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Air Emissions (RCRA)
Batteries
Best Demonstrated Available Technology (BDAT)
Bevill Amendment
Boilers
Burning
Buy Recycled
Characteristic Wastes
Chemicals (RCRA)
Cleanup
Cleanup (RCRA)
Closure (Hazardous Waste)
Combustion
Combustion of Hazardous Waste
Compliance
Composting
Conditionally Exempt Small Quantity Generators (CESQG)
Construction and Demolition Waste
Construction and Demolition Wastes
Containers
Containment Buildings
Corrective Action (RCRA)
Corrosive Wastes
Crude Oil
Definition of Solid Waste
Delisting Petitions
Disposal
Drip Pads
Educational Materials
Enforcement (RCRA)
EPA Forms
Exclusions (RCRA)
Exports
F-wastes
Financial Assurance (hazardous waste)
Financial Assurance (nonhazardous waste)
Gas
Generators
Grants (hazardous Waste)
Grants (municipal solid waste)
Groundwater Monitoring
Hazardous Waste
Hazardous waste data
Hazardous Waste Identification
Hazardous Waste Recycling
Household Hazardous Waste
Identification of Hazardous Waste
Imports
Incineration
Incinerators
Industrial Furnaces
Industrial Wastes
	04/01/2010	Green Renovation Brings a Community Back to Life: The Lazarus Building	Publication
	Description: This fact sheet discusses renovation of the Lazarus Building in Columbus, Ohio. The Lazarus Team incorporated a variety of sustainable enhancements into the building renovation, including energy and water efficiency, improvements in indoor environmental quality, and the use of sustainable, recycled, and reused materials. The Lazarus Team’s vision resulted in the following key project attributes: reducing, reusing, and recycling materials during renovation and construction; using recycled-content products and materials in construction; cost savings and environmental benefits; environmental awards and recognition; and local community revitalization.
	08/01/2009	Brightwater Wastewater Treatment System: Built with the Environment in Mind	Publication
	Description: This fact sheet discusses the building of one of the most sustainable wastewater treatment systems in the United States, the Brightwater Treatment System in King County, Washington. From the beginning, the Brightwater Team made a commitment to sustainability. The architects, engineers, and contractors working on the project have been dedicated to protecting natural resources, limiting the impacts of construction, and leading the way in the development of sustainable practices. Brightwater used four key sustainable practices, including using coal fly ash in concrete as a cement substitute; retaining excavated soils on site to visually screen wastewater processing areas; reusing materials to create salmon habitat and a reforestation area; and building a green on-site environmental education and community center.
	07/01/2009	Using Recycled Industrial Materials in Roadways	Publication
	Description: This fact sheet discusses the use of industrial materials in roadways and other infrastructure projects as an alternative to virgin materials and construction products. Many industrial materials have chemical and physical properties that make them valuable resources when recycled or beneficially reused, but they are often disposed of as waste. Industrial materials recycling is helping to green the nation’s infrastructure by making roadways more durable, conserving natural resources, decreasing energy use, and reducing greenhouse gas emissions.
	10/01/2008	Using Recycled Industrial Materials in Buildings	Publication
	Description: This fact sheet discusses the use of recycled industrial materials, the byproducts of industrial processes, in buildings as an alternative to virgin materials and building products.
	06/03/2008	Study on Increasing the Usage of Recovered Mineral Components in Federally Funded Projects Involving Procurement of Cement or Concrete to Address theSafe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users; Report to Congress	Publication
	Description: This report to Congress contains EPA’s analysis of the information addressed in the Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users (SAFETEA-LU). SAFETEA-LU directs EPA to conduct a study to determine the extent to which procurement requirements, when fully implemented, may realize energy savings and environmental benefits attainable with substitution of recovered mineral components in cement used in cement or concrete projects.
	06/01/2008	Construction Initiative	Publication
	Description: This document discusses EPA's Construction Initiative (CI), a collaborative, public-private sector effort to increase the recycling and reuse of industrial materials in building and transportation construction projects. The Initiative increases awareness of the potential value and unique abilities of these materials to replace virgin materials in numerous construction applications.
	09/01/2007	Building for the Future by Recycling Industrial Materials	Publication
	Description: This document describes how putting industrial materials, such as coal ash, foundry sand, construction and demolition materials, slag, and gypsum into productive use saves resources and contributes to a sustainable future. These materials are valuable products of industrial processes and have many of the same properties as the virgin materials they replace.
	05/01/2006	WasteWise: Preserving Resources, Preventing Waste	Publication
	Description: This fact sheet discusses WasteWise, a free, voluntary partnership program sponsored by EPA through which organizations reduce municipal solid waste and selection industrial wastes, benefitting their bottom line and the environment. The fact sheet provides information about how to become a WasteWise partner, technical assistance available through WasteWise, and the WasteWise endorser program.
	02/01/2003	Guide for Industrial Waste Management	Publication
	Description: The Guide provides valuable assistance to anyone interested and involved in industrial waste management, from states to industry to citizens. States currently have varying industrial waste programs and can use the Guide to address any gaps in their programs or review their existing rules and guidance and replace them with parts of this Guide as they see fit.
	02/01/2003	Industrial Waste Management: Guide To Best Practices	Publication
	Description: This brochure describes and contains an order form for the Guide for Industrial Waste Management (530-C-03-002) on CD-ROM. The Guide for Industrial Waste Management provides information and resources to develop state guidelines, hold workshops to educate businesses and people, and train facility managers.
	11/01/2002	Industrial Waste Air Model (IWAIR) User's Guide	Publication
	Description: This document describes how to use the Industrial Waste Air Model (IWAIR). It identifies the computer system requirements for running the IWAIR software and gives instructions for installing the software, and introduces the user to program screens and navigational tools; assists the user in selecting the appropriate calculation method (i.e., forward calculation to risk estimates or backward calculation to protective waste concentration), waste management unit type, and modeling pathway; provides detailed guidance to develop risk estimates for wastes of known chemical concentration(s) and to predict protective waste levels based on a user-specified risk level; and includes example calculations and references.
	11/01/2002	Industrial Waste Air Model (IWAIR): Technical Background Document	Publication
	Description: This document provides technical background information on the Industrial Waste Air (IWAIR) model, and accompanies the Guide for Industrial Waste Management for use in evaluating inhalation risks. It explains the model selection and gives an overview of CHEMDAT8, emission model input parameters, and mathematical development of emissions; describes the development of dispersion factors using ISCST3 and how these are used in the model; addresses the exposure factors used in the model; details the health benchmarks used in the model and how these were developed if health benchmarks were not available from standard sources; describes the calculation of risk; and includes references. The appendices contain chemical-specific data used in emission modeling, summary data for 29 meteorological stations, derivation of chronic inhalation non-cancer and cancer health benchmark values, and sensitivity analysis of ISC Air Model.
	08/01/2002	Industrial Waste Management Evaluation Model (IWEM) Technical Background Document	Publication
	Description: This document provides technical background on the assumptions, methodologies and data used by EPA to develop Tier 1 and Tier 2 ground-water impact evaluation tools as part of the Agency’s Guide for Industrial Waste Management. The evaluation tools are combined in the Industrial Waste Management Evaluation Model (IWEM).
	08/01/2002	Industrial Waste Management Evaluation Model (IWEM) User's Guide	Publication
	Description: This document describes how to use the Industrial Waste Management Evaluation Model (IWEM). IWEM is the ground-water modeling component of the Guide for Industrial Waste Management, which has been developed by EPA’ s Office of Solid Waste for the management of non-hazardous industrial wastes.
	11/13/2000	IMPLEMENTATION OF VACATURE OF TCLP USE FOR EVALUATING MANUFACTURED GAS PLANT (MGP) WASTES IN THE BATTERY RECYCLERS CASE	Memo
	Description: D.C. Court of Appeals vacated use of TCLP for evaluating manufactured gas plant (MGP) waste (Association of Battery Recyclers, Inc., et al. v. US EPA). MGP waste cannot be classified as toxicity characteristic (TC) hazardous, since TCLP test is part of TC regulatory definition. MGP wastes unlikely to exhibit other characteristics. MGP wastes may be regulated under broader in scope state programs, state cleanup programs, or state industrial waste programs (SEE ALSO: 65 FR 51087; 8/22/00; RPC# 10/19/00-01).
	10/19/2000	MANUFACTURED GAS PLANT (MGP) REMEDIATION WASTE	Memo
	Description: TCLP cannot be used to determine whether manufactured gas plant (MGP) waste is hazardous due to court ruling (Association of Battery Recyclers, Inc., et al. v. US EPA). MGP remediation waste is not listed but may be hazardous if exhibit ignitable, corrosive, or reactive characteristic, though unlikely. MGP remediation waste determined to be nonhazardous would be governed by state industrial or nonhazardous waste regulations (SEE ALSO: 65 FR 51087; 8/22/00; RPC# 11/13/00-01).
	08/07/2000	FEDERAL CONTROLS OF DRY CLEANING FLUID PERCHLOROETHYLENE	Memo
	Description: RCRA mandates EPA establish requirements for management of hazardous waste such as perc (perchloroethylene, tetrachloroethylene). EPA has developed numerous compliance assistance documents for dry cleaning industry. EPA’s Design for the Environment Program (DfE) forms voluntary partnerships to evaluate environmental considerations of products and processes.
	05/12/1999	ELECTROPLATING WASTEWATER TREATMENT SLUDGES FROM GRAY CAST IRON MANUFACTURING OPERATIONS	Memo
	Description: Exclusion from F006 for zinc plating on carbon steel does not apply to plating on gray cast iron, a different base metal. Wastes from gray cast iron plating operations are eligible for delisting petition.
