Skip common site navigation and headers
US EPA
RCRA Online
Begin Hierarchical Links You are here: EPA Home >> Wastes >> Information Sources >> RCRA Online >> Topics Search End Hierarchical Links
Welcome What's New Topics Full Text Search Advanced Search Help

Topics Search

Click on the blue carat to the left of a Topic, the list will expand to show the documents related to the selected Topic.

Show details for Air Emissions (RCRA)Air Emissions (RCRA)
Show details for BatteriesBatteries
Show details for Best Demonstrated Available Technology (BDAT)Best Demonstrated Available Technology (BDAT)
Show details for Bevill AmendmentBevill Amendment
Show details for BoilersBoilers
Show details for BurningBurning
Show details for Buy RecycledBuy Recycled
Show details for Characteristic WastesCharacteristic Wastes
Show details for Chemicals (RCRA)Chemicals (RCRA)
Show details for CleanupCleanup
Show details for Cleanup (RCRA)Cleanup (RCRA)
Show details for Closure (Hazardous Waste)Closure (Hazardous Waste)
Show details for CombustionCombustion
Show details for Combustion of Hazardous WasteCombustion of Hazardous Waste
Show details for ComplianceCompliance
Show details for CompostingComposting
Show details for Conditionally Exempt Small Quantity Generators (CESQG)Conditionally Exempt Small Quantity Generators (CESQG)
Show details for Construction and Demolition WasteConstruction and Demolition Waste
Show details for Construction and Demolition WastesConstruction and Demolition Wastes
Show details for ContainersContainers
Show details for Containment BuildingsContainment Buildings
Show details for Corrective Action (RCRA)Corrective Action (RCRA)
Show details for Corrosive WastesCorrosive Wastes
Show details for Crude OilCrude Oil
Show details for Delisting PetitionsDelisting Petitions
Show details for DisposalDisposal
Show details for Drip PadsDrip Pads
Show details for Educational MaterialsEducational Materials
Show details for Enforcement (RCRA)Enforcement (RCRA)
Show details for EPA FormsEPA Forms
Show details for Exclusions (RCRA)Exclusions (RCRA)
Show details for ExportsExports
Show details for F-wastesF-wastes
Show details for Financial Assurance (hazardous waste)Financial Assurance (hazardous waste)
Show details for Financial Assurance (nonhazardous waste)Financial Assurance (nonhazardous waste)
Show details for GasGas
Show details for GeneratorsGenerators
Show details for Grants (hazardous Waste)Grants (hazardous Waste)
Show details for Grants (municipal solid waste)Grants (municipal solid waste)
Show details for Groundwater MonitoringGroundwater Monitoring
Show details for Hazardous WasteHazardous Waste
Show details for Hazardous waste dataHazardous waste data
Show details for Hazardous Waste IdentificationHazardous Waste Identification
Show details for Hazardous Waste RecyclingHazardous Waste Recycling
Show details for Household Hazardous WasteHousehold Hazardous Waste
Hide details for Identification of Hazardous WasteIdentification of Hazardous Waste
04/11/2014REGULATORY STATUS OF SHIPMENT OF DENTAL X-RAY MATERIALS FROM MEXICO TO CANADAMemo
 Description: Federal RCRA hazardous waste regulations, per 40 CFR 261.2(c)(3) and Table 1 of 261.2, do not regulate the reclamation of off-spec commercial chemical products and characteristic byproducts provided these materials are reclaimed legitimately. Therefore, EPA’s hazardous waste import/export requirements would not apply to a shipment of intact unused off-spec dental x-ray packs and trimmings from unused dental x-ray packs generated in Mexico, with transit across the United States, destined for reclamation in Canada. A RCRA authorized state may regulate these materials more stringently than the federal program, although EPA believes the state’s requirements would not likely apply to transit only activities. However, should a transporter stop at a facility to consolidate a shipment in a state with more stringent requirements, the state may view such materials as a shipment of recyclable hazardous materials destined for precious metal recovery. In this case, the state may require that the consolidating facility comply with the state’s regulations equivalent to Part 266, Subpart F for precious metal recovery and Part 262, Subparts E and F for exports and imports of hazardous waste.
 
05/14/2013CHECKLIST TO ASSIST IN EVALUATING WHETHER COMMERCIAL CHEMICAL PRODUCTS ARE SOLID AND HAZARDOUS WASTE UNDER THE RESOURCE CONSERVATION AND RECOVERY ACTMemo
 Description: This memorandum transmits a separate revised memorandum that provides guidance and a checklist for evaluating the regulatory status of materials that would, under usual circumstances, be commercial chemical products (CCPs). CCPs are not solid waste if they are appropriately stored or managed for use, legitimately reclaimed, or appropriately stored or managed for legitimate reclamation; CCPs are solid waste if they are abandoned by being accumulated, or by being stored, or treated before, or as a means of, being disposed. The checklist is designed to assist in applying this regulatory structure to specific situations and evaluating whether a particular CCP, managed in a particular way, is a solid waste. If a CCP is a solid waste, it then must be determined if the CCP is listed as a hazardous waste or exhibits a characteristic of hazardous waste. If the CCP is a solid and hazardous waste, it must be managed in compliance with the RCRA Subtitle C hazardous waste management regulations.
 
03/01/2013CLARIFICATION ON THE DILUTION OF LISTED F003 HAZARDOUS WASTEMemo
 Description: An F003 hazardous waste (listed solely for the characteristic of ignitability) is not a hazardous waste if the waste no longer exhibits any characteristic of hazardous waste per 40 CFR 261.3(g). However, F003 waste that is subsequently decharacterized is still subject to the Part 268 LDR requirements and may not be simply diluted as a substitute for adequate treatment (268.3) (SEE ALSO: R
 
11/20/2012REGULATORY STATUS OF A WATER-SOLVENT CLEANING SOLUTIONMemo
 Description: In a situation where a waste phase separates (biphasic solution), the generator must make the hazardous waste determination not only at the point of generation, but also after the waste separates into phases. A generator may use either knowledge or testing to determine if a waste exhibits a characteristic. The COLIWASA sampling protocol can be used to sample each phase in a multi-phasic solution. Separating or physically removing the water phase from the ignitable solvent phase is considered treatment. Generators may treat their hazardous waste without a permit or interim status in accumulation tanks and containers that are managed in compliance with the generator accumulation provisions of 40 CFR 262.34.
 
02/17/2012SCOPE OF HAZARDOUS WASTE LISTING P046 (PHENTERMINE)Memo
 Description: The scope of the P046 listing does not include phentermine salts (SEE ALSO: RO 14778).
 
08/23/2010CHARACTERIZATION OF USED TOLUENE WHEN SOLD AS A FUEL ADDITIVE OR FOR OTHER FUEL PURPOSESMemo
 Description: Used toluene is a spent material and not a commercial chemical product (CCP), therefore the solid waste exemption for fuels burned for energy recovery does not apply. "Commercial chemical product" refers to a chemical substance which is manufactured or formulated for commercial or manufacturing use. This consists of the commercially pure grade of the chemical, any technical grades of the chemical that are produced or marketed, and all formulations in which the chemical is the sole active ingredient. It does not refer to a material such as a manufacturing process waste. Used toluene is a spent material because it has been used and as a result of contamination, can no longer serve the purpose for which it was produced without processing. Additionally, "contamination" as used in the definition of spent material, is any impurity, factor, or circumstance which causes the material to be taken out of service. Finally, the definition of spent material has been consistently applied to materials that have been used and are no longer fit for use without being regenerated.
 
08/23/2010REGULATION OF UNUSED DERMAL NICOTINE PATCHESMemo
 Description: Unused dermal patches containing nicotine would be regulated as a listed hazardous waste when disposed. Nicotine in finished dosage forms, such as tablets or capsules, is regulated because it is a commercial chemical product formulation containing nicotine as the sole active ingredient. EPA views transdermal patches as an analogous dosage form. However, after the patch has been applied and removed, it has been used for its intended purpose and therefore would not be listed hazardous waste when discarded. EPA does not view dermal patches to be “manufactured articles”. This letter supersedes an earlier response that was included in a report for the RCRA, Superfund & EPCRA Hotline, RCRA/UST, Superfund and EPCRA Monthly Hotline Report, April 1995 (RO 13741, page 1).
 
06/01/2010Revisions to the Definition of Solid Waste Final Rule Compilations: The Contained StandardPublication
 Description: The Revisions to the Definition of Solid Waste Final Rule Compilations provide easy access for EPA, the states, the regulated community, and the public to important information regarding provisions under the Definition of Solid Waste (DSW) Rule. For each compilation, EPA has incorporated information from relevant Federal Register preambles, regulations, and other materials. This volume of the Compilations series provides information about the contained standard under the DSW Rule.
 
06/01/2010Revisions to the Definition of Solid Waste Final Rule Compilations: The History of Legitimate RecyclingPublication
 Description: The Revisions to the Definition of Solid Waste Final Rule Compilations provide easy access for EPA, the states, the regulated community, and the public to important information regarding provisions under the Definition of Solid Waste (DSW) Rule. For each compilation, EPA has incorporated information from relevant Federal Register preambles, regulations, and other materials. This volume of the Compilations series provides information about the legitimacy standard under the DSW rule.
 
06/01/2010Revisions to the Definition of Solid Waste Final Rule Compilations: The Legitimate Recycling StandardPublication
 Description: The Revisions to the Definition of Solid Waste Final Rule Compilations provide easy access for EPA, the states, the regulated community, and the public to important information regarding provisions under the Definition of Solid Waste (DSW) Rule. For each compilation, EPA has incorporated information from relevant Federal Register preambles, regulations, and other materials. This volume of the Compilations series provides information about the legitimate recycling standard under the DSW rule.
 
06/01/2010Revisions to the Definition of Solid Waste Final Rule Compilations: The Reasonable Efforts ConditionPublication
 Description: The Revisions to the Definition of Solid Waste Final Rule Compilations provide easy access for EPA, the states, the regulated community, and the public to important information regarding provisions under the Definition of Solid Waste (DSW) Rule. For each compilation, EPA has incorporated information from relevant Federal Register preambles, regulations, and other materials. This volume of the Compilations series provides information about the reasonable efforts condition under the DSW rule.
 
01/15/2010MANAGEMENT OF CONTAMINATED HUMAN REMAINS AND PERSONAL EFFECTS FROM HOMELAND SECURITY EVENTSMemo
 Description: EPA does not consider RCRA to apply to human remains that are cremated or buried. EPA also does not consider RCRA to apply to contaminated human remains from a biological, radiological, or nuclear event. Most personal effects generated from a Homeland Security event would be exempt from the federal hazardous waste requirements pursuant to the household hazardous waste exemption.
 
11/03/2009Definition of Solid Waste Decision Tool (v2)Publication
 Description: The Definition of Solid Waste Decision Tool is an interactive decision support tool designed to follow a series of decisions that a typical user might make when determining whether a material meets the definition of solid waste for purposes of being a hazardous waste (see 40 CFR 261.1(b)). The decisions in the tool are organized to simplify this determination process and to allow the user to reach a conclusion as quickly as possible.
 
08/01/2009Hazardous Waste Characteristics: A User-Friendly Reference DocumentPublication
 Description: This web-based document serves as a user-friendly reference to assist EPA and state staff, industrial facilities generating and managing hazardous wastes, and the general public in locating and understanding the current RCRA hazardous waste characteristics regulations, located in 40 CFR Part 261.
 
08/01/2009Identification and Listing of Hazardous Waste 40 CFR 261.4(b): Exclusions: Solid Wastes which are Not Hazardous Wastes: A User-Friendly Reference DocumentPublication
 Description: This web-based document serves as a user-friendly reference to assist EPA and state staff, industrial facilities generating and managing hazardous wastes, and the general public in locating and understanding the regulations specific to the solid wastes which are not hazardous waste, located in 40 CFR 261.4(b).
 
05/14/2009DETERMINATION ON ZIRCONIUM OXIDE COATING PROCESS AS ALUMINUM AND THE F019 LISTINGMemo
 Description: Chemical conversion coating refers to processes used to protect metals from corrosion and to prepare for painting or other surface treatment. Specifically, four operations are within the scope of chemical conversion coating in the F019 listing - coloring, chromating, phosphating, and immersion plating. Zirconium oxide processes do not fit within these categories. The process does not use chromium or phosphate, the aluminum is not converted to an oxide but rather is coated with precipitated zirconium oxide, and does not deposit a layer of metal. While the zirconium oxide process is not covered by the F019 listing, it is possible for the resulting waste to be characteristic.
 
10/01/2008Environmental Fact Sheet: Modification to the Definition of Solid Waste Aims To Increase RecyclingPublication
 Description: This fact sheet describes the Definition of Solid Waste Final Rule, which establishes streamlined requirements for materials that are generated and legitimately reclaimed under the control of the generator; materials that are generated and transferred to another company for legitimate reclamation under specific conditions; and materials that EPA or an authorized state determines to be non-wastes through a case-by-case petition process. The rule also contains a provision to determine which recycling activities are legitimate under the new exclusions and non-waste determinations.
 
06/06/2008ROLE OF MATERIAL SAFETY DATA SHEET (MSDS) IN HAZARDOUS WASTE IDENTIFICATIONMemo
 Description: A Material Safety Data Sheet (MSDS) is often the only information available that can be used to determine the chemical components of a product. Using an MSDS is a generally acceptable means to determine whether or not any of the product’s constituents or properties would make it a characteristic or listed waste, when discarded.
 
03/01/2008Hazardous Waste Listings: A User-Friendly Reference Document (Draft)Publication
 Description: This web-based document serves as a user-friendly reference to assist EPA and state staff, industrial facilities generating and managing hazardous wastes, and the general public in locating and understanding the hazardous waste listing regulations, located in 40 CFR Part 261.
 
02/01/2008Definition of Solid Waste (DSW) CompendiumPublication
 Description: The Definition of Solid Waste (DSW) Compendium serves as a user-friendly reference, to assist EPA and state staff, industrial facilities generating and managing solid and hazardous wastes, as well as the general public, in locating resources addressing specific regulatory issues within the federal Definition of Solid Waste regulations. The DSW Compendium consists of 22 volumes, covering various topics related to the DSW regulations. This reference is designed to be web-based; therefore, the usefulness of the document is maximized when it is viewed on a computer that is connected to the internet.
 
10/15/2007SCOPE OF HAZARDOUS WASTE LISTING P042 (EPINEPHRINE)Memo
 Description: The scope of the P042 listing does not include epinephrine salts (SEE ALSO: RO 14831).
 
