988SPENT PICKLE LIQUOR CORROSIVITYMemo
 Description: Spent pickle liquor generated by a steel fabricator is not K062 since the facility is not in SIC codes 331 or 332. Nonlisted spent pickle liquor is corrosive if it corrodes 1020 steel at a rate of >0.25 inches/year. Nonlisted sludge from a pickling tank is D002 if pH of the sludge is < 2. The 264.314 liquids in landfills ban does not apply to nonhazardous waste disposal facilities.
 
04/29/1988ELEMENTARY NEUTRALIZATION EXEMPTIONMemo
 Description: Sumps, as defined in 260.10, are tanks. A neutralization sump and ancillary equipment handling corrosive-only wastewater qualify for the elementary neutralization unit (ENU) exemption.
 
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.
 
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.
 
09/15/1987DEFINITION OF AQUEOUS FOR CORROSIVITY CHARACTERISTICMemo
 Description: For the corrosivity characteristic (D002), a waste is aqueous if it has a liquid phase containing more than 50% water (SUPERSEDED: see RPC# 1/7/93-02; RPC# 4/23/93-01; RPC# 9/1/92-02).
 
09/14/1987AQUEOUS AS USED IN THE CORROSIVITY CHARACTERISTICMemo
 Description: Aqueous for the corrosivity characteristic (D002) is defined as waste having a liquid phase containing more than 50% water (SUPERSEDED: See RPC# 4/23/93-01).
 
08/18/1987CORROSIVE CHARACTERISTIC APPLIED TO LIQUID AND AQUEOUS WASTESMemo
 Description: The corrosivity characteristic (D002) applies only to aqueous and liquid wastes. There is no definition of a corrosive solid.
 
03/16/1987K062 LISTING APPLIES ONLY TO FACILITIES WITHIN THE IRON AND STEEL INDUSTRYMemo
 Description: Pickle liquor wastes from industries not in the iron and steel industrial classifications are hazardous only if they are characteristic. Because spent pickle liquor is generally corrosive (D002) and usually contains high concentrations of chromium and lead, it is probably characteristic.
 
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).
 
02/01/1987F006Question & Answer
 Description: Sludge generated off site from a mixture of corrosive (D002) electroplating rinsewater and other acid wastes is F006.
 
06/16/1986RESIDUAL WATER DERIVED FROM AN EXEMPT WASTE (COAL ASH) IS EXEMPTMemo
 Description: Residual water that becomes corrosive (D002) from Bevill exempt fossil fuel combustion waste is also exempt. Residual water derived from an exempt waste is exempt.
 
06/02/1986PAINTING CONTRACTOR WASTES-SMALL QUANTITY GENERATORMemo
 Description: Methylene chloride is a listed waste (F002) when used as a solvent and can be toxic. Muriatic acid is likely to be corrosive (D002) but not toxic. Generators who produce greater than 100 kg/mo are subject to regulation. CESQGs may dispose of hazardous waste in any state approved landfill.
 
05/12/1986DEIONIZATION ACID REUSED, NOT A WASTEMemo
 Description: Corrosive materials (deionization acid) that are beneficially reused as effective substitutes for a virgin material, meet relevant specifications for contamination levels, and used under controlled conditions are not solid waste. Discussion of the retroactive application of exclusions from the definition of solid waste. A surface impoundment holding waste which has never been solid waste need not be closed.
 
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.
 
04/21/1986PRECIPITATION WHICH IS CORROSIVE DUE TO CONTACT WITH EXEMPT WASTES (COAL GASIFICATION ASH)Memo
 Description: Precipitation that becomes corrosive (D002) solely as a result of contact with Bevill exempt fossil fuel combustion wastes (such as coal gasification ash) is exempt since characteristic is derived from the exempt waste.
 
02/01/1986FOSSIL FUEL COMBUSTION WASTE EXCLUSIONQuestion & Answer
 Description: Quench water that becomes corrosive (D002) as a result of contact with ash from coal combustion is exempt under the section 261.4(b)(4) Bevill exclusion for fossil fuel combustion wastes since the characteristic is derived from exempt waste.
 
01/22/1986COPPER PLATING SOLUTIONMemo
 Description: Materials incorporated into products used on the land are a solid waste (SW) and potentially a hazardous waste (HW) under the use in manner constituting disposal provisions. Corrosive (D002) spent copper sulfate bath used in a fertilizer is a SW and a HW. A commercial fertilizer product derived from a characteristic HW is not regulated (SUPERSEDED: see 266.20(b)).
 
01/22/1986COPPER PLATING SOLUTION REACTED WITH A CHELATING AGENT TO PRODUCE A COMMERCIAL FERTILIZERMemo
 Description: Materials incorporated into products used on the land are solid waste (SW) and potentially hazardous waste (HW) under “use in manner constituting disposal“ provisions. Corrosive (D002) spent copper sulfate bath used in fertilizer is SW and HW. Commercial fertilizer product derived from characteristic HW is not regulated (SUPERSEDED: see 266.20(b)).
 
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.
 
05/15/1985BATTERIES, WASTE ELECTROLYTE FROM RECHARGEABLE NICKEL-CADMIUMMemo
 Description: Disposal of a spent nickle-cadmium battery (batteries) potassium hydroxide electrolyte into a sewer is excluded. The spent electrolyte may be corrosive (D002) or toxic.
 
01/01/1985POLLUTION CONTROL SLUDGE FROM TREATMENT OF MINING WASTE - EXCLUSIONQuestion & Answer
 Description: Pond sludge from the treatment of drainage from an active coal mine is exempt under the 261.4(b)(7) Bevill exemption for mining and mineral processing wastes, even if it meets the definition of corrosivity. Pollution control residues from the treatment of mining wastes are exempt under 261.4(b)(7).
 
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).
 
02/01/1983PH MEASUREMENT ON PARTIAL SOLIDSQuestion & Answer
 Description: Material that contains free liquids (using the paint filter liquids test) can be measured for pH to evaluate corrosivity (SEE ALSO: RPC# 4/23/93-01; RPC# 10/20/93-01).
 
09/16/1980FOOD PROCESSORS, IMPACT OF HAZARDOUS WASTE REGULATIONS ONMemo
 Description: Caustic food processing waste may exhibit the characteristic of corrosivity (D002). It is not exempt even though it is neutralized before it leaves the facility as non-characteristic. Waste is not exempt simply because it is managed in a safe and proper manner.
 
05/02/1980Corrosivity Characteristic (40 CFR 261.22); Identification and Listing of Hazardous Waste Under RCRA, Subtitle C, Section 3001Publication
 Description: This document explains EPA's definition of corrosive waste, discusses comments received on Agency's proposed definition of corrosive waste, and the changes made in response to comments. It also includes the rationale for the proposed characteristic of corrosivity for identification and listing of hazardous waste as well as the test methods used to make that determination.
 
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