	05/01/1999	User's Guide for the Industrial Waste Management Evaluation Model (IWEM): Tier 1 Look-Up Tables and Tier 2 Neural Networks for Groundwater Model, Draft	Publication
	Description: The User's Guide describes the software, Industrial Waste Management Evaluation Model (IWEM). The software is still in draft form, and when finalized, will be used to assist facilities in determining the most appropriate waste management unit design. Also available on CD-Rom (see EPA530-C-99-001).
	01/01/1999	PICKLING BATH CARRYOVER AND K062	Question & 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).
	06/01/1997	AIR EMISSIONS FROM ELECTROPLATING OPERATIONS	Question & Answer
	Description: A filter used to concentrate air emissions from electroplating line would not carry the F006 listing. The filter meets the definition of sludge, but does not result from the treatment of an electroplating wastewater. Air emissions are not wastewater.
	06/01/1997	USE AS INGREDIENT NOT WITHIN SOLVENT LISTING	Question & Answer
	Description: The use of solvent as an ingredient is not covered by the spent solvent listings. Unused product being disposed would not carry an F listing if the unused solvent had been added as an ingredient. Unused product may be P or U listed when disposed if the solvent served as the sole active ingredient in the product.
	05/01/1997	APPLICABILITY OF K052 WASTE CODE TO PIPELINE TERMINALS	Question & Answer
	Description: The K052 listing is limited to leaded tank bottoms generated at petroleum refineries. Leaded tank bottoms generated at pipeline terminals that are not directly part of a refinery do not meet the K052 listing, and are only hazardous wastes if characteristic.
	03/25/1997	DEFINITION OF SOLID WASTE AMENDMENTS FOR PETROLEUM REFINERIES	Memo
	Description: The deadline for the petroleum refining listing determination and recycling amendments proposed on November 20, 1995 (60 FR 57747), has been extended. It is now scheduled for promulgation on April 30, 1998 (Rule finalized 8/6/98; 63 FR 42110). Additional time enables EPA to issue a Notice of Data Availability (NODA) and respond to comments. The American Petroleum Institute requested EPA separate the listing determination from the proposed Section 261.4(a)(12) recycling amendments, and expedite (fast track) the latter. The Agency believes it is more efficient to finalize both portions of the rule together.
	03/25/1997	STATUS OF THE RECYCLING AMENDMENTS PROPOSED IN THE LISTING DETERMINATION FOR PETROLEUM REFINING PROCESS WASTES	Memo
	Description: The petroleum refining listing determination and recycling amendments proposed on November 20, 1995 (60 FR 57747) are scheduled for promulgation on April 30, 1998 (Rule finalized 8/6/98; 63 FR 42110). Additional time enables EPA to issue a Notice of Data Availability (NODA) and respond to all comments. The American Petroleum Institute asked EPA to separate the listing determination from the proposed Section 261.4(a)(12) recycling amendments, and to expedite (fast track) the latter. The Agency believes it is more efficient to finalize both portions of the rule together.
	02/24/1997	SPENT ALUMINUM POTLINER (K088) RECYCLING	Memo
	Description: EPA expects to provide national guidance regarding legitimate recycling of spent aluminum potliners (K088) as soon as possible.
	01/21/1997	REGULATORY STATUS OF ION EXCHANGE RESIN WASTE	Memo
	Description: Ion exchange filter waste used in the treatment of electroplating rinsewaters is F006, even though purified water is recycled to process. An ion exchange filter is classified as a sludge. The definition of sludge is tied to type of unit in which the waste is generated.
	12/24/1996	CLASSIFICATION OF SOLVENTS ADDED	Memo
	Description: Solvent used as reactants or ingredients in a product are not F-listed spent solvents. The policy also applies to discarded unused product containing solvent. The policy applies to solvents which are added by the end user to adjust viscosity. Statements to the contrary in the Solvent Study (EPA530-R-96-017) (August 1996) and Listing Determination Background Document for the 8/14/96 solvent listing proposal (61 FR 42318) are incorrect.
	08/30/1996	CHEMICAL CONVERSION OF ALUMINUM AND WHETHER WASTEWATER TREATMENT SLUDGE GENERATED IS CONSIDERED AN F019 HAZARDOUS WASTE	Memo
	Description: Sludge from an aluminum powder preparation process involving phosphating (but not zirconium phosphating) meets the F019 listing. Phosphating includes producing a mildly protective layer of insoluble crystalline phosphate on the surface of a metal. All wastewater treatment sludges from the chemical conversion coating of aluminum, except zirconium phosphating, are covered by the F019 listing, regardless of their composition and constituent concentration. (SUPERCEDES Brandes to Wozniak; 2/27/95 (RO 11940))
	03/07/1996	INDUSTRIAL WIPERS AND THE HAZARDOUS WASTE IDENTIFICATION RULE	Memo
	Description: Discusses possible factors to consider in a future rulemaking on disposable and reusable rags and wipers contaminated with solvents (SEE ALSO: RPC# 10/27/94-01 and RPC# 2/14/94-01).
	11/27/1995	HAZARDOUS WASTE LISTING DETERMINATION (60 FR 7825, FEBRUARY 9, 1995) OF K156 WASTE FROM THE PRODUCTION OF METHYL CARBAMATE	Memo
	Description: Carbamates are a salt or ester of carbamic acid. Methyl carbamate is the simplest ester of a carbamic ester. Organic wastes from the production of methyl carbamate are K156 regardless of the concentration of toxic contaminants (SUPERSEDED: K156 listing vacated by Dithiocarbamate Task Force v. EPA).
	08/24/1995	CARBAMATE LISTING DETERMINATION (60 FR 7824, FEBRUARY 9, 1995) AS IT RELATES TO THE LATEX PROCESS WASTES GENERATED BY A COMPANY	Memo
	Description: K161 is limited to production wastes from dithiocarbamate acids and their salts. Latex process wastes containing dithiocarbamate (ethyl zimate) are not U407, as ethyl zimate is not the sole active ingredient (SUPERSEDED: U407 listing vacated by Dithiocarbamate Task Force v. EPA). Residue remaining in a container or inner liner removed from a container that held any listed CCP is a hazardous waste when discarded or intended for discard.
	08/03/1995	EPA'S INTERPRETATION OF THE EXEMPTION IN 40 CFR 261.3(A)(2)(IV)(F), A NEW SECTION OF EPA'S REGULATIONS ON CARBAMATE LISTING RULE	Memo
	Description: The mixture rule exemption for K157 carbamates (261.3(a)(2)(iv)(F)) must account for all constituents not reacted, destroyed, or recovered, including the amount volatilized. The compliance point (where volatilization is measured) is the point of generation prior to mixing with other wastes. Volatilization during production is not counted towards the threshold. The relationship between 261.3(a)(2)(iv)(F) and 261.3(a)(2)(iv)(B) (solvents from non-specific sources) is discussed.
	07/18/1995	DETERMINATION OF EQUIVALENT TREATMENT (DET) FOR F024 FOR WHICH INCINERATION IS BDAT	Memo
	Description: The proposed treatment of F024 using catalytic extraction processing would provide the treatment equivalent to the promulgated treatment standard, INCIN (incineration). This determination of equivalent treatment (DET) pursuant to 268.42(b) applies to specific facilities. Additional sites may be covered by a DET if the technology is expected to be commercially deployed at other sites and the company requests a DET.
	06/30/1995	DETERMINATION WHETHER SECONDARY MATERIAL TRANSPORTED TO A CANADIAN COPPER SMELTER IS A SOLID WASTE	Memo
	Description: Although dewatering is reclamation, dried metal hydroxide solids in pellet powder from dewatering electroplating wastewater are F006. The listing applies even if the sludge is reclaimed further. Pellets sent to a smelter to recover metals are reclaimed, not directly used or reused, because distinct components are recovered as separate end products. The sludge is F006 before reclamation unless a variance from the definition of solid waste for partially-reclaimed wastes needing further reclamation (260.30(c)) is obtained.
	05/25/1995	ARE TANK BOTTOMS REMOVED FROM TANKS CONTAINING ONLY NAPHTHA DEEMED TO BE K052 HAZARDOUS WASTE?	Memo
	Description: K052 is limited to tank bottoms generated at or as part of a petroleum refinery from tanks used to store leaded gasoline or leaded blending fractions. The listing applies regardless of whether the waste exhibits a characteristic. Because naptha is an unleaded petroleum fraction, tank bottoms from naptha storage at a refinery are not K052.
	04/20/1995	REGULATORY REQUIREMENTS FOR TANKS, VEHICLES, VESSELS, PROCESS OR MANUFACTURING UNITS, OR PIPELINES WHICH HAVE BEEN SHUT DOWN	Memo
	Description: Waste generated in a manufacturing process unit may remain in the unit for up to 90 days after the unit has been shut down, and may be stored for an additional 90 days in generator accumulation units. EPA headquarters policy does not address whether K050 waste is generated only through the actual cleaning of heat exchanger bundles, or if the regulated K050 waste is created when sludges remains in a shut-down exchanger for more than 90 days or when they are discarded along with an uncleaned bundle.
	02/27/1995	CLARIFICATION OF F006/F019 INTERPRETIVE LETTER REGARDING WASTES GENERATED FROM AN ALUMINUM COATING PROCESS	Memo
	Description: Wastewater treatment sludges from anodizing aluminum in sulfuric acid are excluded from the F006 listing. Sealing and coloring anodized aluminum are not processes covered by the F006 or F019 listing if no chromates or cyanides are used. Electrodeposition with a clear acrylic film does not generate a listed hazardous waste if no chromate or cyanides are used. (SUPERCEDED BY: Bussard to Environmental Science Services; 8/30/96 (RO 14103))
	02/16/1995	RESPONSE TO PETITION ON PROHIBITION OF USE OF SLAG FROM HIGH TEMPERATURE METALS RECOVERY AS ANTI-SKID/DEICING AGENT	Memo
	Description: The 266.20 use constituting disposal regulations effectively prohibit the use of slag derived from high temperature metals recovery (HTMR) of K061, K062, and F006 for anti-skid or deicing agents. HTMR residues may contain high concentrations of metals. EPA is not confident that K061, K062, and F006 used in this manner have been treated to minimize any threat.