08/23/2007RECLAMATION OF MATERIAL RECOVERED FROM CRUDE OIL STORAGE TANKSMemo
 Description: Crude oil tank sediment from petroleum refining operations is listed hazardous waste K169. If the tank is located at or affiliated with a petroleum refinery, and the tank materials are reclaimed on-site at the petroleum refinery, the generated residuals would meet the K169 listing. Crude oil tank materials sent for legitimate reclamation would not be a solid waste. Residuals generated from off-site reclamation would represent a new point of generation, would not meet the K169 listing, and would only need to be assessed for hazardous waste characteristics. No listings apply to discarded tank sediments for crude oil storage not located or affiliated with a petroleum refinery.
 
05/21/2007APPLICABILITY OF RCRA TO DISPOSAL OF UNIFIED GROUP RATION - EXPRESS (UGR-E)Memo
 Description: For disposal of expired flameless heaters in Unified Group Ration - Express (UGR-E), EPA believes that it is unlikely that intact UGR-Es would be RCRA hazardous waste when disposed. For disposal of unused, individual chemical heaters by a unit, although the heaters may exhibit the characteristic of reactivity, EPA believes unused individual heaters taken from an UGR-E issued for use in the field are excluded under the household waste exclusion. Therefore, EPA urges generators and handlers to manage unused heaters carefully and recycle them if possible.
 
05/18/2007REGULATORY STATUS OF WASTEWATER TREATMENT SLUDGES FROM ALUMINUM AND COPPER FINISHINGMemo
 Description: Copper etching/bright dipping is within the scope of the F006 listing. Descaling by an acidic solution removes metal from the surface and is therefore essentially chemical etching. Bright dipping is a chemical etching process (SEE ALSO: Memorandum, Straus to Sauer; January 27, 1987 (RO 11214)). Bright dipping is defined as a “specialized form of etching that is used to remove oxide and tarnish from ferrous and nonferrous materials”.
 
10/04/2005GUIDANCE FOR IDENTIFYING INCIDENTAL PROCESSING ACTIVITIESMemo
 Description: Activities that change a material’s physical form without changing the mass of the material or its chemical composition or make only a minor change to the mass of the material, which may also make a minor change to the chemical composition, are considered incidental processing. Incidental processing activities may take place at any step during the use/reuse process. A process may involve more than one incidental processing step as long as the cumulative effect is incidental. Another indicator of incidental processing is whether an analogous process using raw materials includes the same or similar activities at the same point in the process. Provides examples of incidental processing.
 
09/01/2005Environmental Fact Sheet: Wastewater Treatment Exemptions for Certain Hazardous Waste MixturesPublication
 Description: This fact sheet discusses the final rule that makes revisions to the wastewater treatment exemptions for hazardous waste mixtures, also known as the "Headworks Rule,” originally proposed on April 8, 2003.
 
06/08/2005STATUS OF BRINE RESIDUE FROM EMIT PROCESSMemo
 Description: EMIT technology is one of several technologies currently available or under development for treating produced water from coal bed methane extraction. As long as the residual brine/spent acid combination is sent from the cation-exchange system to a tank (or other elementary neutralization unit) and neutralized as part of the overall treatment process so that it does not exhibit the RCRA characteristic of corrosivity, and as long as the treated residue is handled in Class I non-hazardous waste injection wells, the process or the waste material is not subject to any RCRA subtitle C regulatory requirements.
 
11/12/2004REGULATORY DETERMINATION OF DISCARDED LEATHER PRODUCTS UNDER RCRAMemo
 Description: There is no data demonstrating that discarded leather products exhibit the toxicity characteristic (TC) for chromium as a result of the tanning process.
 
10/29/2004CLASSIFICATION AND DISPOSAL OF WASTE FLAMELESS RATION HEATERSMemo
 Description: The disposal of flameless ration heaters (FRHs) that are discarded by individual soldiers issued Meals, Ready-to-Eat (MREs) is excluded from RCRA Subtitle C regulation under the household waste exclusion. It is unlikely that multiple, unused MREs (that contain FRHs) would be RCRA hazardous waste when disposed. EPA generally considers multiple unused FRHs (not packaged with MREs) that are discarded to be a D003 reactive waste which, therefore, must be managed as a RCRA hazardous waste when disposed.
 
10/14/2004BURNING OF CONTAINMENT RAINWATER CONTAMINATED WITH HAZARDOUS WASTE FUELMemo
 Description: Under the contained-in policy, EPA requires contaminated environmental media, although not hazardous wastes themselves, be managed as hazardous waste if they contain hazardous waste or exhibit a characteristic of hazardous waste. Contaminated rainwater containing hazardous waste fuel is subject to all applicable RCRA requirements until it no longer contains hazardous waste. Listed hazardous waste burned as an ingredient is a waste-derived product. Waste derived products are eligible for exemption from any further regulation if they meet the applicable LDR treatment standards. Cement produced from clinker product does not contain hazardous waste if contaminated rainwater is burned in kiln.
 
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.
 
04/01/2004INTERSTATE SHIPMENTS OF WASTE LISTED SOLELY FOR IGNITABILITY, CORROSIVITY, OR REACTIVITYMemo
 Description: A transporter must have an EPA ID number, a manfiest, and comply with Part 263 if traveling through any state that recognizes the waste as hazardous. A TSDF is subject to the standards of the state where it is located.
 
02/18/2004APPLICATION OF P AND U WASTE CODES TO FERTILIZERS MIXED WITH INSECTICIDES OR HERBICIDESMemo
 Description: Listings in 261.33(e) or 261.33(f) do not include chemical mixtures where the listed chemical is not the sole active ingredient, regardless of whether only one or more active ingredients are present. Note that “sole active ingredient” means the active ingredient is the only chemically active component that performs the functions of the product. When a formulated product has more than one chemical or compound as an active ingredient, the presence of a P or U chemical substance in the formulation does not render the product, when discarded, a P- or U-listed hazardous waste. Such products still need to be evaluated to determine if they exhibit any hazardous waste characteristics.
 
02/12/2004APPLICABILITY OF THE F006 CLASSIFICATION TO WASTES FROM THE CHEMICAL ETCHING OF MAGNESIUMMemo
 Description: The applicability of hazardous waste listings is determined by the straight reading of regulatory language when specific processes are not mentioned. The F006 listing covers wastewater treatment sludges from certain electroplating operations. The listing applies to chemical etching, among other activities, and only excludes chemical etching of aluminum. Magnesium etching is not excluded, and wastewater treatment sludges generated from the chemical etching of magnesium are subject to the F006 listing. EPA's interpretation that the F006 listing applies to "common and precious metals" only applies in certain instances, but it did not affect anodizing, chemical etching and milling, or cleaning and stripping processes (SEE ALSO: 51 FR 43351; December 2, 1986). If a wastewater treatment sludge does not contain any constituents of concern for the F006 listing, the waste may be eligible for delisting.
 
01/20/2004SEMI-VOLATILE CONSTITUENT ANALYSIS AND ANALYTICAL LEVEL OF DETECTION LIMITATIONS OF THE TOXICITY CHARACTERISTIC LEACHING PROCEDURE (TCLP)Memo
 Description: A generator may use process knowledge regarding how a waste is generated and scientific knowledge regarding chemical reactions to identify the constituents of concern for analysis. It is not necessary to test for all TCLP consitituents if the waste is determined to be nonhazardous using process knowledge. If a waste is 100% solid as defined by TCLP method 1311, the results of the total constituent analysis may be divided by twenty to convert the total results into the maximum leachable concentration. If it is a filterable liquid, then the concentration of each analyte phase must be determined.
 
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.
 
11/19/2003MSDS INFORMATION FOR CHEMICALS AND THE APPLICABILITY OF U-LISTED WASTE CODESMemo
 Description: OSHA is responsible for overseeing the development and distribution of Material Safety Data Sheets (MSDS). Toluene may meet the U220 listing and carbon tetrachloride may be U221. U-listed wastes must meet three criteria: the U-listed waste must be an unused discarded or spilled commercial chemical product (CCP); the CCP must contain a chemical ingredient listed in 261.33(e) or (f); and the chemical ingredient in the CCP must be the sole active ingredient in the product. If all three criteria are not met, the material is not a listed waste but may be hazardous if it exhibits a characteristic.
 
05/19/2003FLASH POINT TESTING OF A WASTE FIBROUS FILTER MATERIALMemo
 Description: Only liquid wastes are evaluated for ignitability using the flash point test in 261.21(a)(1). Non-liquid wastes, such as fibrous filter material, are assessed for ignitability using the narrative criteria found in 261.21(a)(2). No specific federal test has been developed for determining the ignitability of non-liquid wastes. State implementing agencies may have tests or guidance for determining non-liquid waste ignitability.
 
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.
 
03/18/2003REGULATION OF NITROGLYCERINE UNDER REVISED MIXTURE AND DERIVED-FROM RULESMemo
 Description: Under the revised mixture and derived-from rules, wastes listed solely for exhibiting the characteristic of ignitability, corrosivity, or reactivity are not hazardous wastes if they do not exhibit a characteristic. Medicinal nitroglycerine is not listed as P081 if it is not reactive because P081 is listed solely for reactivity. If a waste does not exhibit a characteristic at the point of generation, then land disposal restrictions (LDR) are not applicable (SEE ALSO: 66 FR 27286; 5/16/01). The revised mixture and derived-from rules are less stringent, so authorized states may choose not to adopt them. Nitroglycerine will remain regulated as P081 in states that do not adopt the new rules.
 
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.
 
02/01/2003Proposed Revisions to the Hazardous Waste Identification Rule (HWIR)Publication
 Description: This fact sheet provides background information about the hazardous waste identification rule, and gives a summary of revisions to the rule that EPA is proposing to make.
 
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.
 
11/15/2002REGULATION AND DISPOSAL REQUIREMENTS FOR SODIUM AZIDEMemo
 Description: RCRA regulates the management of wastes containing sodium azide in certain circumstances, including disposal of commercial sodium azide, disposal of wastes from the manufacture of explosives, and disposal of wastes that, when mixed with water, generate toxic gases in quantities sufficient to present a danger to human health or the environment. States may have more stringent or more specific waste management regulations. The Occupational Safety and Health Administration (OSHA) governs safety procedures for managing various classes of explosives and has general guidelines for handling chemicals and risk communication.
 
11/01/2002APPLICABILITY OF LDR TO BEVILL MIXTURESQuestion & Answer
 Description: A mixture of a Bevill-exempt waste and a characteristic waste (or a waste listed solely for exhibiting a characteristic) remains subject to the land disposal restrictions (LDR) even if it is no longer hazardous at the point of land disposal. A Bevill mixture is hazardous if it exhibits a characteristic of the non-excluded waste, but not if it exhibits a characteristic imparted by the Bevill waste. LDR attaches at the point of generation. A Bevill mixture must be treated for characteristics and underlying hazardous constituents (UHCs) attributed to the non-excluded portion, but not UHCs uniquely contributed by the Bevill portion. A facility remains subject to all applicable LDR notification requirements. The act of mixing a hazardous waste with a Bevill-exempt waste to render it nonhazardous is treatment, may require a permit, and may be a form of impermissible dilution.
 
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.
 
10/01/2002APPLICABILITY OF HAZARDOUS WASTE IDENTIFICATION RULE (HWIR) TO AS-GENERATED WASTESQuestion & Answer
 Description: A waste listed solely for the characteristic of ignitability, corrosivity, and/or reactivity (i.e., hazard code I, C, and/or R) that does not exhibit a characteristic at the point of generation is not considered a listed hazardous waste and is not subject to the land disposal restrictions (LDR) requirements. A waste listed solely for the characteristic of ignitability, corrosivity, and/or reactivity that exhibits a characteristic at the point of generation and subsequently loses the characteristic is no longer considered a listed hazardous waste, but is still subject to LDR requirements (SEE ALSO: 66 FR 27266; 5/16/01).
 
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.
 
09/01/2002MIXTURE RULE EXCLUSION FOR WASTEWATER CONTAINING TOXIC WASTEQuestion & Answer
 Description: The 261.3(a)(2)(iv)(E) exclusion from the mixture rule applies to wastes listed as toxic wastes (T) and as characteristic wastes (i.e., I, C, or R), as long as the annualized average flow of laboratory wastewater into the facility's headworks does not exceed one percent of the total flow, or the combined average concentration of toxic constituents entering the headworks or pretreatment system does not exceed one ppm. Sludges generated during wastewater treatment are subject to Subtitle C if they exhibit a hazardous waste characteristic.
 
08/16/2002HAZARDOUS WASTE GENERATED IN LABORATORIESMemo
 Description: Academic institutions may be large quantity generators (LQGs) or small quantity generators (SQGs). Most laboratory hazardous waste (HW) initially accumulates in satellite accumulation areas. The HW determination is not limited to the individual producing the HW. Any lab personnel, environmental health and safety (EH&S) personnel, or other individual meeting the definition of "person" can make the HW determination and should obtain all necessary information. EPA does not address where to make the HW determination. LQGs and SQGs can conduct on-site treatment of HW in tanks and containers without a permit, except for thermal treatment. Generators can transfer HW between accumulation units. Waste destined for land disposal must comply with the land disposal restrictions (LDR). Generators who treat HW on site in non-permitted units to remove characteristics must have a waste analysis plan (WAP). On-site recycling and HW treatment in exempt units do not require a permit, but prior storage is subject to RCRA. EPA proposed streamlined permitting requirements for generators storing HW longer than their respective accumulation times (SEE ALSO: 66 FR 52192; 10/12/01).
 
08/08/2002REGULATORY STATUS OF CRUDE SULFATE TURPENTINE (CST) UNDER RCRAMemo
 Description: Crude sulfate turpentine (CST) is not a solid waste when it is burned for energy recovery because it is a commercial chemical product (CCP) that is itself a fuel (SEE ALSO: 50 FR 14219; 4/11/85). EPA rejected using turpentine as a benchmark fuel in establishing comparable fuel specifications, since CST is not widely used as a fuel (SEE ALSO: 63 FR 33782, 33785; 6/14/99). CST contains hydrogen sulfide that can pose health risks, thus it should be managed in accordance with applicable OSHA standards.
 
08/01/2002HAZARDOUS CHARACTERISTIC SCOPING STUDYMemo
 Description: The Hazardous Waste Characteristics Scoping Study reviewed the effectiveness of the current hazardous waste characteristics regulations to identify whether other waste properties should be used to classify waste as hazardous or if the current characteristics should be expanded. EPA also collected data on toxic chemical releases from landfills. The current regulations ensure that most hazardous waste is addressed properly, but the Scoping Study identified areas that deserve additional investigation, including waste constituent releases to air and identifying supplements to the Toxicity Characteristic Leaching Procedure (TCLP). EPA has set priorities for completion of follow-up studies. Any revision of the TC regulation would have to take into account a number of considerations, including updated groundwater models.
 