	12/01/1994	ELEMENTARY NEUTRALIZATION UNITS GENERATING AND STORING NON-CORROSIVE HAZARDOUS WASTES	Question & Answer
	Description: A tank in which corrosive-only (D002) electroplating wastewaters are treated meets the definition of elementary neutralization unit (ENU), even if the treatment process produces an F006 sludge. F006 is subject to regulation once it is removed from the tank.
	10/27/1994	REGULATORY STATUS OF INDUSTRIAL WIPERS UNDER RCRA	Memo
	Description: The EPA Headquarters deferral on the determination of the regulatory status of rags and wipers to the appropriate Region or State implementing agency (SEE ALSO: RPC# 2/14/94-01) is discussed.
	09/30/1994	List of Industrial Waste Landfills and Construction and Demolition Waste Landfills	Publication
	Description: Provides an estimate of the number of industrial and construction and demolition (C&D) waste landfills in the United States. Presents state summaries, including number of facilities; date of data; list of additional data available from the state list; and the name, address, and telephone number of the contact who provided the information. Contains the state lists of active industrial and C&D waste landfills, sorted by county, city, and name.
	09/28/1994	CLARIFICATION ON: MANIFEST DOCUMENT NUMBER; F003, F005, D001; WASTE DESTINED FOR RECYCLING; AND TREATMENT STANDARDS FOR CFC	Memo
	Description: F003 and F005 waste exhibiting ignitability must carry a notification for and meet the D001 treatment standard (TS), since F003/F005 does not operate in lieu of D001 (SEE ALSO: 55 FR 22520, 22530; 6/1/90) (USE WITH CAUTION: see RPC# 3/1/94-02). The TS for chlorinated fluorocarbons (CFC) is discussed. A CFC waste may be subject to the California list prohibition for halogenated organic compounds (HOC) (SUPERSEDED: California list removed, see 62 FR 25997; 5/12/97) (SEE ALSO: RPC# 5/16/91-01). Materials that are not a solid waste (SW) when recycled are exempt even if shipped to a recycler via a TSDF. Scrap metal is both a SW and is hazardous, but is exempt if recycled. The legitimacy of recycling must be documented. Use of manifest continuation sheets is outlined.
	09/21/1994	APPLICABILITY OF F006 HAZARDOUS WASTE CODE TO NICKEL RECLAMATION PROCESS FOR ELECTROLESS NICKEL PLATING SPENT SOLUTIONS	Memo
	Description: Electroless plating is not covered by the F006 listing. Spent electroless nickel solutions may be hazardous waste if mixed with a listed hazardous waste, if derived from a listed hazardous waste, or if they exhibit a characteristic. Because the scrap metal definition is based on physical form, the determination of whether nickel-plated steel wool generated during nickel-recovery is scrap metal should be made by the State or Regional office.
	09/19/1994	CLARIFICATION ABOUT THE SCOPE OF EPA'S ADMINISTRATIVE STAY FOR A PORTION OF THE K069 HAZARDOUS WASTE LISTING	Memo
	Description: The K069 listing does not apply to secondary acid scrubber wastes, including calcium sulfate sludge from secondary lead smelting, during the administrative stay. The stay remains in effect until 30 days after the future rulemaking clarifying the scope of the K069 listing.
	08/22/1994	REGULATORY STATUS OF FOAM MATERIALS FROM THE USE OF CFCS, HCFCS, AND HFCS AS BLOWING AGENTS	Memo
	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.
	08/02/1994	CLASSIFICATION OF WASTEWATER TREATMENT SLUDGE FROM THE REVISED ""ZINC-COBALT ALLOY PLATING ON CARBON STEEL"" PROCESS	Memo
	Description: The exclusion from the F006 listing for zinc plating on carbon steel applies even if zinc-cobalt alloy is used instead of just zinc.
	08/01/1994	UNUSED FORMULATIONS CONTAINING SODIUM PENTACHLOROPHENATE ARE F027	Question & Answer
	Description: Sodium pentachlorophenate is a compound derived from pentachlorophenol (PCP) and therefore meets the F027 listing when discarded unused.
	07/21/1994	REGULATORY INTERPRETATION FOR ION EXCHANGE RESIN USED FOR WATER REUSE ON ELECTROPLATING WASTEWATERS	Memo
	Description: The sludge definition is tied to the type of unit in which a waste is generated, not the disposition of the treated effluent or the intent of processing. Ion exchange resin used to filter electroplating wastewater is F006 regardless of whether it exhibits a hazardous characteristic. The act of filtering contaminants from wastewater is pollution control and generates a sludge, even if the intent is to reclaim the wastewater for reuse in a production process.
	07/15/1994	APPLICABILITY OF HAZARDOUS WASTE CODES TO A CHEMICAL POLISHING SYSTEM	Memo
	Description: Discarded chemical polishing bath solution containing the oxidizer hydrogen peroxide may be ignitable (D001) because it is capable of severely exacerbating a fire by yielding oxygen to stimulate combustion. Acid baths may be corrosive (D002) due to sulfuric acid content. The chemical polishing process does not generate a listed waste if no electroplating or cyanides are used (SUPERSEDED: Memorandum, Dellinger to Waterman; May 18, 2007 (RO 14808)). Discarded baths from this process are hazardous wastes only if characteristic. Wastes that exhibit a characteristic at the point of generation may be subject to the Part 268 requirements even if they do not exhibit a characteristic at the point of disposal (261.3(d)(1)).
	07/12/1994	REGULATORY INTERPRETATION REGARDING PHOTORESIST SOLIDS (""SKINS"") GENERATED IN THE PRINTED CIRCUIT BOARD MANUFACTURING INDUSTRY	Memo
	Description: Cleaning and stripping is electroplating only if associated with (i.e., in line or contiguous with) other electroplating operations. Wastes from printed circuit board manufacturing can be F006 if electroplating operations are involved. Stripping solutions or baths can be electroplating wastewaters. Photoresist solids or "skins" filtered from stripping solutions in the printed circuit board industry can be F006 sludges.
	06/03/1994	DEFINITION OF RCRA WASTE K050	Memo
	Description: A sludge from a double-pipe heat exchange unit is not K050. Inside the tube of a double-pipe unit is not a bundle. A sludge may exhibit the toxicity characteristic for benzene and other heavy organics.
	06/01/1994	SCOPE OF SPENT SOLVENT LISTINGS	Memo
	Description: EPA has not established numerical levels for solvent contamination in nonhazardous manufacturing process wastes that trigger hazardous waste regulation. If listed solvent hazardous waste in any amount is mixed with other solid waste, the mixture is listed (SEE ALSO: 261.3(a)(2)(iv) exemption; RPC# 10/20/92-02).
	06/01/1994	TECHNICAL GRADE SOLVENT FORMULATIONS AND THE F003 LISTING	Question & Answer
	Description: The F003 listing covers pure solvent mixtures as well as technical grade solvent formulations used for their solvent properties. Discusses the definition of technical grade. A solvent can contain de minimis concentrations of contaminants or impurities and still meet the F003 listing.
	04/08/1994	REGULATORY STATUS OF WOOD STICKERS USED FOR WOOD PRESERVING OPERATIONS	Memo
	Description: Although the F032, F034, and F035 listings do not generally apply to treated wood products that are discarded, wood "stickers" (pieces of wood used during wood preserving to separate bundles of lumber) that come into contact with wood preservative are listed hazardous waste when discarded.
	02/01/1994	K052: BOTTOMS FROM TANKS STORING LEADED GASOLINE AT PETROLEUM REFINERIES	Question & Answer
	Description: The K052 listing applies only to bottoms from tanks storing leaded gasoline at petroleum refineries. The listing does not apply to bottoms from refinery tanks storing other petroleum fractions.
	09/01/1993	HAZARDOUS WASTE RECYCLING REGULATIONS TO A PROPOSED INK RECYCLING PROCESS	Memo
	Description: Waste ink is a spent material. Spent materials are solid wastes when they are reclaimed. Process recycling waste ink is not regulated under RCRA Subtitle C. The storage of waste ink prior to recycling is subject to permit standards. Whether a temporary holding area is subject to permitting is decided on a case-by-case basis. Lithographic printers may qualify as CESQGs (SEE ALSO: RPC# 9/20/93-03). Waste ink may be characteristic or listed, depending on the type of solvent used to clean the ink machine. Hazardous waste recyclers must notify EPA under RCRA 3010 and obtain EPA ID numbers. Residues from the recycling process may no longer be solid wastes if they are legitimate products. Discusses the regulatory status of reclaimed materials and legitimacy determinations.
	06/01/1993	UNUSED FORMULATIONS OF AGENT ORANGE	Question & Answer
	Description: Unused formulations of Agent Orange meet the F027 listing when discarded because Agent Orange contains 2,4,5-T, a compound derived from the synthesis of trichlorophenol.
	05/01/1993	WASTE CLASSIFIED AS BOTH F005 AND K086	Question & 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.
	04/20/1993	REGULATORY STATUS OF CENTRIFUGE UNDERFLOW WASTES	Memo
	Description: Centrifuge underflow waste is not coke byproduct waste K147 or K148, but it may exhibit a characteristic.
	04/19/1993	DISCUSSION PAPER ON POSSIBLE UNIVERSAL WASTE	Memo
	Description: EPA is evaluating the applicability of the household hazardous waste (HHW) exclusion to lead-based paint abatement wastes (SEE ALSO: 63 FR 70233, 70241; 12/18/98). Part 279 prohibits the storage of used oil in unlined surface impoundments and applying used oil to roads. Fluorescent bulbs may be conditionally exempt in the future. EPA does not believe that F001-F005 solvents should be included as universal wastes. EPA is currently studying other solvent wastes to determine if they merit a listing (SEE ALSO: 61 FR 42318; 8/14/96). Spent antifreeze may exhibit the toxicity characteristic for lead and/or benzene. EPA is evaluating toxicity characteristic levels for lead and pentachlorophenol (PCP). New MCLs could affect future toxicity characteristic levels. Sandblast grit from the removal of lead-based paint may be D008.
	03/05/1993	RECYCLING PETROLEUM REFINERY OILY WASTES; REGULATORY STATUS OF SEPARATION AND RECOVERY SYSTEMS SAREX PROCESS FOR RECYCLING PETROLEUM REFINERY OILY WASTES	Memo
	Description: Effluent from a petroleum recovery process that accepts hazardous waste K048-K051 returned to a wastewater treatment system is not derived from listed waste if it is chemically equivalent to non-listed influent (SEE ALSO: RPC# 8/23/85-01). The closed-loop exemption does not apply to oil being returned to a refinery where it will be used as a fuel. The closed-loop exemption does not apply to reclaimed material that will be used to produce a fuel or produce a product that will be applied to the land.
	03/04/1993	PETITION FOR EXCLUSION OF WESTERN WHEEL HOWELL F019 WASTE	Memo
	Description: Wastewater treatment sludges that are generated from the treatment of contaminated rinsewaters collected from the stages prior to chromate conversion coating are not F019, provided that these wastewaters are kept separate from the wastewaters from the chromate conversion step.
	12/24/1992	CLARIFICATION ON WHAT CONSTITUTES DIOXIN RELATED MATERIALS	Memo
	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.
	12/22/1992	IDENTIFICATION OF SPENT SOLVENT IN CERTAIN INDUSTRIAL PROCESSES	Memo
	Description: Toluene-containing polyurethane coating used in the manufacture of marine buoys and fenders is not F005 when used to mechanically clear a spray gun nozzle (i.e., not solubilizing) as long as the solvent is not used for its solvent properties.
	12/11/1992	CLARIFICATION OF HAZARDOUS WASTE LISTINGS PERTAINING TO WOOD PRESERVING OPERATIONS	Memo
	Description: Wood preserving is defined as any process intended to preserve wood from structural attack. The definition is based on intent of treatment, not on type of process. Dipping operations could be wood preserving. Sodium pentachlorophenate used as wood preservative is F032 when discarded.
	12/01/1992	HYDROCHLOROFLUOROCARBONS USED IN DEGREASING	Question & Answer
	Description: Hydrochlorofluorocarbons (HCFCs) used in degreasing are F001 if the concentration was 10% before use. Hydrogenated fluorocarbons (HFCs) are not F001.
	12/01/1992	STATUS OF ELECTRIC ARC FURNACE DUST INCORPORATED INTO GLASS FRIT	Memo
	Description: Electric arc furnace dust (K061) used as an ingredient in grit for abrasive blasting, roofing granules, or ceramics is not solid waste as long as the dust is not used in a manner constituting disposal. EPA does not generally consider an end use as roofing granules, glass ceramic, and ceramic glaze to be use in a manner constituting disposal.
	11/04/1992	CLASSIFICATION OF F003 WASTES	Memo
	Description: Xylene and acetone used to remove paint is F003, even if the waste is not ignitable. The 261.3(a)(2)(iii) mixture rule exemption does not apply to nonignitable F003 that has not yet been mixed with solid waste, and does not apply to a mixture of soil and F003 that does not exhibit a characteristic (SEE ALSO: 66 FR 27266; 5/16/01). Land disposal restrictions (LDR) treatment requirements still apply to F003 waste that has been rendered nonignitable and/or nonhazardous under 261.3(a)(2)(iii). If F003 is spilled into soil, the soil must be managed as listed waste until the state or Region determines that it no longer contains hazardous waste.
	10/20/1992	REGULATORY STATUS OF WASTE GENERATED BY MCLAUGHLIN GORMLEY KING (MGK) COMPANY IN MINNESOTA	Memo
	Description: F001-F005 solvents such as toluene that are used as carriers, extractants, reaction media, etc., are listed hazardous wastes when spent and separated from the process in which they were used, but other wastes that are separated from the final product containing trace amounts of solvents picked up during the production process are not F001-F005 or listed via the mixture rule.
	10/01/1992	PERCHLOROETHYLENE USED IN DRY CLEANING	Question & Answer
	Description: Spent tetrachloroethylene (perchloroethylene) used in dry cleaning is classified as F002. The F001 listing is limited to solvents used in degreasing.
	09/18/1992	REQUEST FOR CLARIFICATION ON F019 WASTE DETERMINATION	Memo
	Description: Wastewater treatment sludges from the conversion coating operation are F019 regardless of where in the wastewater treatment train they are generated. The listings apply regardless of whether there is prior treatment or commingling with other wastewaters, even if the sludges contain very low concentrations of hazardous constituents. The concentration-based standards under CWA are not a factor.
	08/17/1992	WASTE GENERATED DURING THE MANUFACTURE OF POLYURETHANE FOAM	Memo
	Description: Wastes from the normal use or discard of toluene and polyurethane coating formulation are not F001-F005 (the solvent is used as an ingredient). If an identical formulation is used to clean a spray gun or equipment, then the resulting wastes can be F001-F005. In all cases, the waste must be evaluated for characteristics.
	07/16/1992	REGULATORY DETERMINATION - SPENT SOLVENT LISTINGS AND THE MIXTURE RULE	Memo
	Description: The Shell Oil decision on the mixture rule does not affect the scope of the spent solvent listings (F001-F005). A spent solvent is not a “mixture” of solvent and its contaminants.
	01/15/1992	REQUEST FOR ASSISTANCE REGARDING F006 DETERMINATION AT THE EAGLE-PICHER COLORADO SPRINGS, COLORADO FACILITY	Memo
	Description: EPA defines electroplating as the reduction or plating of metal ions on a cathodic surface. Electrolysis is not electroplating. A facility does not need to be subject to CWA electroplating effluent standards in order to generate wastes within the scope of the F006-F009 and F019 listings.
	12/01/1991	RECLAIMED SPENT WOOD PRESERVATIVE EXCLUSION IN 40 CFR §261.4(A)(9)	Question & Answer
	Description: Spent wood preserving solutions that are reclaimed are no longer solid wastes and so are not derived from listed wastes F032, F034, or F035 (SEE ALSO: 63 FR 28556; May 26, 1998). Wood treated with the reclaimed preservative is not a hazardous waste when placed on land.
	11/26/1991	DISCARDED WASTEWATER AT A CORROSION CONTROL FACILITY	Memo
	Description: Discarded wastewater containing methylene chloride at a corrosion control facility is a solid waste. There is insufficient information to determine if the waste is hazardous. Methylene chloride is listed under both F001 and F002.
	11/01/1991	MULTISOURCE LEACHATE (F039) WASTE CODE AS IT APPLIES TO CONTAMINATION FROM SPILLS	Question & Answer
	Description: Water that has percolated through soils contaminated with more than one listed hazardous waste is normally F039, since spills and drips of hazardous waste which have collected in soil are normally land disposed wastes.
	09/04/1991	RCRA ARAR DETERMINATION AT MAXEY FLATS SUPERFUND SITE	Memo
	Description: Vials containing waste radioactive scintillation cocktails using xylene or toluene as a reaction medium are F003 and/or F005 if they meet the applicable solvent percentage thresholds (SEE ALSO: RPC# 3/1/89-04). If they are listed or characteristic, the cocktails must be managed as RCRA hazardous wastes.
	08/30/1991	RESIDUALS MATERIALS CONTAMINATED WITH TRACE SOLVENTS	Memo
	Description: Discusses solvent carryover. When a metal part is cleaned using an F-listed solvent, then air dried and blasted, the blasting grit containing trace levels of the solvent is not F001-F005 or listed via the mixture rule. If the solvent was used in excessive amounts during the initial cleaning, the solvent in the grit could be F-listed.
	08/05/1991	REGULATORY STATUS OF RESIDUES FROM SECONDARY LEAD SMELTERS THAT RECYCLE K069 WASTES; RESIDUES FROM SECONDARY LEAD SMELTERS THAT RECYCLE K069 WASTES	Memo
	Description: EPA did not intend for slags and drosses from secondary lead smelting where K069 is used as a feedstock to be listed K069 via the derived-from rule. Such smelting residues may be hazardous waste if they are characteristic. Discusses the indigenous principle for recycled furnace wastes.
	07/31/1991	TC RULE HAZARDOUS WASTE DETERMINATION	Memo
	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.
	07/05/1991	APPLICABILITY OF THE “MIXTURE” RULE TO PETROLEUM REFINERY WASTEWATER SYSTEMS	Memo
	Description: Addresses petroleum wastewater separation sludges. Liquid from which F037 and F038 listed sludge is generated is not itself a listed waste via the mixture rule unless the sludge is mixed with the liquid (e.g., sludge is scoured upon the introduction of the waste to the unit).
	07/03/1991	DRAFT REGION VIII POLICY ON “AGGRESSIVE BIOLOGICAL TREATMENT”	Memo
	Description: Sludges formed in aggressive biological treatment (ABT) units are not F037 or F038. Only secondary or tertiary treatment units qualify as ABT units. ABT units receiving or generating toxicity characteristic hazardous waste are subject to all applicable rules. F037/F038 sludges can be formed in ABT units that are not operating properly.
	06/01/1991	ADMINISTRATIVE STAY FOR WOOD PRESERVING WASTES	Question & Answer
	Description: Description of administrative stay of the effective date for wood preserving wastes F032, F034, and F035.
	05/31/1991	DRIPPAGE IN WOOD PRESERVING STORAGE YARDS	Memo
	Description: Incidental drippage after the removal of treated wood from drip pad is not illegal hazardous waste disposal, provided the owner and/or operator responds immediately. An immediate response determination is site-specific. A facility must have a contingency plan and must keep records of the response.