07/29/2002RESULTS OF HAZARDOUS CHARACTERISTIC SCOPING STUDYMemo
 Description: The Hazardous Waste Characteristics Scoping Study did not identify hazards that warrant regulatory changes, but identified areas that deserve additional investigation, including waste constituent releases to air and identifying supplements to the Toxicity Characteristic Leaching Procedure (TCLP). EPA collected data on toxic chemical releases from landfills. The toxicity characteristic (TC) regulation remains an appropriate tool for defining hazardous waste. EPA will continue to examine the hazardous waste characteristics. States may develop regulations that are more inclusive than the federal program.
 
07/17/2002SCOPE AND APPLICABILITY OF RCRA REGULATIONS AT WOOD PRESERVING FACILITIESMemo
 Description: Whether stormwater runoff from pentachlorophenol treated wood is a hazardous waste (e.g., F032) depends on site-specific factors. Stormwater that contacts preservative solutions or listed waste is hazardous via the contained-in policy. Precipitation runoff in storage yards is not F032 and drippage does not constitute illegal disposal, provided the facility complies with Subpart W. Steam from wood preserving equipment that condenses and settles away from the equipment is not F032, F034, or F035. A facility operating a tank-based zero discharge system is considered subject to the CWA for the purposes of the wastewater treatment unit (WWTU) definition. Drip pads are not required in storage yards, provided that any infrequent and incidental drippage is immediately responded to as outlined in the facility contingency plan. Infrequent and incidental drippage determinations are site-specific. Whether the presence of hazardous contaminants in soil indicates illegal disposal is determined on a case-by-case basis. State regulations can be more stringent.
 
06/14/2002HAZARDOUS CHARACTERISTIC SCOPING STUDYMemo
 Description: The Hazardous Waste Characteristics Scoping Study reviewed the effectiveness of the current hazardous waste characteristics regulations to identify whether other waste properties should be used to classify waste as hazardous or if the current characteristics should be expanded. EPA also collected data on toxic chemical releases from landfills. The current regulations ensure that most hazardous waste is addressed properly, but the Scoping Study identified areas that deserve additional investigation, including waste constituent releases to air and identifying supplements to the Toxicity Characteristic Leaching Procedure (TCLP). EPA has set priorities for completion of follow-up studies. Any revision of the TC regulation would have to take into account a number of considerations, including updated groundwater models.
 
05/20/2002POINT OF GENERATION FOR SPRAY PAINTING OPERATIONSMemo
 Description: The point of generation of hazardous waste from spray painting operations is at the emergence from the spray paint gun. EPA is working on maximum achievable control technology (MACT) standards for emissions from transporting the waste inside the auto plant building. EPA is also working on Subpart J guidance to reduce or eliminate industry burden, while ensuring that leaks are properly captured and contained.
 
05/16/2002REGULATORY STATUS OF VANADIUM-CONTAINING WASTE (SPENT STRETFORD SOLUTION)Memo
 Description: The consent decree in EDF v. Browner, Civ. No. 89-0598 (D.D.C.), required EPA to decide whether or not to list several categories of petroleum refining wastes and to prepare a report on other waste categories. EPA determined that sludges from the Stretford process (which contain vanadium salts), catalysts from sulfur complex and H2S facilities, and vanadium-containing Stretford or Beavon-Stretford solutions do not require listing determinations (SEE ALSO: Listing Background Document for 1992-1996 Petroleum Refining Listing Determination, Study of Selected Petroleum Refining Residuals, and 63 FR 42110; 8/6/98). Hazardous waste listing determinations are wastestream-specific, not constituent-specific. Vanadium does not present sufficient risk to provide a basis for listing. EPA is deferring the use of the persistence, bioaccumulative, and toxic (PBT) criteria for metals in its waste minimization program, since it is working to develop an Agency-wide approach. The Science Advisory Board (SAB) will review the 3MRA model, which estimates the chemical release, fate, exposure and resulting risks to human health and the environment (SEE ALSO: 64 FR 63382; 11/19/99).
 
05/06/2002REGULATORY STATUS OF SOLVENT-CONTAMINATED SHOP TOWELSMemo
 Description: EPA has not determined what regulatory action is appropriate for solvent-contaminated shop towels. EPA may provide an exclusion from the definition of solid waste for these items. States have policies for contaminated wipes, but the regulations differ from state to state. Generators have petitioned EPA for federal regulations to promote regulatory consistency. EPA is working with stakeholders to develop a proposal that ensures environmentally sound management, is cost-effective, and encourages source reduction and recycling of the hazardous solvents.
 
05/01/2002REGULATORY STATUS OF SOLVENT-CONTAMINATED SHOP TOWELSMemo
 Description: EPA may provide an exclusion from the definition of solid waste for solvent-contaminated shop towels. States have policies for contaminated wipes, but regulations differ from state to state. Generators have petitioned EPA for federal regulations to promote regulatory consistency. EPA is working with stakeholders to develop a proposal, which ensures that solvent-contaminated shop towels are managed in an environmentally sound manner at the lowest possible cost to the regulated community.
 
03/01/2002Environmental Fact Sheet: Paint Wastes Not Listed as Hazardous WastePublication
 Description: EPA proposed concentration-based listings for certain paint waste solids (K179) and liquids (K180) on February 13, 2001 (66 FR 10060). Following a review of public comments and supplemental analyses based on public comments, EPA determined that these paint wastes should not be listed as hazardous waste.
 
02/01/2002Environmental Fact Sheet: EPA Proposing to Allow Waste as an Energy Source for Synthesis Gas Production and Power GenerationPublication
 Description: EPA is proposing to conditionally exclude, from RCRA’s definition of solid waste, hazardous secondary materials that are processed in gasification systems to manufacture synthesis gas.
 
01/31/2002REUSE OF REGENERATED HYDROPROCESSING CATALYSTSMemo
 Description: EPA listed certain spent hydroprocessing catalysts (i.e., K171 and K172) as hazardous wastes (SEE ALSO: 63 FR 42110; 8/6/98). Prior to reclamation or regeneration, these materials are considered spent listed wastes and are subject to all applicable RCRA requirements. After regeneration, they would be excluded from RCRA if they are reused as effective substitutes for commercial products (i.e., as substitutes for new catalysts). Criterion's enhancement process is used to augment regenerated catalysts that are already viable commercial chemical products (CCPs) and thus, does not constitute further reclamation. State regulations can be more stringent than the federal regulations.
 
01/01/2002F003 WASTES GENERATED PRIOR TO HWIR WASTE RULEQuestion & Answer
 Description: The new HWIR-Waste Rule is less stringent than the prior regulation, so states are not required to amend their authorized programs. In states authorized for the new exlcusion, wastes listed solely for exhibiting the characteristic of ignitability, corrosivity, or reactivity are no longer hazardous when they do not exhibit a characteristic. A mixture of a non-characteristic F003 waste generated after the effective date and a non-characteristic F003 waste generated before the effective date, will not carry the F003 waste code if resultant mixture is non-characteristic. If states are not authorized for 261.3(g), then the mixture would continue to carry the F003 code. (SEE ALSO: 66 FR 27266; 5/16/01)
 
12/11/2001CLARIFICATION OF THE NEW MIXTURE AND DERIVED-FROM RULES FOR F003Memo
 Description: Section 261.3(g)(1) generally exempts hazardous waste originally listed as F003 if it no longer exhibits the characteristic of ignitability. Mixtures of solid waste and F003 wastes and wastes derived-from F003 are no longer hazardous and the F003 code is removed if the subsequent wastes no longer exhibit the characteristic of ignitability. F003 land disposal restrictions (LDR) requirements are still applicable to the exempted waste if it exhibited the characteristic of ignitability at the point of generation, regardless of whether it is ignitable at the point of land disposal. If a waste that meets the F003 listing contains 10% or more of the other F-listed solvents (F001, F002, F004 and/or F005) but is not ignitable or if a waste that meets the F003 listing is mixed with another listed waste and is not ignitable, then the F003 waste code would be dropped, all other waste codes would be retained.
 
10/11/2001REGULATORY STATUS OF ANTIMONY OXIDE SLAGMemo
 Description: Currently antimony oxide slag is not a hazardous waste because a final decision has not been made to list the slag as hazardous (SEE ALSO: 66 FR 58258; 11/20/01). The management of any secondary material, including use in the production of a product, may be subject to state regulations. A waste that is actively managed after the effective date of a listing would be subject to the listing. Slag used as an ingredient in product asphalt prior to the effective date of the listing would not be a hazardous waste when actively managed after the effective date of the listing, unless it exhibited a hazardous waste characteristic. Since the listing does not apply at the time of use, the use would not be subject to RCRA jurisdiction. Any releases from the material to the environment could be considered wastes and addressed under Section 7003 of RCRA.
 
10/01/2001REMEDIATION OF TNT-CONTAMINATED SOILQuestion & Answer
 Description: Pink/red water from soil remediation at a TNT production facility would be listed as K047 only if the contamination is attributable to the production of TNT. Examples include TNT purification filtrates and air pollution control scrubber effluents. If a TNT-containing product is sold, shipped, or used, but not manufactured at a facility, then any wastewater resulting from the remediation of soil contaminated by the TNT product would not be regulated as K047.
 
05/17/2001REGULATORY STATUS OF DROP-OUT SLAG GENERATED AT ELECTRIC ARC FURNACESMemo
 Description: Drop-out box slag (DOBS) generated at electric arc furnaces (EAFs) is not covered by the K061 listing, which includes dust and sludge from EAF emissions. DOBS does not meet the description of dust or sludge as defined in the K061 Listing Background Document. Material in ductwork leading to or collected in air pollution control devices may meet the K061 definition. DOBS may exhibit the toxicity characteristic for various metals, but would not be a solid waste if sent for legitimate recycling.
 
05/02/2001RECYCLED ARCTIC GRADE DIESELMemo
 Description: Diesel oil hydrocarbons generated at exploration and production sites, where these hydrocarbons are returned to the petroleum refining process, are excluded from the definition of solid waste pursuant to 261.4(a)(12)(ii). This exclusion does not apply to recovered oils that are managed on the land, nor those that are speculatively accumulated before being recycled back into the refining process. Spills and other discarded diesel that are not recovered and returned to a refinery would not be excluded under this provision.
 
01/19/2001SCIENCE ADVISORY BOARD RECOMMENDATIONS TO PROMOTE INCREASED WASTE UTILIZATIONMemo
 Description: This memo contains the OSWER response to Science Advisory Board (SAB) recommendations on overcoming barriers to waste utilization. OSW has amended the definition of solid waste and hazardous waste recycling requirements several times to encourage recovery. OSW has studied cement kiln dust (CKD) and fossil fuel combustion waste utilization. OSW and the Office of Research and Development (ORD) have developed an environmental fate and transport model called the 3MRA Model for estimating "exit levels" for waste. OSW has designated items containing recovered materials in the Comprehensive Procurement Guidelines (CPG) and supported the Extended Product Responsibility (EPR) and the Jobs Through Recycling (JTR) programs. EPA supports the development of guidance manuals on waste utilization and innovative technology development programs for the large-scale utilization of waste materials.
 
12/27/2000APPLICABILITY OF RCRA SECTION 3020 TO IN-SITU TREATMENT OF GROUND WATERMemo
 Description: NO SIGNED PAPER COPY AVAILABLE - Reinjection of treated groundwater to promote in-situ treatment is allowed under RCRA 3020(b) as long as certain conditions are met: groundwater must be treated prior to reinjection; treatment must be intended to substantially reduce hazardous constituents in groundwater either before or after reinjection; cleanup must be protective of human health and environment; and injection must be part of RCRA corrective action or response action under CERCLA 104 or 106 (SEE ALSO: OSWER Directive 9234.1-06; December 27, 1989).
 
11/30/2000SULFURIC ACID RECYCLING IN THE SEMICONDUCTOR INDUSTRYMemo
 Description: Secondary materials used or reused as ingredients in an industrial process to make a product are excluded from RCRA hazardous waste regulation. “Reclaimed” secondary materials are not eligible for this exclusion. Filtration occurring near the end of the process when it is already in essence a completed product may not constitute reclamation. The filter removes only minute quantities of particulate matter to guarantee the physical quality of the product, not to reclaim the secondary material in any meaningful sense (SEE ALSO: 50 FR 634; 1/4/85 and Memo, Straus to Lawrence; 5/30/86 (RO 11159)). Water added to the input acid is necessary for the final product and does not dilute the wastestream to remove a hazardous waste characteristic or circumvent regulation. (SEE ALSO: Memo, Lowrance to Directors; 4/26/89 (RO 11426))
 
07/31/2000REGULATORY STATUS OF WASTE GENERATED BY CONTRACTORS AND RESIDENTS FROM LEAD-BASED PAINT ACTIVITIES CONDUCTED IN HOUSEHOLDSMemo
 Description: Lead-based paint (LBP) debris generated by contractors in households is excluded household hazardous waste. LBP waste from abatement, renovation, and remodeling in homes and other residences eligible for exclusion. LBP waste from households may be subject to state, local and/or tribal government regulation (SEE ALSO: 63 FR 70233; 12/18/1998).
 
06/07/2000REGULATION OF CONCRETE RESIDUALS AS HAZARDOUS WASTEMemo
 Description: Concrete products are not regulated under RCRA, which governs the management of waste. EPA has no plans to develop new regulations which would classify concrete residuals or by-products as hazardous wastes.
 
06/01/2000REQUEST FOR CLARIFICATION OF ISSUES RAISED BY EPA'S NOVEMBER 29, 1999 MEMO ON THE "PETROLEUM REFINERY RESIDUAL LISTINGS/ SOLID WASTE DEFINITION EXCLUSION RULE" (63 FR 42110, AUGUST 6, 1998)Memo
 Description: Spent catalysts from petroleum hydroprocessors performing treating function are listed hazardous waste (K171). EPA does not consider spent catalysts from petroleum hydroprocessing reactors to be a listed hazardous waste solely because some incidental and minimal amount of hydrotreatment occurs in hydrocracking reactors. EPA reserves right to conduct listing determination on spent hydrocracking catalyst in the future. Spent hydrocracking catalyst are subject to hazardous waste characteristic determination (SEE ALSO: 66 FR 35379; 7/5/01).
 
06/01/2000REQUEST FOR CLARIFICATION, SPENT CATALYSTS FROM MOTIVA ENTERPRISES LLC, CONVENT REFINERY H-OIL UNITMemo
 Description: Spent catalysts from dual purpose petroleum hydroprocessor performing substantial hydrotreating function are listed hazardous wastes (K171) (SEE ALSO: RPC# 11/29/99-01).
 
06/01/2000SPENT CATALYSTS FROM PETROLEUM REFINING DUAL PROCESS REACTORSMemo
 Description: Spent catalysts from dual purpose petroleum hydroprocessor performing substantial hydrotreating function are listed hazardous wastes (K171 or K172). Listing does not apply to spent catalysts solely because some incidental and minimal amount of hydrotreatment occurs in unit. Spent hydrocracking catalyst are subject to hazardous waste characteristic determination (SEE ALSO: RPC# 11/29/99-01).
 