	05/29/1991	ELECTROPLATING WASTES	Memo
	Description: Anode bags are spent materials when removed from electroplating bath for reclamation. Spent anode bags are both reactive (D003) and F007. Bags can be washed in an accumulation tank/container without a permit under Section 262.34. Filter media, and residue from the apparatus used to filter cyanide plating bath are D003 (reactive) and F008, but not F007. A cleaning bath that does not contain cyanides is not F009.
	05/01/1991	COMPARATIVE DEFINITIONS OF F001 AND F002	Question & Answer
	Description: The type of degreasing determines whether tetrachloroethylene, trichloroethylene, methylene chloride, and 1,1,1-trichloroethylene receive the F001 or F002 listings. F001 applies to large-scale industrial degreasing, and F002 applies to equipment cleaning, and smaller scale degreasing operations.
	04/26/1991	SPENT PICKLE LIQUOR DELISTING PETITION	Memo
	Description: Discusses additional sampling and analysis requirements for a delisting petition of a liquid phase from lime neutralization of spent pickle liquor and associated rinsewaters (K062). A facility has 6 months to submit data before petition dismissal. A petition may be withdrawn and re-submitted.
	04/12/1991	NOTIFICATION OF ERRORS IN THE TECHNICAL AMENDMENT TO THE THIRD THIRD LAND DISPOSAL RESTRICTIONS (LDRS), PUBLISHED JANUARY 31, 1991	Memo
	Description: Addresses the corrections to the treatment standards for K048, P003, P073, U001, U003, U154 (errata sheet for 58 FR 3877; 1/31/91, Technical Amendment to the Third Third) (SEE ALSO: current 268.40).
	03/07/1991	DELISTING PETITION - FUJI PHOTO FILM WASTEWATER TREATMENT SLUDGE	Memo
	Description: The metal treatment process is not chemical conversion coating of aluminum (i.e., does not create F019) if it does not involve chromate compounds or oxide, phosphate, or chromate conversion.
	02/01/1991	PETROLEUM REFINERY WASTEWATER TREATMENT SLUDGE CLASSIFICATION	Question & Answer
	Description: Discusses the applicability of the F037 and F038 listings, primary/ secondary separation, and primary/ secondary treatment.
	01/23/1991	REGULATORY STATUS OF SOLVENT-CONTAMINATED RAGS AND WIPERS	Memo
	Description: Until EPA has the resources to respond to a petition to exempt solvent-contaminated rags, wipers, and shop towels from the mixture rule, EPA believes the waste determination should be made by the state or region on a case-by-case basis since they are in the best position to make an evaluation.
	01/01/1991	CLASSIFICATION OF LEACHATE CONTAMINATED GROUND WATER	Question & Answer
	Description: Groundwater contaminated with leachate resulting from the disposal of multiple listed wastes contains F039. F039 wastewaters destined for underground injection received a two-year national capacity variance.
	10/17/1990	PETROLEUM REFINERY SLUDGE REGULATIONS	Memo
	Description: Contains EPA’s response to issues raised during the Office of Management and Budget (OMB) review of petroleum refinery sludge final rule listing F037 and F038.
	08/15/1990	TANK TREATMENT PROCESSES	Memo
	Description: Circuit board manufacturing wastes can be F006 if electroplating is involved. Anodizing is electroplating. Chemical conversion coating is a non-electrical process and is not anodizing or electroplating for F006, F007, F008, F009. Wastewater is defined only for the land disposal restrictions (LDR). Containers and tanks storing hazardous waste (HW) before an off-site shipment are not wastewater treatment units (WWTUs). EPA did not intend to include containers in the definition of ancillary equipment. Generator accumulation starts when the waste first enters the container. HW sludge that is removed from a WWTU is subject to full regulation. A unit can be both a WWTU and an elementary neutralization unit (ENU). A wastewater treatment sludge is anything that precipitates or separates during treatment. F006 may be formed in an exempt unit.
	08/02/1990	APPLICABILITY OF F019 LISTING TO WASTEWATER TREATMENT SLUDGE FROM THE TIN COATING OF ALUMINUM	Memo
	Description: The non-electrolytic tin phosphate coating of aluminum is chemical conversion coating. Wastewater treatment sludge from the phosphate coating process is F019, even if no hazardous constituents or characteristics are present.
	07/25/1990	THIRD THIRD REVISIONS TO F024 TREATMENT STANDARDS	Memo
	Description: Pending the effective date of revised F024 treatment standards or a correction notice establishing an immediate effective date, treatment standards promulgated in the Second Third remain in effect (SEE ALSO: current 268.40).
	06/20/1990	CLARIFICATION OF SPENT SOLVENT LISTINGS	Memo
	Description: If the total of all F001, F002, F004, or F005 solvents before use is 10% or more by volume, the waste from using solvent is listed and carries all applicable codes. F001-F005 codes can apply even if each F001-F005 constituent is under 10%. Trichloromethane (chloroform) is U044 or D022, not F-listed.
	06/19/1990	STABILIZED WASTE PICKLE LIQUOR FROM STEEL/IRON INDUSTRY	Memo
	Description: Lime-stabilized K062 spent pickle liquor is not exempt from the derived-from rule if characteristic. For the exemption, the K062 must be stabilized at an iron and steel manufacturer. Lime stabilization at a commercial TSDF does not qualify.
	06/14/1990	RCRA WASTE CLASSIFICATION OF LABORATORY STANDARDS	Memo
	Description: F-listed solvent used to dissolve CCP to formulate lab standards use as an ingredient, not a solvent. Diluting or dissolving chemicals to make lab standard is not use. Discarded unused lab standards with P- or U-list chemicals are P-list or U-list hazardous waste if there is one active ingredient. The federal regulations do not require waste codes on the manifest, but the state may. If the waste is both listed and characteristic, it carries all applicable codes for land disposal restrictions (LDR) and incompatible waste.
	06/13/1990	USED OIL AND IDENTIFICATION OF LISTED HAZARDOUS WASTE	Memo
	Description: F001-F005 "before use" is before use at the facility, not when purchased. If pure solvent was purchased, diluted below 10% concentration, and used as solvent, the waste is not F001-F005. Solvent before use has any amount F003 and 10% total F001, F002, F004, or F005, waste F003 and other applicable F001-F005 listings. The K list applies only to wastes from industrial sources in the listing description. In general, the primary SIC code for a facility does not dictate if the facility is within the K-list category. A commercially pure /technical grade undefined for the P- and U-lists. It can include purity grades marketed or in general use by industry. Part 266, Subpart E (SUPERSEDED: see Part 279) applied to used oil (UO) not mixed with listed hazardous waste burned for energy recovery. Characteristic UO recycled in manner other than burning for energy recovery is not subject to RCRA (SUPERSEDED: see Part 279).
	06/12/1990	CHEMICAL ETCHING PROCESS-HAZARDOUS WASTE IDENTIFICATION	Memo
	Description: Bright dipping is chemical etching, a type of electroplating. Wastewater treatment sludge from the bright dipping process is F006.
	06/01/1990	DYES USED IN INK FORMULATION (K086)	Question & Answer
	Description: The term pigment as used in the K086 listing is synonymous with the term dye, and wastes from dye manufacturing meeting the listing description are K086. The listing background document describes the four types of raw materials that meet the listing description.
	05/03/1990	PAINT SPRAY BOOTH AIR FILTERS	Memo
	Description: The process wastes such as discarded paint and paint spray booth air filters containing toluene and xylene as ingredient in paint are not F001, F002, F003, F004, or F005.
	05/02/1990	ZIRCONIUM PHOSPHATING SLUDGES EXEMPTION	Memo
	Description: The exclusion from F019 listing apples to zirconium phosphating on aluminum cans when no cyanide, chromium, or other hazardous constituents are involved.
	04/17/1990	MARTIN MARIETTA - F019 WASTE LISTING DETERMINATION	Memo
	Description: Wastewater from chemical conversion coating of aluminum (electroplating waste) retains its identity while passing through the treatment train. Sludges generated in an initial treatment unit and subsequent units are all F019.
	04/12/1990	CADMIUM WASTES FROM MILITARY COATING MATERIALS	Memo
	Description: Cadmium wastes from coating materials and spent sacrificial anodes generated by military operations may be F-listed electroplating, heat treating, or aluminum conversion coating wastes (F006, F019, F007, F008, F009, F010, F011, F012) or may exhibit EP (extraction procedure) Toxicity for cadmium (SUPERSEDED: see Section 261.24).
	03/01/1990	TREATMENT STANDARDS FOR METHANOL WHICH DOES NOT MEET THE F003 LISTING	Question & Answer
	Description: A generator need not include the methanol treatment standard in the land disposal restrictions (LDR) notification for F003 waste xylene with traces of methanol used as a fuel. The use of a solvent as a reactant or ingredient is not solvent use meeting listing (SUPERSEDED: no treatment standard on notification, see new 268.7(a)(2)).
	02/26/1990	CHLOROFLUOROCARBONS (CFCS) FROM PRODUCTION OF FOAM PRODUCTS	Memo
	Description: CFCs used as blowing agents in production of foam insulation products (i.e., to physically open and expand the foam cells) are not considered used as solvents and are not F001-F005 when spent (SEE ALSO: RPC# 8/22/94-01).
	02/13/1990	RECYCLING OF K061 AS AN INGREDIENT IN CEMENT	Memo
	Description: Discussion of the legitimacy of K061 as an exempt ingredient claim. K061 in cement is not exempt for reuse because it is used in manner constituting disposal. Discussion of a sham determination. K061 cement must meet land disposal restrictions (LDR) for high zinc treatment standard metal recovery and cannot be land disposed (SUPERSEDED: see 268.40). The land application presumption is rebuttable.
	10/20/1989	DISPOSAL OR RECLAMATION OF RAGS	Memo
	Description: Rags contaminated with volatiles and F-listed solvents through wipe down and cleaning processes may be incinerated or laundered (SUPERSEDED: see RPC# 2/14/94-01).
	10/20/1989	RAGS AND SIMILAR MATERIALS ABSORBING VOLATILES AND F-WASTES, HANDLING	Memo
	Description: Rags contaminated with volatiles and F-listed solvents through wipe down and cleaning processes may be incinerated or laundered (SUPERSEDED: see RPC# 2/14/94-01).
	10/06/1989	WASTEWATER TREATMENT SLUDGES CONTAINING METHANOL	Memo
	Description: Wastewater treatment sludges containing small quantities of methanol are not necessarily listed or characteristic hazardous waste. Even if such waste is not hazardous under federal rules, more stringent or broader-in-scope state regulations can trigger regulation.
	10/03/1989	PETITION TO WITHDRAW K090 AND K091 LISTINGS	Memo
	Description: K090 and K091 cover waste generated by air pollution control devices from ferrochromium or ferrochromium silicon production furnaces. K090 and K091 are listed for total chromium (Cr). As of 1989, there is no plan to remove listings since new data show trivalent Cr may be a carcinogen. EPA is considering removing the 261.4(b)(6) exclusion for wastes containing trivalent chromium. EPA will not remove listed waste from regulation based solely on whether or not waste exhibits toxicity characteristic. In making delisting decisions, EPA considers whether waste meets any of the criteria for which it was originally listed, as well as additional constituents and factors.
	10/01/1989	CLARIFICATION OF F019 LISTING AND APPLICABILITY TO OTHER WASTEWATER TREATMENT SLUDGES	Question & Answer
	Description: Supernatant from the treatment of wastewaters from the chemical conversion coating of aluminum is not F019. Supernatant is hazardous if characteristic or if mixed with a listed sludge. Filtrate from a listed sludges is not hazardous via derived-from rule if similar to influent wastewater. Supernatant in which sludges are accidentally resuspended are listed.
	10/01/1989	CLARIFICATION OF SPENT SOLVENT LISTING	Question & Answer
	Description: CFC-11 (trichlorofluoromethane) used as blowing agent in the production of foam is not used for its solvent properties, and is not listed (SEE ALSO: RPC# 8/22/94-01).
	09/22/1989	TETRACHLOROETHYLENE CONTAMINATED WITH POLYCHLORINATED BIPHENYLS (PCBS)	Memo
	Description: Cleaning PCBs from a transformer with solvent containing 10% or more tetrachloroethylene (PCE) before use results in F002 listed waste. Applicable TSCA PCB regulations do not supersede the RCRA regulations. If TSCA and RCRA rules conflict, the more stringent regulations take precedence. Using solvent as dielectric is not "solvent use" triggering F001-F005 listings.
	08/25/1989	CLARIFICATION ON THE SCOPE OF K088	Memo
	Description: K088 only applies to the carbon portion of the aluminum potliner inside an electrolytic reduction cell. Other portions of the pot containing "significant levels of free cyanide" may be reactive (D003).
	08/21/1989	P AND U-LISTED WASTES	Memo
	Description: The P-and U-listings do not apply to chemicals listed in 261.33 that have been used for their intended purpose, but waste must still be evaluated for characteristics. If an unused chemical is no longer a technical or commercially pure grade due to contamination, it can still be an off-specification species of that chemical and so still meet the applicable P or U listing when discarded. Solvent CCPs that have been used for their solvent properties may meet one of F001-F005 listings.
	08/21/1989	WASTEWATER TREATMENT SLUDGES RESULTING FROM METAL CLEANING PROCESS	Memo
	Description: The use of an electrical current is not a prerequisite for a process to be considered an electroplating operation for purposes of F006 listing (e.g., chemical etching does not involve an electrical current, but sludges from treating wastewaters from chemical etching meet F006 listing). Cleaning must be associated with electroplating operations for sludges from treatment of cleaning bath to be F006.
	08/02/1989	CHLOROFLUOROCARBONS (CFCS) AS REFRIGERANTS, RECYCLING OF SPENT	Memo
	Description: Used CFC refrigerants are not hazardous waste F001 or F002 because they were not used as solvents, and are not U121 because they have been used. Such wastes are only hazardous if characteristic (SEE ALSO: 261.4(b)(12)).
	08/02/1989	SCOPE OF THE K051 AND K052 LISTINGS	Memo
	Description: Sludges generated at bulk terminals are not typically within the scope of K051 and K052 listings (SEE ALSO: F037, F038 in 261.31). If K049, K051, or K052 wastes are shipped to a bulk terminal, wastes derived from their management meet the listings. The discharge of residuals from K049 storage to an oil-water separator could make the resulting sludge listed via the derived-from and mixture rules.
	08/01/1989	CLARIFICATION OF ELECTROPLATING LISTINGS	Question & Answer
	Description: Definition of “electroplating operations” for F006 given in the December 2, 1986 Federal Register (54 FR 43351) and may be applied analogously to F007, F008, and F009. Electroless plating bath solutions will not meet F007, F008, and F009 listings even if they contain cyanide.
	07/28/1989	TEL GASOLINE SLUDGE DISPOSAL	Memo
	Description: Leaded tank bottoms from the petroleum refining industry are listed hazardous waste (K052) subject to land disposal restrictions (LDR). Solvent extraction and incineration is best demonstrated available technology (BDAT) for gasoline sludge waste. A temporary variance may be granted.
	07/21/1989	ACETONE AND METHANOL CONTAMINATED WASHWATERS	Memo
	Description: When toluene is used as solvent in a production process and then recovered, trace quantities of toluene found in facility's washwaters are not normally F-listed spent solvents and do not render all facility wastewaters and sludges hazardous via the mixture rule. Using pure methanol and acetone as a drying agent to extract water from a product is solvent use, and resulting wastes are F003. If a product contains only F003 solvents before use, wastes from solvent use are F003. F003 that is nonignitable when generated is still F003 until mixed with solid waste and qualifies for 261.3(a)(2)(iii) mixture rule exemption (SEE ALSO: 66 FR 27266; 5/16/01). If a tanker truck holding P- and U-listed hazardous waste is rendered empty according to 261.7 (contents removed using "reasonable" means and less than one inch or 0.3% of tanker volume remains), water from subsequent rinsing is not regulated, even if it contains traces of P- or U-listed chemicals.
	07/13/1989	DISTILLATION BOTTOM TARS AS K022 WASTE	Memo
	Description: The K022 listing for "distillation bottom tars from the production of phenol/acetone from cumene" includes liquids.
	07/12/1989	CLARIFICATION OF K064 LISTING	Memo
	Description: Magma Copper's acid plant blowdown (APB) and APB/tailings mixture is not K064 because it is not thickened into sludge or slurry.
	07/10/1989	1,1,1-TRICHLOROETHANE CONTAINED IN A SAND-METAL-SOLVENT MIXTURE	Memo
	Description: If a metal part is degreased in F001-F005 solvent and then ground with sand, the resulting metal and sand waste containing traces of solvent is not F001-F005 or listed via mixture rule. The metal and sand mixture is considered a process waste contaminated with solvent that was not "spent" (SEE ALSO: RPC# 3/1/87-03).
	07/06/1989	ACID PLANT BLOWDOWN SLURRY/SLUDGE FROM PRIMARY COPPER PRODUCTION	Memo
	Description: Magma Copper's acid plant blowdown (APB) and APB/tailings mixture is not K064 because it is not thickened into a sludge or slurry.
	07/06/1989	SPENT CYANIDE PLATING BATH SOLUTIONS FROM SILVER RECOVERY	Memo
	Description: An operation that recovers silver ions from cyanide bath is not an electroplating process, and resultant waste is not F007. Contains description of electroplating operations.
	07/05/1989	CHARACTERISTIC HAZARDOUS WASTE OR SOLID WASTE TREATMENT MAY CREATE A LISTED HAZARDOUS WASTE	Memo
	Description: Waste derived from the treatment of waste listed solely for exhibiting a characteristic (e.g., F003) is listed unless mixed with solid waste and the mixture no longer exhibits a characteristic (SUPERSEDED: 66 FR 27266; 5/16/01; SEE ALSO RPC# 11/4/92-01). The treatment of nonhazardous or characteristic electroplating wastewater can generate a listed F006 sludge, whether treatment occurs at generator facility or off-site TSDF.
	07/01/1989	CLARIFICATION OF THE F009 LISTING	Question & Answer
	Description: The F009 listing applies only to spent cleaning and stripping baths from electroplating processes that are used after the cyanide bath, because these baths contain cyanide due to dragout (SEE ALSO: RPC# 7/12/94-01).
	06/28/1989	SOLVENT AND COMMERCIAL CHEMICAL PRODUCT WASTE STREAMS	Memo
	Description: A listed solvent used to extract aqueous liquid from a product stream meets a listing when it is spent and removed from the process. An extracted aqueous wastestream which picked up trace amounts of solvent during extraction is not F001-F005. A chemical made in a lab instead of purchased from a commercial source is equivalent to a CCP and could be P-listed or U-listed when disposed. Diluting a CCP to make a lab standard is not "use" and excess diluted CCPs that are not analyzed can meet a P or U listing.
	04/26/1989	RECYCLING OF ELECTROPLATING SLUDGES (F006) FOR CEMENT/AGGREGATE MANUFACTURE	Memo
	Description: Discussion of sham recycling. Lists criteria to be used in deciding whether processing of secondary material is legitimate recycling or regulated hazardous waste treatment and sham recycling. Cement kiln dust (CKD) generated when F006 is used as ingredient is only exempt if CKD chemical makeup is not significantly affected by the use of hazardous waste (SUPERSEDED: see 266.112). F006 destined for use as ingredient in aggregate, cement, or other products to be placed on the land is regulated as a hazardous waste from the point of generation forward until 266.20(b) is satisfied. Smelting or recovering metals from F006 is not subject to regulation (SEE ALSO: Part 266, Subpart H). Smelter slag residue from F006 metal recovery is hazardous waste via derived-from rule (SEE ALSO: 261.3(c)(2)(ii), 266.20(c), and 59 FR 67256; 12/29/94).