05/25/2000TOTAL WASTE ANALYSIS ON POTW BIOSOLIDS AND CERCLA LIABILITYMemo
 Description: Generator must determine if waste exhibits toxicity characteristic (TC) by testing or applying knowledge. Using total constituent concentrations in waste is one type of generator knowledge. EPA does not presume waste is TC hazardous if 1/20th the total constituent concentrations in waste exceed TC regulation levels. RCRA Online letters do not constitute EPA policy. Domestic sewage exclusion would not exonerate sewage generators from potential liability under CERCLA 107(a)(3) if the generators’ discharges include CERCLA hazardous substances. A generator may be shielded from liability due to federally permitted release statutory provisions in CERCLA 107(j). Placement of biosolids on land may constitute normal application of fertilizer in CERCLA 101(22)(D) and exempt the generator from liability;. To evaluate normal application of fertilizer, EPA would consider, among other things, compliance with Clean Water Act 405(d) and application rates.
 
03/28/2000PLACEMENT OF SEWAGE SLUDGE ON FARMSMemo
 Description: Domestic sewage exclusion regulatory language elaborates on statutory language by adding to exclusion mixtures of domestic sewage and other wastes. Domestic sewage exclusion applies to wastes which mix with sanitary wastes in sewer system leading to POTW. Hazardous waste delivered to POTW by truck, rail, or dedicated pipe subjects POTW to permit-by-rule requirements. Mixture and derived-from rules apply to hazardous wastes that are not excluded.
 
03/10/2000PERMITTING OF MOLTEN SALT OXIDATION PROCESSMemo
 Description: Miscellaneous unit regulations specify environmental performance standards. Permitting agency will specify terms and provisions from other sections of regulations as technical standards. EPA expects permit writer to look to new maximum achievable control technology (MACT) incinerator air emissions standards for miscellaneous unit. Spent salt from molten salt oxidation (MSO) process may be hazardous waste via derived-from rule. Permitting authority may require risk assessment be completed. Heavy metals are of concern since they are not destroyed by treatment. Units treating waste containing polychlorinated biphenyls (PCBs) may need RCRA and TSCA permits in order to operate. Mixed waste is dually regulated in most states by both EPA and Nuclear Regulatory Commission (NRC).
 
12/09/1999AGENCY ACTIVITIES IN RESPONSE TO THE 1996 HAZARDOUS WASTE CHARACTERISTICS SCOPING STUDYMemo
 Description: Hazardous Waste Characteristics Scoping Study identified a number of potential gaps in the hazardous characteristics regulatory program. EPA describes potential gaps and efforts to further address them. Discusses the release of final Air Characteristic Study report; review of TCLP test and concerns regarding alkaline waste and oily waste. Work on replacement guidance for withdrawn sulfide and cyanide reactivity test guidance proceeding at low level of activity due to competing priorities. Discusses development of tools for evaluation of ecological risks from waste.
 
12/08/1999INTERPRETATION OF THE RCRA IGNITABILITY CHARACTERISTIC WITH REGARD TO ACETONE WIPESMemo
 Description: Whether solvent-contaminated rags, wipers, or towels contain a listed hazardous waste, are mixed with a listed hazardous waste, only exhibit a characteristic, or are not a waste at all depends on site-specific factors best evaluated by Region or State implementing agency (SEE ALSO: RPC# 2/14/94-01). ASTM Method D4982-89, Method A is not appropriate for determining ignitability. Method 1030 assesses a solids tendency to burn vigorously and persistently, but does not address the mode of ignition. Ignitability for non-liquids should be determined using generator knowledge.
 
11/29/1999SPENT CATALYSTS FROM PETROLEUM REFINING DUAL PROCESS UNITSMemo
 Description: Spent catalysts from petroleum hydroprocessors performing hydrotreating or hydrorefining operations are captured by the K171 and K172 listings, regardless of whether hydrocracking also occurs in a dual purpose unit. EPA differentiates between hydrocracking and the other two petroleum hydroprocessing operations by relying upon the definitions of these processes in DOE’s Petroleum Supply Annual (PSA) (SEE ALSO: 66 FR 35379; 7/5/01).
 
11/16/1999INTERPRETATION OF FEDERAL USED OIL REGULATIONSMemo
 Description: Spent petroleum-based solvents do not meet definition of used oil. Sent petroleum-based solvents are subject to hazardous waste determination. Spent petroleum-based solvents that are intentionally mixed with used oil (e.g., to make fuel oils) can be regulated as used oil under 279.10(b). Hazardous waste determination required prior to mixing.
 
11/01/1999LABORATORY SAMPLES AND THE BEVILL EXCLUSION (SECTION 261.4(B)(7))Question & Answer
 Description: Laboratory samples are not uniquely associated with mining, and thus are not exempt under the Bevill exclusion for mining and mineral processing. Laboratory activities are considered ancillary operations (SEE ALSO: 63 FR 28556; 5/26/98).
 
10/28/1999SPENT CATALYSTS FROM PETROLEUM REFINING HYDROCRACKING PROCESSESMemo
 Description: EPA made no formal listing determination for spent hydrocracking catalysts generated by petroleum refineries. Agency listed spent hydrotreating catalysts (K171) and spent hydrorefining catalyst (K172). No action regarding a listing determination is not the same as “no list” determination. Spent hydrocracking catalysts may exhibit characteristics of toxicity or ignitability (SEE ALSO: 63 FR 42110; 8/6/98).
 
09/13/1999SLUDGES FROM WASTEWATER MIXTURESMemo
 Description: Wastewater treatment sludges from mixture of wastewater that is precursor to listed waste sludge and wastewater that is not precursor to listed waste sludge are covered by listing description (e.g., F006, F012, F019, K001-K007, K151, K106, K032, K035, K037, K040, K041, K044, K046, K066, K084). United States v. Bethlehem Steel Corp. decision held that F006 listing did not apply to sludges from combined wastewater streams. Bethlehem Steel decision binding only on district courts in Seventh District (independent of the mixture rule). Sludges from mixed wastewaters are RCRA hazardous wastes under mixture rule (261.3(a)(2)(iv)), regardless of the court’s decision.
 
07/01/1999RESIDUES FROM THE TRIAL BURN OF LISTED HAZARDOUS WASTESQuestion & Answer
 Description: Residue from trial burn of listed hazardous waste mixture is listed hazardous waste via derived-from rule (261.3(c)(2)(i))(SEE ALSO: 66 FR 27266; 5/16/01). Permit applicant for incinerator is not absolved from identifying solid and hazardous waste generated from trial burn.
 
06/01/1999SPENT SULFURIC ACID EXCLUSION AND USE CONSTITUTING DISPOSALQuestion & Answer
 Description: Spent sulfuric acid used to produce virgin sulfuric acid per 261.4(a)(7) is not a solid waste, regardless of how the facility subsequently utilizes the virgin sulfuric acid. Excluded sulfuric acid incorporated into a fertilizer is not waste-derived and is not regulated when applied to the land. The entire recycling process must be considered for a material not specifically excluded under 261.4(a).
 
05/20/1999CLASSIFICATION AND DISPOSAL OF UNUSED FLAMELESS RATION HEATERSMemo
 Description: Unused Flameless Ration Heaters (FRH) for the Army’s Meals Ready to Eat (MRE) may be a reactive (D003) hazardous waste when disposed. The Department of the Army (DOA) has developed several management options for FRHs including reuse, incineration, and/or treatment and disposal. Products that have not been used, and which are to be used for their original purpose, are generally not wastes under RCRA. Unused commercial chemical products (CCPs) being reclaimed are not regulated as wastes. FRHs may be reacted with water and then disposed of as ordinary wastes if treatment is conducted in accordance with applicable requirements and if land disposal restrictions (LDR) requirements are met before land disposal. Some states may have more stringent requirements. The disposal of spent FRH materials, following normal use to heat a MRE, is not disposal of a hazardous waste.
 
03/19/1999REGULATORY STATUS OF USED CRUCIBLES AND CUPELSMemo
 Description: Used crucibles and cupels are laboratory wastes. Laboratory wastes are not uniquely associated with mining, and thus are not exempt under the Bevill exclusion for mining and mineral processing wastes (SEE ALSO: 63 FR 28556; 5/26/98). Used crucibles and cupels are spent materials, and therefore would be solid wastes when reclaimed. Reclaimed materials are not eligible for the 261.2(e) use/reuse exemption.
 
03/18/1999REGULATORY STATUS OF SPENT GRANULATED ACTIVATED CARBON AND ION EXCHANGE COLUMNSMemo
 Description: Ion exchange filters meeting the definition of spent material and sludge are considered sludges since the definition of sludge is more narrow. Spent filters used within an electroplating process may be F006. The fate of the effluent does not affect the status of the filters (i.e., the effluent can be returned to the process or it can be passed on to other processes) (SEE ALSO: RPC# 7/21/94-02);. A wastewater treatment unit (WWTU) does not have to be subject to the CWA to generate a sludge, but must be subject to CWA to be an exempt unit.
 
01/01/1999PICKLING BATH CARRYOVER AND K062Question & Answer
 Description: Rinsewater contaminated with small amounts of pickling liquor carried over (carryover, dragout) to rinse tanks during normal steel finishing process is not considered K062 via the mixture rule. The pickling solution is a material in use, and is not waste until it is spent and removed from the process (SEE ALSO: RPC# 4/7/88-01; RPC# 7/28/87-02).
 
10/14/1998MANAGEMENT OF REMEDIATION WASTES UNDER RCRAMemo
 Description: This memo consolidates existing guidance on the RCRA regulations and policies that most often affect remediation waste management. It discusses, among other topics, the contained-in policy, the area of contamination (AOC) policy, corrective action management units (CAMUs) and temporary units (TUs), land disposal restrictions (LDR) applicability and the alternative standards for soils and debris, the treatability studies exemption, reinjection of contaminated groundwater (RCRA 3020(b)), and permit waivers (RCRA 7003) and emergency permits.
 
09/28/1998HAZARDOUS WASTE DETERMINATION FOR KEVLAR SOFT BODY ARMORMemo
 Description: EPA believes that discarded soft body armor (SBA) made from Kevlar is not a hazardous waste. State laws and regulations may be more stringent than federal hazardous waste regulations.
 
08/21/1998REGULATORY STATUS OF USED PARTS WASHING SOLVENTMemo
 Description: A used solvent employed for another solvent use without reclamation remains a product (continued use). Used parts washing solvent employed for drum washing without reclamation is not a spent material and is not a solid waste provided it is legitimately recycled. After the solvent is used for drum washing, any residuals solvents are subject to a hazardous waste determination. If any part of a shipment of solvent is reclaimed, burned for energy recovery, or otherwise defined as a solid and hazardous waste, the entire shipment is subject to hazardous waste regulation.
 
07/27/1998REGULATORY ACTION BASED ON AIR CHARACTERISTIC STUDYMemo
 Description: Study entitled “Potential Inhalation Risks due to Air Emissions from Certain Waste Management Units” (Air Characteristic Study) completed May 1998. EPA has decided not to pursue initiation of proposal for air characteristic under RCRA to address risks from inhalation.
 
07/15/1998SCOPE OF THE EXCLUSION FROM THE DEFINITION OF SOLID WASTE FOR CHARACTERISTIC BY-PRODUCTS BEING RECLAIMEDMemo
 Description: Characteristic by-products being reclaimed may be placed or stored in a land based unit (e.g., waste pile) without affecting their exclusion from the definition of solid waste. Characteristic by-products being reclaimed are not subject to the RCRA hazardous waste regulations, including the prohibition on land placement. The 261.2(e)(1)(iii) exclusion from the definition of solid waste is conditioned on no land placement.
 
07/15/1998SPENT METHYL BROMIDE ACTIVATED CARBON IS NOT U029Memo
 Description: Spent activated carbon used to capture methyl bromide that has been used for its intended purpose is not a listed U029 hazardous waste. The P and U lists apply to unused commercial chemical products. The spent carbon may still exhibit a characteristic of hazardous waste.
 
06/30/1998ISSUANCE OF FINAL HWIR-MEDIA RULEMemo
 Description: EPA considers the issuance of the Hazardous Waste Identification Rule for contaminated media (HWIR-Media) to be among its highest RCRA priorities. Signature of the final rule is expected no later than October 30, 1998 (HWIR-Media finalized 63 FR 65873; 11/30/98).
 
06/01/1998COMPARABLE FUELS EXCLUSIONMemo
 Description: EPA proposed an exclusion from the definition of solid waste for hazardous waste-derived fuels that meet specification levels comparable to fossil fuels for concentrations of hazardous constituents and for physical properties that affect burning (SEE ALSO: 63 FR 33782; 6/19/98). EPA believes this exclusion promotes beneficial energy recovery, reduces unnecessary regulatory burden, and demonstrates a common sense approach to regulation.
 
06/01/1998MANAGEMENT OF EMISSION CONTROL DUST FROM ELECTRIC ARC FURNACES IN BAGHOUSE SILOSMemo
 Description: Determining the applicability of RCRA to baghouse dust is generally made when the material is removed from the baghouse (point of generation) (SEE ALSO: RPC# 10/19/95-01). Where enclosed silos are integral to the baghouse dust handling system (e.g., connected to the baghouse via piping), the applicability of RCRA is determined when the material is removed from the silo. Long-term storage of material in the silo would indicate the silo is a waste storage unit and not simply a part of the electric arc furnace (EAF) emission control system.
 
05/19/1998PROVISIONAL ELIMINATION OF F032 WASTE CODEMemo
 Description: A provisional elimination of the F032 waste code for decontaminated equipment does not apply to contaminated soils. The original provision (55 FR 50450; 12/6/90) required new process wastes not to show any level of dioxin. The amendment (57 FR 61492; 12/24/92) specifies that facilities that switch to an alternative chemical (other than chlorophenol) are not required to identify their wastes as F032 as long as they continue to manage the waste as F034 or F035. Storage yard soils contaminated with infrequent or incidental drippage (kickback) would not carry a listing if wood preserving plants develop and implement a contingency plan for emergency response to drippage.
 
04/21/1998WITHDRAWAL OF CYANIDE AND SULFIDE GUIDANCEMemo
 Description: The cyanide and sulfide reactivity guidance is withdrawn (See RPC# 7/12/85-02). Critical errors were made in developing the original guidance. A Federal Register notice announcing the withdrawal of the guidance from SW-846 will be prepared soon. The Agency expects that generators should continue to classify their high concentration sulfide- and cyanide-bearing wastes as hazardous based on the narrative standard.
 