	04/19/1989	GENERATOR TREATMENT OF F006 ELECTROPLATING SLUDGE	Memo
	Description: Stabilizing F006 compounds prior to thermal drying is hazardous waste treatment. A permit is not needed if the unit is exempt under 270.1(c)(2) or if treatment occurs in generator accumulation units in compliance with 262.34. A permit is required if thermal treatment of hazardous waste is involved.
	04/12/1989	WASTE SOLVENT-BASED GLUE	Memo
	Description: A solvent used as an ingredient is not an F001-F005 spent solvent. A waste glue with a solvent ingredient is not listed.
	03/06/1989	CLARIFICATION OF THE SCOPE OF THE K088 LISTING	Memo
	Description: The K088 listing for spent potliners only applies to the carbon portion contained inside the electrolytic cell. Other materials contained in the pot are not covered by the listing.
	03/03/1989	CLARIFICATION OF THE SCOPE OF THE K088 LISTING	Memo
	Description: The K088 listing only applies to the carbon portion of the material contained inside the electrolytic reduction cell. Other materials contained in the pot are not within the scope of the listing. Newly listed wastes (e.g., K088) for which EPA has not established treatment standards are not subject to land disposal restrictions (LDR).
	03/01/1989	DEFINITION OF SPENT SOLVENT	Question & Answer
	Description: Cutting oil containing 80 percent 1,1,1-trichloroethane, before use, is not F002 when spent. 1,1,1-trichloroethane is used as an ingredient, which is not a use covered by the F001-F005 spent solvent listings.
	03/01/1989	K061 WASTE	Question & Answer
	Description: K061 only applies to primary steel producers. Foundry emission control dust is excluded from K061 listing. Emission control dust generated from electric arc furnaces using scrap steel to produce semi-finished goods, such as steel billets and rolled steel, is regulated as K061.
	03/01/1989	SPENT SOLVENTS IN SCINTILLATION COCKTAILS	Question & Answer
	Description: Xylene in scintillation cocktails is used as a reaction medium. A used scintillation cocktail meets the F003 listing when spent. Explains the use of scintillation cocktails.
	01/24/1989	REGULATORY STATUS OF WASTEWATER TREATMENT SLUDGES FROM ZIRCONIUM PHOSPHATING OF ALUMINUM CANS	Memo
	Description: Wastewater treatment sludges from processes involving zirconium phosphating of aluminum cans should be excluded from F019. EPA plans to modify the F019 listing to exclude these wastes. The exclusion would apply retroactively to wastes generated before promulgation of the final exclusion.
	01/01/1989	REGULATORY STATUS OF WASTEWATER TREATMENT SLUDGES FROM ZIRCONIUM PHOSPHATING OF ALUMINUM CANS	Memo
	Description: Wastewater treatment sludges from zirconium phosphating of aluminum cans do not contain or form Appendix VIII constituents in hazardous concentrations and should not be hazardous waste. Proposes modifying the F019 listing (SEE ALSO: 55 FR 5340; 2/14/90).
	12/07/1988	INDUSTRIAL PLATING OPERATIONS, STATUS OF VARIOUS WASTES FROM	Memo
	Description: Electroless plating is not electroplating. A facility with a recycling unit needs a permit only for hazardous waste storage prior to or after recycling unless the reclamation process involves incineration or land disposal. Partially reclaimed waste which only needs further refining before it can be beneficially used may not be a waste. Partially reclaimed material may be eligible for a variance. Discussion of the regulatory status of filter cake from treatment of plating wastes. Filter cake from thre treatment of an electroplating bath is more likely to be a spent material than a sludge (i.e., plating bath is not wastewater).
	12/06/1988	SOLVENT-CONTAMINATED WASTESTREAMS FROM A PHARMACEUTICAL MANUFACTURER; SOLVENT-CONTAMINATED WASTESTREAMS FROM PHARMACEUTICAL MANUFACTURER	Memo
	Description: F001-F005 solvents used as carriers, extractants, etc. are listed hazardous waste when separated from the process in which they were used, but other wastestreams (extracted wastewaters, etc.) that picked up trace solvents during process (carryover) are not F001-F005 or listed via mixture rule once separated from process. Rinsewaters with solvent from equipment rinsing are not listed solvents. Solvents used as ingredients or reactants incorporated into products are not used as solvents and do not trigger F listings.
	11/16/1988	CASE-BY-CASE EXTENSIONS OF LAND DISPOSAL RESTRICTIONS EFFECTIVE DATES	Memo
	Description: EPA is aware of special problems in storing dioxin-containing wastes since no facilities are permitted to treat or dispose of these wastes. Discussion of notice of information needed to process case-by-case extension application.
	11/04/1988	GENERATION AND TREATMENT OF K044 WASTE	Memo
	Description: K044 (listed solely for exhibiting a characteristic) that no longer exhibits the reactivity characteristic after being treated in a facility’s wastewater treatment system is no longer K044, but must be designated as a hazardous waste if it exhibits another characteristic (SEE ALSO: 268.3; 66 FR 27266; 5/16/01).
	10/27/1988	TREATMENT RESIDUALS OF CHARACTERISTIC HAZARDOUS WASTE AS A LISTED HAZARDOUS WASTE	Memo
	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.
	10/03/1988	IMMERSION PLATING WASTEWATERS-BRONZE PLATING	Memo
	Description: The plating of copper-tin (bronze) alloy on carbon steel wire using no electrodes or electrolysis is "immersion plating" and is not electroplating operation triggering F006-F009 listings.
	09/01/1988	STILL BOTTOM WASTE GENERATED DURING THE PRODUCTION OF POLYSTYRENE	Memo
	Description: Toluene used as a carrier or diluent during the production of polystyrene is used as a solvent. Still bottoms from the recovery of spent toluene are F005, even if they are generated in a closed-loop recycling process.
	08/29/1988	PENTACHLOROPHENOL AS A WOOD PRESERVATIVE	Memo
	Description: EPA is considering a petition to change the designation of pentachlorophenol (PCP)-containing wastes F021 and F027 from acutely hazardous to toxic. The banning of chemicals is outside the purview of the Office of Solid Waste.
	07/28/1988	PAINT FILTERS, USED	Memo
	Description: Filters from paint spray booths are not listed hazardous waste, although they may exhibit characteristics (does not address filters capturing solvents used to clean booths). if F001-F005 solvent is used to clean paint-laden filter, the resulting solution of paint and thinner is a listed hazardous waste.
	07/21/1988	CHLOROFLUOROCARBON RECYCLING	Memo
	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).
	06/15/1988	RECYCLING OF ELECTRIC ARC FURNACE DUST	Memo
	Description: K061 is a solid waste (SW) until it enters the load cell reactor where reclaimed. Reclamation is not regulated. K061 run through a process associated with primary steel production may not be a SW. Processed zinc-rich metal oxide may no longer be SW per 261.3(c)(2). Discussion of reasons for listing K061. Slag from K061 reclamation used as aggregate is a SW unless the material has undergone a chemical reaction so that hazardous waste is inseparable by physical means (SUPERSEDED: SEE 266.20(c), and RPC# 2/16/95-01).
	05/13/1988	INTERPRETATION OF 40 CFR 268.7 REQUIREMENTS	Memo
	Description: Listings depend on how materials are used in a process, not only on the hazardous constituents. Restricted wastes that are treated, stored, disposed on site or sent off site are subject to the testing, recordkeeping, and manifest requirements. Wastes sent to a recycling facility are subject to the land disposal restrictions (LDR). Treatment residues are subject to LDR notification (SEE ALSO: 62 FR 25997; 5/12/97).
	05/13/1988	LAND DISPOSAL RESTRICTIONS TESTING AND RECORD KEEPING REQUIREMENTS	Memo
	Description: Listings depend on how materials are used in a process, not only on the hazardous constituents. Restricted wastes that are treated, stored, disposed on site or sent off site are subject to the testing, recordkeeping, and manifest requirements. Wastes sent to a recycling facility are subject to the land disposal restrictions (LDR). Treatment residues are subject to LDR notification (SEE ALSO: 62 FR 25997; 5/12/97).
	05/05/1988	PAINTS CONTAINING SOLVENTS	Memo
	Description: Wastes containing solvents that were used as reactants or ingredients in CCPs are not F-listed hazardous waste. Paints that contain F001-F005 solvents as ingredients are not F-listed when discarded.
	05/02/1988	SPENT PICKLE LIQUOR CORROSIVITY	Memo
	Description: Spent pickle liquor generated by a steel fabricator is not K062 since the facility is not in SIC codes 331 or 332. Nonlisted spent pickle liquor is corrosive if it corrodes 1020 steel at a rate of >0.25 inches/year. Nonlisted sludge from a pickling tank is D002 if pH of the sludge is < 2. The 264.314 liquids in landfills ban does not apply to nonhazardous waste disposal facilities.
	05/01/1988	HAZARDOUS WASTE IDENTIFICATION - K111 LISTING	Question & Answer
	Description: The K111 listing includes product washwaters from the production of dinitrotoluene (DNT) as an intermediate to trinitrotoluene (TNT).