04/06/1998INTERACTION OF SPECULATIVE ACCUMULATION AND GENERATOR ACCUMULATION PROVISIONSMemo
 Description: A person accumulating potentially recyclable materials (not solid wastes under Section 261.2) becomes a generator when the materials become solid and hazardous wastes at the end of the speculative accumulation period. The generator can then hold the waste for 90 additional days (or 180/270 for small quantity generators) in compliance with Section 262.34 without a permit.
 
04/06/1998USE OF CAS NUMBERS AS HAZARDOUS WASTE IDENTIFICATION AIDMemo
 Description: Both anhydrous chloral and chloral hydrate are referenced generically as chloral and are regulated as U034. Even though the CAS number under the U034 listing corresponds to anhydrous chloral, CAS numbers are added solely as an identification aid. The hazardous waste codes in Sections 261.33(e) and (f) apply to all commercial chemical products or manufacturing intermediates having the generic name listed.
 
03/01/1998DE MINIMIS WASTEWATER MIXTURES SENT OFF SITEQuestion & Answer
 Description: The mixture rule exclusion at Section 261.3(a)(2)(iv)(D) applies only to mixtures of wastewaters and de minimis amounts of commercial chemical products that are sent to a facility's on-site wastewater treatment system discharging under CWA 307(b) or 402. If the wastewater mixture is shipped off-site by truck, the shipment must be delivered by a hazardous waste transporter and accompanied by a manifest. The manner in which the wastewater mixture is transported to an on-site wastewater treatment unit does not affect the exemption.
 
02/26/1998LIMITING METAL CATALYSTS IN COMPARABLE FUELSMemo
 Description: EPA believes that limiting total chlorine levels (including inorganic chlorine) in comparable fuels is appropriate to control emissions of chlorinated dioxins and other hydrocarbons. The Agency is not in a position to focus exclusively on the impact of metal catalysts to control chlorinated hydrocarbon (CHC) emissions.
 
02/13/1998CLARIFICATION OF THE REGULATORY STATUS OF AGGLOMERATED DROSSESMemo
 Description: Agglomerated drosses (from any source, not just scrap metal processing) can be classified as processed scrap metal and, if recycled, are excluded from the definition of solid waste. Agglomerated drosses are solid chunks of metal in a physical state that does not allow them to be easily crushed, split, or crumbled. Dross which has not been agglomerated is by-product, not scrap metal. Agglomerated drosses used in a manner constituting disposal are excluded scrap metal being recycled and thus not solid waste. Drosses that have not been agglomerated are solid wastes when used in a manner constituting disposal.
 
02/02/1998REGULATORY STATUS OF GASOLINE SPILLSMemo
 Description: A gasoline spill on the ground at a product storage facility could be a solid waste because the product has been discarded by being abandoned. Disposal of a hazardous waste has occurred if the spilled and abandoned material exhibits a characteristic. Spilled gasoline becomes a waste when it exits the unit, enters the environment, and is not promptly recovered or cleaned up. An implementing agency can require cleanup of a spill to site-specific levels. In rare cases, the spill area may be considered a land disposal unit (SEE ALSO: RPC# 9/29/1986-02). The recovered free product is potentially not a solid waste if it is reused for its original purpose or reclaimed.
 
01/06/1998CLASSIFICATION OF SPILLED TOLUENE AS U220 HAZARDOUS WASTEMemo
 Description: Off-specification commercial chemical product (CCP) is an unused material that would have been a CCP if it met specifications. EPA has not set exact concentrations for a CCP to be considered off-specification. A material can be off-specification CCP if it is contaminated without being used for its intended purpose (e.g., during storage). If a material is contaminated via normal use, it would be a spent material. A spent material can regain its unused CCP status if the material is reclaimed and requires no additional processing before it can be used beneficially. Used toluene spilled from a storage tank may meet F005 listing or may exhibit a characteristic (such as ignitability).
 
11/20/1997REGULATORY STATUS OF ETHYLENE GLYCOLMemo
 Description: Pure, unused ethylene glycol and unused antifreeze containing ethylene glycol are not hazardous wastes until a decision is made to discard these products. Since they are not listed hazardous wastes, they would be hazardous only if they exhibited one of the hazardous waste characteristics. Ethylene glycol is included on the list of chemicals subject to reporting requirements under Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA).
 
10/20/1997USE OF HAZARDOUS WASTE AS INGREDIENT IN FERTILIZERS AND SOIL AMENDMENTSMemo
 Description: The Agency has created a multi-disciplinary workgroup to evaluate and assess the nature and extent of any possible risks posed by the use of fertilizers that contain heavy metals and other potentially toxic compounds. EPA will then identify whether appropriate government actions are needed. Provides a brief summary of regulatory provisions governing hazardous waste derived fertilizers.
 
10/01/1997REEXAMINATION OF PROPOSED EXCLUSION FOR OIL-BEARING RESIDUALSMemo
 Description: EPA proposed to broaden the recovered oil exclusion to include all oil-bearing hazardous wastes inserted into the refining process (60 FR 57747; 11/20/95). EPA did not intend to create a loophole from hazardous waste status for residual materials left over from the recycling process (e.g., residuals generated from deoiling excluded sludges that are not themselves reinserted into the refinery) (SEE ALSO: 63 FR 42110; 8/6/98, and new F037 listing).
 
09/03/1997HAZARDOUS WASTE LISTING DETERMINATION FOR ORGANOBROMINE PRODUCTION WASTESMemo
 Description: EPA continues to believe that solids and filter cartridges from the production of 2,4,6-tribromophenol warrant listing. In response to comments and information received since the organobromines proposal (59 FR 24530; 5/11/94) (SEE ALSO: 63 FR 24596; 5/4/98), EPA reexamined the listing decision. This letter provides notice and explanation of EPA's further evaluation of the listing. decision. EPA will accept comment on the additional information up to 30 days from the date of letter issuance (SUPERSEDED: Organobromine listings vacated; see 65 FR 14472; 3/17/00) .
 
08/14/1997REGULATORY STATUS OF USED NICKEL CATALYSTMemo
 Description: Discusses the regulatory status of spent catalyst being reclaimed. A material is reclaimed if it is processed to recover a usable product, or if it is regenerated. The hazardous waste determination is the generator’s responsibility. Determination is made by evaluating the waste using a required test or by comparing the properties of the waste with the narrative standard. A lack of required test for ignitability of solids and reactivity does not prohibit consideration of test data where there is reason to question the generator’s RCRA determination.
 
07/25/1997INCORPORATION OF PRETOX 2000 INTO LEADED PAINT STRIPPERMemo
 Description: Leaded paint scrapings and blasted paint typically fail the toxicity characteristic for lead. Use of additives in paint strippers or blasting grit to mask the leaching of hazardous constituents is not illegal under current regulations, but any masking may only be temporary. Use of such materials does not relieve the generator of CERCLA liability.
 
06/03/1997REGULATORY STATUS OF SOLVENT RECOVERY UNITSMemo
 Description: All secondary materials (e.g., process solvents from agricultural chemical manufacturing process and automotive paint manufacturing process) must be returned to the production process to qualify for the closed-loop recycling exclusion. A process which returns 80% of xylene and sends 20% of recovered xylene off as product does not qualify. Production process includes activities that tie directly into the manufacturing operation or are the primary operation at a facility.
 
05/23/1997REQUEST FOR OPINION REGARDING CARBAMATE WASTE GENERATED BY CYTEC INDUSTRIES INC.Memo
 Description: The K156 listing (organic wastes from the production of carbamates and carbamoyl oximes) includes wastes from the production of methyl carbamate. Carbamate is a salt or ester of carbamic acid and methyl carbamate is the simplest ester of carbamic acid. A generator may petition for a delisting if the wastestream does not contain hazardous constituents that are the basis for listing K156. Industry may challenge a final rule during the 90 day period after the rule is promulgated (RCRA 7006(a)(1)).
 
05/22/1997HOW IGNITABLE SOLIDS AND SOLVENT CONTAMINATED RAGS OR SHOP TOWELS FIT INTO D001 CHARACTERISTIC OF IGNITABILITYMemo
 Description: Solvent contaminated rags and towels may be hazardous waste if they exhibit a hazardous waste characteristic. EPA recommends that states or regional offices make such determinations on a site-specific basis. EPA does not currently have a method to determine the ignitability of solids (SUPERSEDED: Method 1030 introduced in 62 FR 32451; 6/13/97). In determining the ignitability of rags, consider the type and amount of solvent used, the type and number of rags used, and how the rags are stored. Solvent contaminated rags with no free liquids are still capable of exhibiting the ignitability characteristic (D001). Rags placed in a container can force free liquid into the bottom of the container through force of gravity. Rags placed in an environment with oxygen present may meet criteria in 261.21(a)(2).
 
05/19/1997RULES FOR DISPOSAL OF DISCARDED CONCRETEMemo
 Description: Concrete has not been identified by EPA as listed hazardous waste. Common concrete is not likely to exhibit any of the characteristics of hazardous waste. Authorized states can establish more stringent requirements and may have their own rules regarding nonhazardous waste or debris.
 
03/12/1997RCRA APPLICABILITY TO PAINT REMOVAL WASTESMemo
 Description: The paint removal process is not subject to regulation in some circumstances. Waste determination under Section 262.11 is made once the combination of paint and surface preparation product is removed from the surface of the structure. Each product user is responsible for waste determination. Nonhazardous waste which subsequently becomes hazardous is subject to regulation. Generators are potentially liable under CERCLA for damage caused by a release. A lead-based paint abatement contractor and building owner are both generators (cogenerators).
 
03/10/1997APPLICABILITY OF THE DOMESTIC SEWAGE EXCLUSIONMemo
 Description: The domestic sewage exclusion extends to both listed and characteristic wastes which pass through sewer system to a publicly owned treatment works (POTW). Sewage is subject to CWA, and exempt from RCRA. Waste removed or leaked from a sewer line does not meet the conditions of the exemption. Releases from a sewage lines could be solid waste management units (SWMUs) or areas of contamination (AOCs). The definition of facility for corrective action is dependent on site-specific factors. Releases from SWMUs at permitted facilities are addressed under Sections 3004(u) or 3004(v) authority. Non-SWMU related releases, both within and beyond the facility boundary, are addressed under Section 3005(c)(3) omnibus permitting authority; releases at interim status facilities addressed under Section 3008(h) interim status corrective action orders. Domestic sewage is defined as untreated sanitary wastes that passes through a sewer system.
 
10/30/1996INCLUSION OF ADDITIONAL CHEMICAL REAGENT INTO EXISTING K062 EXEMPTIONMemo
 Description: The Section 261.3(c)(2)(ii)(A) exclusion applies only to spent pickle liquor sludge (K062) stabilized with lime. The exclusion does not apply if other treatment agents (e.g., magnesium hydroxide) are used. Expansion of the exclusion is not a priority for OSW.
 
09/17/1996MAINTAINING CONSISTENCY REGARDING THE REGULATORY STATUS OF DISPOSABLE AND REUSABLE RAGS AND WIPERSMemo
 Description: EPA recognizes the issues involved with maintaining consistency among the Regions on the regulatory status of disposable and reusable wipers (rags) contaminated with de minimis amounts of solvent. EPA is developing a data collection strategy to draw conclusions on the potential environmental concerns posed by these wipers.
 
07/12/1996MANAGEMENT AND DISPOSAL OF WASTE VINYL MINI BLINDSMemo
 Description: Toxicity characteristic (D008) lead-containing mini blinds are not solid waste if they are returned to the manufacturer for resale in a reverse distribution system. Blinds from homes, apartments, and hotels are exempt household hazardous waste (HHW). Waste from hospitals, offices, day care centers, and non-residential buildings at military bases are not HHW. HHW and non-HHW must be segregated. A generator can test waste or apply knowledge. The most conservative approach assumes that the blinds are hazardous waste (HW). The generator is vulnerable for enforcement for an incorrect determination if subsequent EPA testing reveals that the waste is HW.
 
06/19/1996CLARIFICATION OF TWO SECTIONS OF THE HAZARDOUS WASTE REGULATIONS: WASTE CHARACTERIZATION IN 40 CFR 262.11 AND LDR NOTIFICATIONMemo
 Description: EPA does not require waste codes on the manifest, but states may require one or more waste codes to be identified. RCRA waste codes may be part of the proper DOT shipping description. When a waste meets a specific listing and exhibits a characteristic for one of the constituents that make up the listed waste code, the generator may decide which waste code to include on the manifest based on which waste code most accurately identifies the waste for emergency response purposes.
 
03/21/1996SLUDGE FROM TREATMENT OF U154 CONTAMINATED GROUNDWATERMemo
 Description: Sludge generated from treatment of groundwater contaminated with U154 (methyl alcohol) is prohibited from land disposal only if the sludge is a hazardous waste at its point of generation. Sludge generated from wastewater treatment is considered a newly-generated waste because it is a different treatability group than the wastewater being treated (SEE ALSO: 55 FR 22661; 6/1/90). Discusses change in treatability group. U154 is listed solely for ignitability and is no longer hazardous when it becomes part of a noncharacteristic mixture (Section 261.3(a)(2)(iii))(SEE ALSO: 66 FR 27266; 5/16/01). Contaminated groundwater may become part of a non-ignitable mixture when introduced to wastewater treatment system. Sludge generated from treating non-ignitable wastewaters is not derived from hazardous waste.
 
03/01/1996Environmental Fact Sheet: Hazardous Waste Identification Rule for Contaminated Media (HWIR-Media) -- Proposed RulePublication
 Description: EPA is releasing for comment a proposed rule which would reexamine many of the RCRA Subtitle C treatment and management standards for contaminated media and other wastes managed in cleanups overseen by EPA or authorized states. HWIR-Media will address the major RCRA Subtitle C management requirements that are considered the biggest causes of problems and delays for cleanups. These requirements include the Land Disposal Restrictions (LDR), Minimum Requirements (MTRs), and RCRA permitting procedures.
 
01/31/1996APPROPRIATE SELECTION AND PERFORMANCE OF ANALYTICAL METHODS FOR WASTE MATRICES CONSIDERED TO BE "DIFFICULT-TO-ANALYZE"Memo
 Description: This memo presents OSW’s position on waste matrices that industry considers to be “difficult to analyze”. Chemicals or materials that have been intentionally added under the claim of treatment (e.g., iron filings added to foundry sands) can cause interference with analysis. Proper selection of appropriate analytical method and analytical conditions are demonstrated by adequate recovery of spiked analytes and reproducible results. Analytical performance problems with difficult-to-analyze matrices can be corrected by using an alternative method or by modifying the analytical conditions.
 
01/30/1996BARIUM IN HAZARDOUS WASTEMemo
 Description: Reexamination of the regulatory levels for barium in hazardous waste and other media is not currently an Agency priority. EPA also has regulatory levels for barium in drinking water and would have to coordinate any scientific review of established levels with the EPA office responsible for these standards.
 
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.
 
06/22/1995DETERMINATION ON WHETHER A GENERATOR'S FLUORESCENT TUBES ARE NONHAZARDOUSMemo
 Description: A generator is responsible for determining if a waste exhibits a characteristic. Testing one spent fluorescent mercury lamp tube to determine if all waste lamps exhibit the characteristic is not representative sampling. Selection of randomly chosen bulbs is more appropriate (see Chapter 9, SW-846). States authorized for the universal waste (UW) rule may add lamps to the state UW list and set management standards (SEE ALSO: 64 FR 36466; 7/6/99). The UW rule streamlines regulations for hazardous waste batteries (battery), pesticides, and mercury thermostats (SEE ALSO: 70 FR 45508; 8/5/05).
 
09/29/1994APPLICABILITY OF CERCLA TO MERCURY-CONTAINING LAMPS AND PCB-CONTAINING BALLASTSMemo
 Description: Disposal of fluorescent lamps in a hazardous waste landfill is exempt from CERCLA reporting, but not from CERCLA liability or response provisions. The disposal of fluorescent lamps or ballasts in a Subtitle D landfill or a TSCA landfill is not exempt from CERCLA release reporting requirements.
 
08/22/1994REGULATORY STATUS OF FOAM MATERIALS FROM THE USE OF CFCS, HCFCS, AND HFCS AS BLOWING AGENTSMemo
 Description: The attachment is an information sheet on CFC, HCFC, HFC blowing agents, solvents, and refrigerants. Foam products containing CFCs used as physical blowing agents are not listed hazardous wastes (SEE ALSO: RPC# 2/26/90-01). Spent trichlorofluoromethane and 1,1,2-trichloro-1,2,2-trifluoroethane used as solvents or reaction media are listed hazardous wastes. CFCs and HCFCs used in degreasing are F001. F001 listing description does not include HFCs. Used chlorofluorocarbon refrigerants from totally enclosed heat transfer equipment are excluded under 261.4(b)(12), provided the refrigerant is reclaimed for further use. This guidance provides the definition of treatment.
 
08/15/1994Environmental Fact Sheet: EPA Simplifies Land Disposal Restrictions by Establishing a Set of Universal Treatment Standards, and Finalizes Treatment Standards for 42 Newly Listed and Identified WastesPublication
 Description: This fact sheet discusses the promulgation of a set of universal treatment standards for more than 200 constituents in an effort to simplify the land disposal restrictions (LDR) program. The rule also finalizes LDR treatment standards for 42 newly listed or identified wastes, including coke by-product wastes, chlorotoluene wastes, and organic toxicity characteristic (TC) wastes, and promulgates regulations requiring TC pesticide and highly concentrated ignitable wastes be treated and not merely diluted prior to injection in Class I nonhazardous deep injection wells. The fact sheet includes a table of regulated hazardous organic constituents, wastewater concentration total composition (mg/L), and nonwastewater concentration total composition (mg/L).
 
08/05/1994SALE AND SCRAPPING OF DOT'S MARITIME OBSOLETE VESSELS FROM THE NATIONAL DEFENSE RESERVE FLEETMemo
 Description: Purchasers of ships to be scrapped and sold abroad must determine when export rules apply. Vessels destined for scrap as well as any materials necessary for operating the ship are not discarded while the vessel remains intact because those materials continue to serve a useful purpose. Removal of a material from a ship's structure that is intended for discard is the point of generation. Section 106(a) of the Federal Facilities Compliance Act (FFCA) prohibits the storage of hazardous waste on a public vessel for longer than 90 days after the vessel is placed in reserve or is no longer in service without a RCRA storage permit. Materials from a dismantled ship that are to be recycled may be scrap metal.
 
05/16/1994ACCEPTABILITY OF IMPORTING NICKEL-CONTAINING CATALYSTS FOR NICKEL RECOVERY AND STAINLESS STEEL SCRAPMemo
 Description: Nickel-containing catalysts and stainless steel scrap that do not exhibit a characteristic may be imported for recovery because they are not hazardous wastes. The applicability of the Basel Convention and bilateral agreements are discussed.
 
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.
 
04/18/1994RESPONSE TO REQUEST FOR COMMENT TO IMPORT METAL-BEARING SLUDGEMemo
 Description: A generator retains the burden of proof when claiming an imported material is not a solid waste or is conditionally exempt from regulation. An importer must make a hazardous waste determination on a shipment by shipment basis.
 
04/12/1994TESTING OF USED FILTERSMemo
 Description: A generator may apply knowledge for a hazardous waste determination on a nationwide basis only if all processes and materials are identical at each location. Once a waste has been tested and shown to be nonhazardous, further testing is unnecessary as long as the process and materials do not change.
 
01/04/1994REGULATORY STATUS OF WASTE AEROSOL CANSMemo
 Description: No categorical determination is possible as to the reactivity of various types of aerosol cans. A hazardous waste determination is the responsibility of generator. Steel aerosol cans that do not contain a significant amount of liquid (e.g., cans that have been punctured and drained) meet the definition of scrap metal. Aerosol cans that are recycled as scrap metal are exempt, and the generator need not make a hazardous waste determination (SEE ALSO: 261.4(a)(13) exclusion for processed scrap metal).
 
01/01/1994USE OF TOTAL WASTE ANALYSIS IN TOXICITY CHARACTERISTIC DETERMINATIONSQuestion & Answer
 Description: The maximum theoretical leachate concentration limits for the TCLP can be calculated from the results of a total waste analysis using a specific formula. Discusses the use of a total waste analysis for liquid wastes, solid wastes, and dual-phase wastes. Discusses maximum theoretical extract concentration (MTEC).
 
05/01/1993WASTE CLASSIFIED AS BOTH F005 AND K086Question & Answer
 Description: Washes and sludges generated from cleaning an ink pigment mixing tub using an 80 percent toluene solvent is classified as F005 and K086. For purposes of land disposal restrictions (LDR), the generator must also determine applicable characteristics.
 
03/05/1993U.S. WASTE MANAGEMENT PRACTICES FOR AUTOMOBILES AND AUTO SHREDDER RESIDUEMemo
 Description: Automobile shredder residue (ASR or fluff) and shredded appliances have the potential to exhibit characteristics, and may also contain PCBs above levels of regulatory concern. It is the generator's responsibility to determine whether ASR is hazardous waste before disposal. Provides the estimated ASR yearly generation. Most shredder residue is managed in solid waste (SW) landfills. Some states ban disposal of white goods (appliances) and autos from landfills or impose a consumer surcharge.
 
12/24/1992CLARIFICATION ON WHAT CONSTITUTES DIOXIN RELATED MATERIALSMemo
 Description: Contains a list of waste codes that contain dioxin (F020, F022, F023, F026, F027, F028, F032, D017, D041, D042). The F-listed dioxin waste codes do not apply if waste contains dioxin but does not meet the listing description. Waste exhibits the toxicity characteristic only if the level of constituent exceeds the regulatory level. F039, K043, and K099 have land disposal restrictions (LDR) for certain dioxins and furans. If waste meets the listing description, the waste code applies even if no Appendix VIII constituents are present. For purposes of F021, a pentachlorophenol derivative includes any substance which is related structurally and can be made from pentachlorophenol (PCP), including sodium pentachlorophenate, octachlorodibenzodioxin, octachlorodiphenyl ether, and potassium pentachlorophenate. Derivatives from tri- and tetrachlorophenol include tri- and tetra-chlorophenoxy derivatives of carboxylic acids. F020 -F023, F026-F028 hazardous waste must be incinerated in an unit meeting 99.9999 DRE or burned in thermal treatment unit meeting same DRE. Waste that contains Appendix VII constituents but cannot be traced to the original process that would generate the waste meeting listing description is exempt from regulation unless characteristic.
 
11/10/1992REGULATORY STATUS OF SPENT PHOTOCONDUCTOR DRUMS FROM PHOTOCOPYING MACHINESMemo
 Description: The generator is responsible for determining the regulatory status of spent photoconductor drums removed from photocopying machines. Spent photoconductor drums taken from photocopying machines meet the definitions of spent material and scrap metal. Spent drums that are recycled qualify for the scrap metal recycling exclusion. Only wastes that qualify as hazardous are subject to the Part 262 export regulations.
 
10/28/1992REGULATORY REQUIREMENTS PERTAINING TO THE MANAGEMENT OF WASTE SOLVENTS AND USED OILMemo
 Description: A generators may make a hazardous waste determination either by testing or by applying knowledge of the characteristics of the waste, in light of materials or process used in its generation; testing is not required. A generator must determine each waste code applicable to waste. A generator can rely on the analysis of unused mineral spirits plus knowledge of the operation to determine whether or not the resulting waste solvent exhibits any hazardous characteristic, provided he has sufficient information to make an accurate determination.
 
09/14/1992EXPORTATION OF HAZARDOUS WASTEMemo
 Description: A generator must perform a hazardous waste determination for waste that will be exported. All TSDFs handling hazardous waste that will be exported must have the proper permits under RCRA Subtitle C.
 
06/03/1992MIXED WASTE MANAGEMENT: NORTHWEST INTERSTATE COMPACTMemo
 Description: The chemical component of biomedical radioactive mixed wastes consists of acids and bases as well as solvents. The sample and treatability study exclusions may be used to develop the mixed waste treatment capability. There is no standard procedure for sampling non-homogeneous mixed waste (or other non-homogeneous (waste) in drums. There is currently no disposal options for scintillation cocktails contaminated with radionuclides other than tritium or carbon-14.
 
12/30/1991PETITION TO DELIST XENIUM FIBERGLASS CORPORATION WASTEMemo
 Description: The delisting process generally takes two years. Addresses minimum delisting petition requirements. A delisting petition is not necessary for waste which is no longer hazardous via the 261.3(a)(2)(iii) exemption for mixtures of solid waste and hazardous waste listed solely for a characteristic that are no longer characteristic (SEE ALSO: 268.3; 66 FR 27266; 5/16/01). The generator is responsible for demonstrating that an exempt mixture remains nonhazardous and for classification as legitimately used, reused, recycled, or reclaimed.
 
12/19/1991USED AUTOMOBILE ANTIFREEZE DISPOSALMemo
 Description: Used antifreeze from households is exempt from regulation. Used antifreeze from business is hazardous waste only if characteristic. Small business may be able to enjoy the reduced CESQG regulation. Industry data indicates used antifreeze may fail TCLP.
 
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.
 
10/29/1991TCLP EXTRACTIONS APPLIED TO LIQUID WASTES, OILS AND SOLVENT-BASED PRODUCTSMemo
 Description: Provides suggested analytical steps when inconclusive results are obtained from application of the TCLP to solvent and oily wastes. Generators may always apply their knowledge in lieu of testing. TCLP analysis is unnecessary for used oil destined for recycling.
 
10/09/1991EXEMPTION FROM PARTICLE SIZE REDUCTION STEP IN TCLPMemo
 Description: Generator knowledge may include previous testing data on similar waste. The generator must test or apply knowledge to make a determination of hazardous waste characteristics. The TCLP particle size reduction method is up to the lab’s best professional judgment.
 
09/06/1991DETERMINATION OF THE IGNITABILITY CHARACTERISTICMemo
 Description: There is no test method for ignitable solids (D001), the generator should apply knowledge (SEE ALSO: SW-846 Method 1030 (62 FR 32451; June 13, 1997). The analyses of solids may help determine if any detectable compounds are known to be ignitable. Meeting any, not all, of the ignitability properties renders a waste hazardous. There is no specific definition of “liquid” for purposes of the Pensky-Martens closed tester (SEE ALSO: RPC# 10/20/93-01) (SEE ALSO: 60 FR 3092; June 13, 1997).
 
08/30/1991LEAD PAINT REMOVAL DEBRIS AND THE TCLP PROCEDUREMemo
 Description: Adding iron or other material to lead-based paint (LBP) removal waste (or to removal abrasive) to mask the lead (D008) characteristic is not legitimate and may subject the generator to additional liability. Whether the masking agent is added to the paint removal abrasive prior to the abatement process or added to the waste following generation is immaterial (SEE ALSO: RPC# 7/3/91-02).
 
07/31/1991TC RULE HAZARDOUS WASTE DETERMINATIONMemo
 Description: Pulp and paper mill wastes should be sampled at an outlet from the bleach plant (point of generation), prior to commingling (mixing) with other wastestreams, to determine whether they exhibit the toxicity characteristic for chloroform (D022). The dilution of characteristic hazardous waste at a pulp and paper mill is acceptable for CWA compliance provided there is no specified method of treatment (58 FR 29860; 5/24/93). The definition of aggressive biological treatment (ABT) units for the purposes of the F037 and F038 listings does not apply to the exemption for biological treatment units from the surface impoundment minimum technical requirements.
 
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.
 
06/21/1991SPENT ANTIFREEZE AND THE TOXICITY CHARACTERISTICMemo
 Description: Discusses the use of TCLP to determine if spent antifreeze exhibits the characteristic for lead. The extraction procedure (EP) and TCLP are functionally equivalent for liquid wastes, since both lead to a direct analysis of the liquid. Extraction procedure toxic wastes are a subset of all hazardous waste. Generators may apply their knowledge instead of testing.
 
06/13/1991TCLP EXTRACTIONS AS THEY APPLY TO OILY WASTEMemo
 Description: The Agency does not recommend applying the TCLP test to oily waste. If oily waste is used oil, characterization is unnecessary if going for recycling (SEE ALSO: Part 279). If the TCLP is inconclusive on oily wastes, the generators may use knowledge.
 
06/07/1991SCOPE OF THE F006 LISTINGMemo
 Description: F006 wastewater treatment sludges include sludges from any type of treatment (e.g., chemical, biological, or simple settling). The domestic sewage exclusion does not extend to private or other non-municipal treatment works (SEE ALSO: FFCA added federally owned treatment works (FOTW) to the exclusion). A mixture of sewage and other wastes en route to a non-municipal treatment works does not cease to be a solid waste. The waste’s identity relevant to hazardous waste listings (i.e., F006) continues throughout the treatment works. The mixture rule exemption for laboratory wastes in 261.3(a)(2)(iv)(E) applies to laboratories discharging diverse, diluted amounts of listed toxic wastes. An electroplating shop located within a larger research and development (R&D) facility is not a laboratory, nor does it generate dilute wastewaters characteristic of an R&D laboratory.
 
05/21/1991APPLICABILITY OF THE TCLP TO WASTE MUNITIONSMemo
 Description: The mandatory hazardous waste determination should be based on knowledge when the application of TCLP to discarded munitions would result in an inherently unsafe situation due to the particle reduction step. The exemption from TCLP is unwarranted because generators can apply their knowledge.
 
05/01/1991APPLICABILITY OF THE TOXICITY CHARACTERISTIC AND THE TCLPMemo
 Description: Generators may test or apply knowledge to make a hazardous waste determination. Generators may limit testing to those constituents that are likely to be present in the waste.
 
05/01/1991TCLP PARTICLE SIZE REDUCTION EXEMPTION FOR MUNITIONSMemo
 Description: Particle reduction in TCLP is unsafe for military munitions. Facilities may apply knowledge to determine characteristic.
 
04/16/1991TC RULE RELATIONSHIP TO USED OIL FILTER DISPOSALMemo
 Description: In spite of the toxicity characteristic rule, generators may still apply their knowledge to make a hazardous waste determination. They must, however, be correct in their determination. Used oil filters are subject to hazardous waste determination (SEE ALSO: 261.4(b)(13)).
 
03/25/1991DILUTION OF TEST SAMPLINGMemo
 Description: TCLP is difficult to use on wastes such as oils and neat solvents because dilution step shifts detection limits are above the toxicity characteristic levels. A generator should apply knowledge in such cases. If no information is available, it would be prudent to handle it as hazardous waste (SEE ALSO: RPC# 8/14/90-01). There is no need to run TCLP on used oil that will be recycled.
 
03/08/1991SLUDGES WITHIN SURFACE IMPOUNDMENTS, NEWLY REGULATED DUE TO TC RULEMemo
 Description: Toxicity characteristic sludges that are generated in surface impoundments are solid waste (discarded by being abandoned). The sludges are solid waste subject to regulation not only when the surface impoundment is cleaned or closed but when sludge is generated (sludges are generated at the moment of deposition at the bottom of a unit).
 
03/01/1991AMENDMENTS TO PART 262 HAZARDOUS WASTE DETERMINATION AND RECORDKEEPING REQUIREMENTS OF PART 262 AND 268Question & Answer
 Description: The Section 262.11(c) requirement for generators to evaluate listed waste for characteristics applies to land disposal restrictions (LDR) paperwork only, and does not affect generator paperwork such as the manifest or the biennial report. If waste is both listed and characteristic, then the LDR standards for the listing operate in lieu of the characteristic standards, unless the listing does not address the characteristic or is not in effect (i.e., under a variance).
 
02/05/1991GENERATOR HAZARDOUS WASTE DETERMINATION AND THE TCLPMemo
 Description: Clarifies a letter (RPC# 11/8/90-04). A generator may always apply knowledge in determining if a waste is hazardous waste. If no information is available except for inconclusive TCLP data, it is prudent for the generator to assume that the waste is hazardous. There is no need to perform TCLP on used oil that is destined for recycling.
 
11/08/1990APPLICABILITY OF THE TCLPMemo
 Description: TCLP is inappropriate for certain matrices, like oils and neat solvents. Dilution step shifts detection limits are above regulatory levels. If that is the case, the generator must assume that the waste is hazardous (SEE ALSO: RPC# 3/25/91-01). TCLP must be used to obtain the extract.
 
09/20/1990SQG COMPLIANCE WITH TC RULEMemo
 Description: A fuel oil leak from a household tank is exempt household hazardous waste (HHW). EPA does not determine if a particular waste is characteristic. The hazardous waste determination is the generator’s responsibility. SQGs that are newly subject due to the toxicity characteristic (TC) rule had until 11/2/90 to notify the region. SQGs were granted an additional three months to comply with the TC Rule. Spilled petroleum products that are reclaimed from contaminated soil and used to produce fuels are not solid wastes.
 
09/07/1990APPLICABILITY OF EXCLUSION FOR REGULATED MEDICAL WASTE THAT HAS BEEN TREATED AND DESTROYEDMemo
 Description: A medical and disinfectant waste mixture should first be evaluated against the hazardous waste criteria. Used and unused sharps are regulated medical waste. Provides definitions of treated and destroyed. Crushing is not destruction (SUPERSEDED: see 60 FR 33912; 6/29/95).
 
08/24/1990SPENT ANTI-FREEZE COOLANT REGULATORY STATUSMemo
 Description: Waste antifreeze coolant (ethylene glycol) is not a listed hazardous waste (HW) but is a solid waste if intended for discard. The generator must determine if it is characteristic, by testing the waste or applying knowledge. Anecdotal evidence indicates that used antifreeze may exhibit the toxicity characteristic for lead, as determined using the EP (extraction procedure).
 
08/14/1990TCLP APPLICABILITYMemo
 Description: The use of TCLP to evaluate solid waste prior to the effective date of TCLP is valid. Addresses the use of matrix spike recovery. TCLP is difficult to apply to oily or solvent matrices. In the absence of usable data, it is safest to assume the material is a hazardous waste (SEE ALSO: RPC# 3/25/91-01).
 
07/31/1990MULTI-SOURCE LEACHATE AND TREATMENT STANDARDS OF LAND DISPOSAL RESTRICTIONSMemo
 Description: Waste codes not required on the manifest. A TSDF may rely on waste analysis data from the generator, but the TSDF must periodically test representative samples. A lab may certify for land disposal restrictions (LDR) as representative of the waste handler. Waste analysis parameters. Stabilization of cyanide to reduce leachability is an inappropriate treatment and generally impermissible dilution. No dilution of toxicity characteristic wastes if land disposed. Generators must determine characteristics. If a listed treatment standard addresses the characteristic, it operates in lieu of characteristic (even if less stringent). Prohibited waste only placed in a minimum technological requirement (MTR) surface impoundment if meets treatment standards, variance or extension, or 268.4. Notice and certification for de-characterized waste is sent to the implementing agency. F039 HSWA. Permitted TSDFs with F039 submit Class 1 modification by 8/8/90. Lab packs must be burned in Subpart O incinerator, not cement kilns.
 
07/19/1990ELECTRIC UTILITY POLESMemo
 Description: Utility poles may exhibit the toxicity characteristic (TC) for organic constituents and trigger hazardous waste regulation. A generator of used utility poles removed from ground must determine if poles exhibit a characteristic of hazardous waste.
 
05/23/1990NICKLE/CADMIUM BATTERIES, REGULATORY STATUSMemo
 Description: There is an exemption for a battery (batteries) returned for regeneration, not spent nickel-cadmium battery export for reclamation (SUPERSEDED: see 60 FR 25535; 5/11/95). Draining is not regeneration. A battery does not have to be contaminated to be a spent material. If it is unknown if a battery reusable, generator may consider spent. Generator determines if spent. Must document claims per 261.2(f) (SEE ALSO: Part 273).
 
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)
 
03/22/1990MICRO-CLEAR REGULATORY STATUSMemo
 Description: A product being used for its intended purpose is not a solid waste until it no longer can be used for its intended purpose (e.g., spent, off-specification, beyond expiration date). Although data may indicate a waste is not hazardous, each individual generator is responsible for evaluating the waste and making a hazardous waste determination.
 
08/17/1989SCRAP DENTAL AMALGAMMemo
 Description: Dental silver amalgam is not specifically listed as a hazardous waste. The American Dental Association (ADA) research suggests amalgam does not exhibit extraction procedure (EP) toxicity (SUPERSEDED: See 261.24), but the burden of determination is ultimately the generator's. ADA data could be the basis of a determination by knowledge. CERCLA 107 liability is independent of the material’s regulatory status under RCRA.
 
08/04/1989DEPLETED MIXTURES OF ETHYLENE GLYCOL AND WATER FROM HEAT EXCHANGERSMemo
 Description: A depleted mixture of ethylene glycol and water used as a coolant is a solid waste when disposed, but would only be hazardous waste if it exhibits a characteristic since no listings apply. Generators must test their wastes or apply knowledge. There is no federal regulation for nonhazardous waste generators.
 
07/06/1989HEALTH BASED VALUES FOR PAH'S IN COKE BY-PRODUCT WASTESMemo
 Description: List of polyaromatic hydrocarbons (PAH) commonly detected in coke by-product waste, and their risk specific doses (RSD) and reference doses (RfD).
 
06/26/1989LEACH TESTING PROCEDURE TO REMOVE LEAD-CONTAMINATED SOILS FROM RESIDENTIAL AREASMemo
 Description: If contaminated soil is removed from a site, the generator must determine if the soil contains hazardous waste by testing and/or applying knowledge. In the absence of a specific cleanup order, soil left in place is not subject to RCRA Subtitle C requirements, including testing (SEE ALSO: 61 FR 18779; 4/29/96).
 
06/12/1989HEALTH STATUS OF PAH'S IN COKE BY-PRODUCT WASTESMemo
 Description: Provides a list of polyaromatic hydrocarbons found in coke by-product wastes and their reference doses (RfD) or cancer assessment group (CAG) classifications.
 
06/05/1989TEST SAMPLES, EXCLUSION FROM HAZARDOUS WASTEMemo
 Description: Samples collected for testing are exempt from RCRA under certain conditions. Samples need not be managed as hazardous waste when being tested. Once samples are no longer exempt, a hazardous waste determination must be made, and waste becomes subject to regulation if it is hazardous. Conditionally exempt small quantity generators (CESQGs) are subject to hazardous waste determination and must send waste to a facility that is authorized to accept such waste. CESQGs that accumulate greater than 1000 kg of hazardous waste are subject to 262.34.
 
06/01/1989APPENDIX VIII AND APPENDIX IXQuestion & Answer
 Description: Explains the differences between Part 261 Appendix VIII and Part 264 Appendix IX. EPA uses 261 Appendix VIII in listing hazardous wastes, but it should not be used by generators in waste identification. 264 Appendix IX is used only for groundwater monitoring at permitted facilities.
 
04/21/1989GENERATOR ACCUMULATION TIME REQUIREMENTSMemo
 Description: Hazardous waste is considered generated when it is first produced or first becomes subject to regulation, not when generator first analyzes waste. Failure to properly analyze, label, and accumulate waste does not exempt the waste from regulation. The generator accumulation time period and regulations apply as soon as waste is produced or when waste is removed from the satellite accumulation area.
 
04/18/1989REQUEST FOR REGULATORY INTERPRETATION BY REACTION THERMAL SYSTEMS, INC. OF NAPA, CAMemo
 Description: If a waste does not match the listing descriptions, the generator is responsible for determining whether the waste exhibits any characteristic.
 
10/27/1988TREATMENT RESIDUALS OF CHARACTERISTIC HAZARDOUS WASTE AS A LISTED HAZARDOUS WASTEMemo
 Description: A sludge is F006 once it precipitates from an electroplating wastewater, whether at generator site or at off-site TSDF. Discussion of the derived-from rule for characteristic waste and waste listed solely for characteristic (SUPERSEDED: See RPC# 7/5/89-01; SEE ALSO: 66 FR 27266; 5/16/01). A generator is not required to identify the source of nonhazardous wastewater, but the TSDF responsible for assigning F006 to sludges. For improper waste characterization, correct the error on the manifest or reject the shipment. The generator and TSDF are potentially liable.
 
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).
 
06/06/1988SECONDARY MATERIALS REGULATION - USED SULFURIC ACIDMemo
 Description: The 261.4(a)(7) exemption only applies to sulfuric acid used in production of virgin sulfuric acid. Generators of sulfuric acid must have adequate documentation to support any exemption claims. The regulatory status of spent sulfuric acid depends on how it is recycled. Used sulfuric acid produced by sulfonation, alkylation, and dehydration reactions may be regulated as a by-product or co-product. Materials used as ingredients for product fuels or fertilizers are still solid wastes.
 
06/02/1988DISCARDED CLASS C EXPLOSIVESMemo
 Description: Only class C explosives designated as off-specification small arms ball ammunition (=.50 caliber) are not reactive (D003). Any other class C explosives, including small arms non-ball ammunition, may be hazardous waste. The generator is responsible for characterization.
 
05/19/1988DISCARDED COMMERCIAL CHEMICAL PRODUCTSMemo
 Description: The P- and U-lists apply to commercial and technical grades of a product, and to formulations in which chemical is sole active ingredient. Sole active ingredient means the only chemically active component for the function of the product. If a waste is not listed, the generator must test or apply knowledge to determine if waste exhibits a characteristic.
 
04/01/1988HAZARDOUS WASTE I.D.Question & Answer
 Description: Groundwater contaminated with F001-F005 solvents is subject to Subtitle C because it contains a listed waste per the contained-in policy. If the groundwater is treated such that it no longer contains a hazardous waste, or the solvents in the groundwater are delisted, it is no longer subject to Subtitle C (SEE ALSO: 61 FR 18779; 4/29/96; 66 FR 27266; 5/16/01).
 
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.
 
10/28/1987NOTIFICATION REQUIREMENT WHEN SHIPPING RESTRICTED WASTES TO A STORAGE FACILITYMemo
 Description: Generators must determine if their waste is subject to the land disposal restrictions (LDR) at the point of generation through analysis or knowledge of the waste. Facilities are required to send LDR notification with each waste sent to an off-site storage facility (SUPERSEDED: 62 FR 25997; 5/12/97).
 
08/19/1987SCINTILLATION COCKTAIL, REGULATION OF LIQUIDMemo
 Description: The liquid scintillation cocktail, Scintiverse BD, is not a listed hazardous waste, but might exhibit a characteristic (SEE ALSO: RPC# 3/1/89-04). Each generator is responsible for making a hazardous waste determination per 262.11.
 
08/19/1987SCINTILLATION COCKTAIL, REGULATION OF LIQUIDMemo
 Description: The liquid scintillation solution, Ready Safe, is not a listed hazardous waste (SEE ALSO: RPC# 3/1/89-04). It may exhibit a characteristic. Each generator is responsible for making a hazardous waste determination.
 
08/10/1987LAND DISPOSAL PROHIBITION RULE FOR SOLVENTSMemo
 Description: Only the initial generator can determine that a waste with less than 1% F001-F005 solvents is subject to a national capacity variance. Treatment facilities must treat residues to meet the applicable treatment standard and must complete land disposal restrictions (LDR) notification. The generator, not the treater, must determine if the waste is prohibited. The treater can apply for a case-by-case extension.
 
06/26/1987SLUDGE CONTAINING 1,1,1-TRICHLOROETHANE (TCE)Memo
 Description: Solvent wastes placed in storage or land disposed prior to the effective date of the land disposal restrictions (LDR) become subject to LDR when they are removed from storage or taken out of the land, unless they are subject to a variance or meet the applicable treatment standard.
 
03/18/1987REACTIVE CHARACTERISTICS OF DISCHARGED LI/SO2 BATTERIESMemo
 Description: Based on the supplied data, EPA agrees that Li/SO2 (lithium-sulfur dioxide) batteries are unlikely to exhibit the reactivity characteristic when they are fully discharged to zero volts. Fully-charged and duty-cycle Li/SO2 batteries are reactive. The generator is responsible for the hazardous waste determination. The placement of ignitable (D001) or reactive (D003) waste into a landfill is prohibited unless it is treated, rendered, mixed before, or immediately after, placement in the landfill so that it is no longer characteristic (SEE ALSO: Part 268).
 
03/11/1987SCINTILLATION COUNTING COCKTAILMemo
 Description: The liquid scintillation cocktail, Bio-Safe II, does not appear to be a hazardous waste, provided that it is not reactive (D003) or corrosive (D002), since it is not ignitable (D001) and does not exhibit the toxicity characteristic (D018-D043). Neither scintillation cocktails, nor lab wastes in general, are listed (SEE ALSO: RPC# 3/1/89-04). Hazardous waste identification is the generator's responsibility.
 
03/03/1987REGULATORY STATUS OF PRODUCTS ECOLISTE AND ECOLUMEMemo
 Description: While scintillation cocktail products EcoLite and EcoLume are not listed hazardous waste and do not appear to be characteristic, the generator is responsible for the determination (SEE ALSO: RPC# 3/1/89-04). Radioactive materials are not specifically listed or characteristic.
 
01/20/1987LAND DISPOSAL RESTRICTIONS CLARIFICATIONSMemo
 Description: Discusses a national capacity variance for solvents, dioxins, soils, and media from RCRA and CERCLA cleanups, an exemption for solvents from SQGs, and the land disposal restrictions (LDR) storage prohibition. Ash derived from the incineration of F003 remains listed (SEE ALSO: 66 FR 27266; 5/16/01). F003 mixed with solid waste is no longer hazardous if it is not characteristic via the mixture rule (SUPERSEDED: See 268.3). If the origin is not known, wastes with F001-F005 constituents are considered listed (SUPERSEDED: See 55 FR 8758; 3/8/90).
 
01/14/1987LITHIUM BATTERIESMemo
 Description: Generators must determine if a lithium battery (lithium thionyl chloride (SOCL2)) exhibits a characteristic.
 
01/06/1987SILVER RECOVERY IN THE PHOTOGRAPHIC INDUSTRY, CHEMICAL RECOVERY CARTRIDGES FORMemo
 Description: Properly washed photographic silver recovery units (e.g., steel wool cartridges, electrolytic recovery cells, ion exchange resins) are not hazardous waste if they are not characteristic. Residues from recovery units that treat wastewater are sludges and are not solid wastes when reclaimed (SEE ALSO: Part 266, Subpart F).
 
01/01/1987SPENT LEAD-ACID BATTERIESQuestion & Answer
 Description: A person who drains spent acid from battery shells is subject to the generator provisions if the acid exhibits a characteristic. Because the act of draining batteries is not part of the reclamation process, a person who drains but does not crack batteries is not subject to 266.80(b) (SEE ALSO: Part 273).
 
12/01/1986WASTES GENERATED IN PROCESS UNITSQuestion & Answer
 Description: Safety-Kleen parts washers are not exempt manufacturing process units under section 261.4(c). A solvent is considered spent when it can no longer be used, and spent materials are solid wastes when they are reclaimed. An operator becomes a generator when the cleaning apparatus is removed from drum.
 
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.
 
05/20/1986USED X-RAY FILM AS A SPENT MATERIAL - SILVER RECLAMATIONMemo
 Description: Used x-ray film is a spent material, but it is not specifically listed hazardous waste (HW). Although trade association data suggest it is not characteristic, each generator is responsible for the HW determination. If HW x-ray film is sent to a silver reclaimer, the generator must get an ID number and manifest the waste.
 
04/28/1986GENERATOR USE OF TOTAL CONSTITUENT ANALYSIS IN LIEU OF THE EP OR TCLP TESTSMemo
 Description: A generator may use knowledge to make a characteristic determination, including the total waste concentration. When using total waste analysis in lieu of the extraction procedure (EP) or TCLP tests, the generator must assume all the contaminant present in the waste will migrate or leach into a liquid extract. A discussion of the maximum theoretical extract concentration (MTEC) (SEE ALSO: RPC# 1/1/94-01).
 
04/21/1986REGULATORY STATUS OF SOLVENT TF-1Memo
 Description: Part 261, Appendix VIII, hazardous constituents are not the only listing determination factor for solvent TF-1, there are other factors. Solvent and PCB wastes with Appendix VIII constituents are not hazardous waste unless they are listed or characteristic. TSCA has the authority to regulate PCB handling and disposal (SEE ALSO: 261.8).
 
03/15/1986Guidance Manual on the RCRA Regulation of Recycled Hazardous WastesPublication
 Description: This document provides guidance to state and EPA regional personnel who must determine which materials, when recycled, are solid and hazardous wastes. In addition, persons who recycle materials or generate materials that are recycled may use this manual to determine which regulations apply to them. Guidance is primarily provided in the form of examples illustrating application of the regulations to actual recycling practices.
 
02/04/1986REGULATORY STATUS OF PHOTOGRAPHIC FILMS AND PAPERS UNDER RCRA SUBTITLE CMemo
 Description: Photo film and paper are not listed hazardous waste (HW). They are HW if characteristic. Data suggest they are usually not toxic by the extraction procedure (EP) (SUPERSEDED: See 261.24). The generator must make the determination. Even if not contaminated, used photo film and paper removed from service to recycle are spent materials. Unless characteristic, spent material status irrelevant.
 
01/30/1986ANTI-NEOPLASTIC AGENTS IN HOSPITAL WASTES, DISPOSAL OFMemo
 Description: Seven antineoplastics are U-listed hazardous waste. Antineoplastics are not regulated as class. Hospitals generating less than 100 kg/mo exempt as CESQG. There is no EPA guidance for a proper incineration destruction temperature.
 
01/16/1986IDENTIFICATION NUMBERS FOR RESIDUES GENERATED FROM THE TREATMENT OF HAZARDOUS WASTEMemo
 Description: The residue from the treatment of a listed waste retains listing via the derived-from rule (SEE ALSO: 66 FR 27266; 5/16/01). The residue from the treatment of a characteristic waste is regulated only if the residue exhibits a characteristic. The TSDF is the generator of the treatment residue (SEE ALSO: RPC# 11/17/89-02).
 
01/16/1986RESIDUES GENERATED FROM THE TREATMENT OF HAZARDOUS WASTE, I.D. NUMBERS FORMemo
 Description: The residue from treatment of a listed waste retains the listing via the derived-from rule (SEE ALSO: 66 FR 27266; 5/16/01). Residue from the treatment of characteristic waste is regulated only if the residue exhibits a characteristic. The TSDF is the generator of treatment residue (SEE ALSO: RPC# 11/17/89-02).
 
10/03/1985APPROPRIATENESS OF THE EP/TCLP SIMULATION OF CO-DISPOSAL SITUATION FOR MINING WASTES; CHARACTERISTIC TESTS FOR DETERMINING THE HAZARDOUS CHARACTERISTICS OF MINING WASTESMemo
 Description: There is no determination on the appropriate tests used to identify mining or Bevill exempt mining and mineral processing wastes to be regulated as hazardous waste. TCLP is designed to simulate the leachability of industrial waste that is co-disposed with sanitary waste. Although the disposal scenario may be incompatible with mining waste disposal, similar generation of acids warrants TCLP or stronger. Mining wastes generate acidic leachate upon exposure to air.
 
05/14/1985DISCARDED COMMERCIAL CHEMICAL PRODUCTSMemo
 Description: Section 262.11 outlines the generator’s responsibility for identifying hazardous wastes. The P- and U-listings apply only to unused CCPs, not to process wastes containing chemicals listed in 261.33. The U122 formaldehyde listing does not apply to waste containing used formaldehyde or fish contaminated with formaldehyde. Discarded fish and formaldehyde must be evaluated for characteristics. EPA regulates certain chemicals in their unused form but not all wastes containing the same chemicals.
 
04/10/1985CLARIFICATION OF “N.O.S.” AS USED IN PART 261, APPENDIX VIIIMemo
 Description: The designation "N.O.S." (not otherwise specified or NOS) in Part 261, Appendix VIII, indicates the inclusion of all compounds of that particular class.
 
02/21/1985EXCAVATED CONSTRUCTION SOIL CONTAINING QUANTITIES OF VOLATILE ORGANIC COMPOUNDSMemo
 Description: Soil contaminated with VOCs would be regulated as a hazardous waste if it exhibited a characteristic or contained a listed hazardous waste.
 
12/26/1984CONTAMINATED GROUNDWATER, RCRA REGULATORY STATUSMemo
 Description: Generators do not use Appendix VIII in hazardous waste (HW) determination. Wastes containing Appendix VIII constituents are not HW unless they are listed or characteristic. Collected groundwater contaminated with listed or characteristic waste is regulated as HW. Discussion of the contained-in policy.
 
09/20/1984DIBUTYLTIN DIFLUORIDE NOT A LISTED RCRA WASTEMemo
 Description: Dibutyltin difluoride is not a listed waste. Dibutyltin difluoride contaminated protective clothing would be hazardous only if it exhibits a characteristic. It is a generator’s responsibility to determine whether a waste is listed or exhibits a characteristic.
 
09/04/1984RESPONSIBILITY OF GENERATOR IN HAZARDOUS WASTE DETERMINATIONSMemo
 Description: The applicability of hazardous waste regulations to SULFA-CHECK spent slurry is discussed. The suggested cyanide and sulfide concentrations for reactivity are less than 10 ppm (SUPERSEDED: see RPC# 4/21/98-01). A generator does not perform determinations in 261.11(a)(2) to classify a waste as hazardous, but rather uses the process established in 262.11 to make a hazardous waste determination.
 
01/06/1984SOILS FROM MISSOURI DIOXIN SITES, WHETHER HAZARDOUSMemo
 Description: The presence of toxic compounds in soil does not automatically make the soil a hazardous waste. The origin of toxicants must be known to apply a listing. If the exact origin is unknown, soils cannot be listed. If characteristic, soils are hazardous (SEE ALSO: 55 FR 8758; 3/8/90, 61 FR 18779; 4/29/96).
 
08/01/1983SOLID WASTE MUST BE EVALUATED FOR ALL CHARACTERISTICSQuestion & Answer
 Description: Even if a generator determines that their waste exhibits one characteristic, they must still evaluate the waste for other characteristics. Generators must have in-depth knowledge of the waste. Provides a summary of EPA’s reasoning (SEE ALSO: current 262.11(c)).
 
06/18/1981GRAY IRON FOUNDRY WASTE DISPOSALMemo
 Description: Two waste streams that are mixed together must be evaluated separately for hazardous waste identification. Mixed characteristic wastes that lose their characteristic are not hazardous. Listed waste must be delisted by petition. Existing characteristic waste treatment permit is valid when the waste becomes listed.
 
11/17/1980WASTES FROM STORAGE OF PETROLEUM PRODUCTSMemo
 Description: Bottom sediments, water wastes, and spilled material and mixtures from the storage of petroleum products are hazardous waste (HW) if they are listed, mixed with listed HW, or characteristic. Appendix VIII is used only for determining if a waste should be listed by the Agency, not for generator determination.
 
09/04/1980DRILLING OPERATIONS, EXEMPTION OF CERTAIN WASTE FROMMemo
 Description: The exclusion in 261.4(b)(5) applies to only oil, natural gas, or geothermal exploration. Similar wastes from other operations may be regulated if they are characteristic. Generators may apply knowledge in lieu of testing.
 
Show details for ImportsImports
Show details for IncinerationIncineration
Show details for IncineratorsIncinerators
Show details for Industrial FurnacesIndustrial Furnaces
Show details for Industrial WastesIndustrial Wastes
Show details for Jobs Through Recycling ProgramJobs Through Recycling Program
Show details for K-wastesK-wastes
Show details for Land Disposal RestrictionsLand Disposal Restrictions
Show details for Land Disposal UnitsLand Disposal Units
Show details for Land Treatment UnitsLand Treatment Units
Show details for LandfillsLandfills
Show details for Large Quantity Generators (LQG)Large Quantity Generators (LQG)
Show details for Legislation (hazardous waste)Legislation (hazardous waste)
Show details for Liability (Hazardous Waste)Liability (Hazardous Waste)
Show details for Listing Hazardous WasteListing Hazardous Waste
Show details for ManifestManifest
Show details for Medical WasteMedical Waste
Show details for Mercury WastesMercury Wastes
Show details for Military MunitionsMilitary Munitions
Show details for Mining WasteMining Waste
Show details for Miscellaneous UnitsMiscellaneous Units
Show details for Mixed Waste (radioactive waste)Mixed Waste (radioactive waste)
Show details for Municipal Solid WasteMunicipal Solid Waste
Show details for Native American - TribesNative American - Tribes
Show details for Native Americans - TribesNative Americans - Tribes
Show details for Natural GasNatural Gas
Show details for Nonhazardous WasteNonhazardous Waste
Show details for OilOil
Show details for Oil FiltersOil Filters
Show details for P-wastesP-wastes
Show details for PCBsPCBs
Show details for Permits and PermittingPermits and Permitting
Show details for PetitionsPetitions
Show details for Petroleum Refining WastesPetroleum Refining Wastes
Show details for Polychorinated Biphenyls (PCBs)Polychorinated Biphenyls (PCBs)
Show details for Post-closure (hazardous waste)Post-closure (hazardous waste)
Show details for ProcurementProcurement
Show details for Public ParticipationPublic Participation
Show details for Radioactive Mixed WasteRadioactive Mixed Waste
Show details for Reactive WastesReactive Wastes
Show details for RecyclingRecycling
Show details for Reducing WasteReducing Waste
Show details for Siting (waste facilities)Siting (waste facilities)
Show details for Small Quantity Generators (SQG)Small Quantity Generators (SQG)
Show details for Solid WasteSolid Waste
Show details for SolventsSolvents
Show details for Source ReductionSource Reduction
Show details for Special WastesSpecial Wastes
Show details for State Programs (RCRA)State Programs (RCRA)
Show details for StorageStorage
Show details for Surface ImpoundmentsSurface Impoundments
Show details for TanksTanks
Show details for Test MethodsTest Methods
Show details for Toxicity CharacteristicToxicity Characteristic
Show details for TransportersTransporters
Show details for TreatmentTreatment
Show details for TSDFsTSDFs
Show details for U-wastesU-wastes
Show details for Underground Storage Tanks (UST)Underground Storage Tanks (UST)
Show details for Universal WasteUniversal Waste
Show details for Used OilUsed Oil
Show details for VariancesVariances
Show details for Waste Determinations for Combusted Non-Hazardous Secondary MaterialsWaste Determinations for Combusted Non-Hazardous Secondary Materials
Show details for Waste MinimizationWaste Minimization
Show details for Waste PilesWaste Piles
Show details for Waste ReductionWaste Reduction
Show details for Wood Preserving WastesWood Preserving Wastes
Show details for (Not Categorized)(Not Categorized)
For more information on commonly used environmental terms please visit the Terms of the Environment EPA Home Page

 

 
Begin Site Footer

EPA Home | Privacy and Security Notice | Contact Us