	04/21/1988	DISTILLATION OR FRACTIONATION COLUMN BOTTOMS FROM THE PRODUCTION OF CHLOROBENZENE	Memo
	Description: Persons may petition EPA to add new types of units to the industrial furnace definition. Distillation or fractionation column bottoms from the production of chlorobenzene (K085) are by-products. Discussion of by-product versus co-product. Bottoms that must be further processed before use are not co-products. EPA intends to designate all materials introduced into halogen acid furnaces (HAFs) as inherently waste-like. A chlorinated by-product reused as ingredient in chlorinated feedstocks and muriatic acid is not a solid waste (SW) if no burning, reclamation, disposal, or speculative accumulation is involved (SUPERSEDED: see 56 FR 7134; 2/21/91). A generator must be able to provide supporting documentation for exempt wastes. If a material is a SW depends on the disposition, or intended disposition, of the material. Discussion of the regulatory status of a gas-fired thermal oxidizer. Discussion of the status of an oxidation reactor burning chlorinated benzene process streams in titanium dioxide production depends on if material is burned for energy recovery or as ingredient in industrial product (SUPERSEDED: see Part 266, Subpart H). Burning waste in an incinerator is destruction subject to incinerator standards.
	04/14/1988	APPLICABILITY OF SOLVENT AND ELECTROPLATING LISTINGS	Memo
	Description: Discarded paint, residues (scrubber water) with a solvent ingredient are not F-listed, but may be characteristic. Paint stripper is a solvent use. A sludge from metal cleaning wastewater associated with electroplating is F006. Routine cleaning, stripping not normally associated with electroplating. The purpose of cleaning, not the location, determines if associated. Metal stripping is part of electroplating. Stripped paint waste listed solely for a characteristic (F003) mixed with a solid waste is hazardous only if it is characteristic (SEE ALSO: 66 FR 27266; 5/16/01). Discussion of mixture rule wastewater exclusions (SEE: 261.3(a)(2)(iv)). F007-F009 are for cyanide electroplating solutions or where cyanides are used in the process. A spent stripping bath itself might also be F001-F005. The scale and size of aluminum chemical conversion coating operation does not affect F019.
	04/07/1988	ELECTROPLATING RINSEWATERS NOT IN F007-009 LISTINGS	Memo
	Description: Electroplating rinsewaters are not listed unless they are deliberately mixed with F007, F008, or F009. Rinsewaters with cyanide plating, cleaning bath carryover not listed via the mixture rule (SEE ALSO: RPC# 7/12/94-01; RPC# 7/28/87-02; RPC# 11/24/86-02).
	04/01/1988	HAZARDOUS 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).
	04/01/1988	SPENT SOLVENT LISTINGS	Question & Answer
	Description: Cutting oil containing, before use, 80 percent 1,1,1-trichloroethane and 20 percent lubricating oil is F002 when spent because 1,1,1-trichloroethane is used a a diluent for mobilizing constituents in lubricating oil (SUPERSEDED: See RPC# 3/1/89-02).
	03/31/1988	SOLVENT/MIXTURE BLENDS	Memo
	Description: If a product solvent has less than 10% total of listed solvents (F001, F002, F004, or F005), it is not a listed hazardous waste after use. It could be F003 or characteristic.
	03/14/1988	ECOSCINT A & ECOSCINT O	Memo
	Description: Ecoscint A and Ecoscint O are not listed. They would be hazardous waste if they exhibit a characteristic.
	03/11/1988	REFRACTORY WASTES AT U.S. EPA COMBUSTION RESEARCH FACILITY	Memo
	Description: Air filters, scrubber water, and ash from incinerating F020 are F020 via the derived-from rule. Wastes derived from F020 are acute hazardous wastes that are subject to special standards for dioxin wastes. Media and debris from dismantling an incinerator are F020 via the "contained-in" policy. They are F020 until they no longer contain F020.
	03/10/1988	STAINLESS STEEL PRODUCTION RESIDUES	Memo
	Description: Residue derived from extracting chromium and nickel from K061 is K061, unless it is delisted (SEE ALSO: 261.3(c)(2)(ii)(C)). K061 applies solely to emission control dust or sludge from electric arc furnaces used in primary steel production (e.g., stainless steel) and not for casting operations.
	03/08/1988	PROCESS WASTEWATER FROM METAL DEGREASING OPERATIONS	Memo
	Description: Solvent-contaminated water in a rinse tank is a process waste, not a spent solvent, and is hazardous only if it exhibits a hazardous characteristic. Includes a comparison of the mixture rule exemption for solvent-water and the land disposal national capacity variance for wastes with less than 1% F001-F005 solvents.
	02/22/1988	WASTES CONTAINING F001-F005 CONSTITUENTS	Memo
	Description: A mixture with hazardous waste (HW) that is listed solely for a characteristic is not HW if the mixture is not characteristic (SEE ALSO: 268.3; 66 FR 27266; 5/16/01). A mixture of F001, D001 carries all applicable codes. A listed solvent constituent in a wastestream does not automatically render a waste HW. It is HW only if it meets the F001-F005 descriptions. If it is HW, it is subject to the land disposal restrictions (LDR). If a transporter mixes wastes of different DOT shipping descriptions, the transporter becomes the generator of new waste.
	02/11/1988	SPENT PIPELINE FILTER CARTRIDGES	Memo
	Description: If F-listed solvents pass through a pipeline and filter cartridge, the spent filter is listed via the derived-from rule until or unless it is delisted (SEE ALSO: 66 FR 27266; 5/16/01). If the filter contains a discarded P- or U-listed CCP solvent, the filter is listed until it no longer contains hazardous constituents.
	02/11/1988	STILL BOTTOM WASTE GENERATED BY A POLYSTYRENE PRODUCTION FACILITY	Memo
	Description: Using toluene as a feedstock in a product or as a "chain transfer agent" (as a reactant controlling the rate of a reaction that is partially consumed in the process) is not a solvent use. Excess toluene recovered from such operations is not F005.
	01/26/1988	ZINC OXIDE RECLAIMED FROM KILNS	Memo
	Description: Discusses indigenous secondary materials (SEE ALSO: 266.100). Partially reclaimed K061 which must be reclaimed further is still a solid waste and is derived from K061. Kiln residue is not exempt because K061 is from primary steelmaking, not from the processing of ores and minerals. F006, F019, and K062 are not indigenous to zinc smelting. The 3004(u) authority applies to releases of Bevill wastes and to releases from pre-RCRA inactive units. Units holding product are not solid waste management units (SWMUs) unless routine and systematic releases occur. Addresses American Mining Congress (AMC) v. EPA. The status of dust from a kiln burning K061 could change when the BIF regulations are finalized (SEE ALSO: 261.3(c)(2)(iii)(C)(1) and 261.4(a)(11)) (SAME AS 9481.1988(01)).
	01/25/1988	NEW JERSEY ZINC COMPANY K061 STORAGE PILE	Memo
	Description: A partially reclaimed waste that must be reclaimed further before it can be used as a product is still a solid and hazardous waste. Discusses the derived-from exemption for residue from processing K061, K062, and F006 in a high temperature metal recovery unit. Addresses American Mining Congress (AMC) v. EPA. The status of dust from a kiln burning K061 could change with the final BIF rule (SEE: 261.4(a)(11) and 261.3(c)(2)(iii)(C)(1)). Discusses indigenous secondary materials (SEE: 266.100). The 3004(u) corrective action authority applies to Bevill waste and releases from pre-RCRA inactive units. Units holding product are not solid waste management units (SWMUs) for purposes of 3004(u) unless routine and systematic releases occur (SAME AS 9444.1988(02a)).
	01/11/1988	METAL FINISHING SLUDGES	Memo
	Description: Mechanical burnishing and polishing are not electroplating for F006-F009. Pickling to remove oxide scale could be cleaning or stripping associated with electroplating. Copper etching on gold-plated copper tubing is electroplating. Non-wastewater spent stripping or plating bath treatment sludge is not F006. A spent etching acid solution is not wastewater. Wastewater treatment sludge that is used solely for non-contact cooling is not F006. Spent pickling bath used to remove oxide scale from precious metals is not K062.
	01/04/1988	TOLUENE-CONTAINING PAINT PRODUCTS FROM WOOD PIECES, REGULATORY STATUS	Memo
	Description: The spent solvent listings do not apply to solvent-containing production wastes, including ingredient solvent in paint skimmings from paint spray booth overspray.
	12/28/1987	F006 LISTING FOR PICKLING AND ETCHING WASTES AND DELISTING ISSUES	Memo
	Description: Wastewater treatment sludges from aluminum etching are exempt from the F006 listing. Sludges are hazardous if they are mixed with spent pickle liquor (K062) or with other listed wastes.
	12/28/1987	REGULATORY STATUS OF LIME-STABILIZED WASTE PICKLE LIQUOR SLUDGE	Memo
	Description: By narrowing the K062 listing, EPA narrowed the derived-from rule exemption for lime-stabilized waste pickle liquor sludge (LSWPLS). The exemption does not apply if K062 is treated with other listed wastes. If the spent pickle liquor is treated with other nonhazardous or characteristic wastes, the sludge is hazardous only if it is characteristic.
	12/24/1987	COAL TAR DECANTER SLUDGE WASTE PILE (TOLEDO COKE)	Memo
	Description: Discusses the regulatory status of a coal tar decanter sludge waste pile. K087 stored before recycling in coke or coal tar production is not exempt under 261.6(a)(3)(vii) (SUPERSEDED: See 56 FR 7203; 2/21/91, 261.4(a)(10), and 261.4(a)(12)).
	12/16/1987	IRON CAKE WASTE GENERATED DURING THE PRODUCTION OF METHYLDOPA	Memo
	Description: Toluene used as a carrier in a manufacturing process is used as a solvent and receives an F-listing after it is spent and separated from the product. However, when iron filter cake containing trace toluene levels is separated from the product, the solvent on the cake (carryover) is not F-listed and does not render the cake listed via the mixture rule.
	12/15/1987	F005 LISTING FOR PYRIDINE STILL BOTTOMS	Memo
	Description: Still bottoms from the reclamation of pyridine meet the F005 listing.
	12/11/1987	K035 LISTING AND DELISTING ISSUES:GROUNDWATER CONTAMINATION	Memo
	Description: K035 includes sludges generated from the biological treatment of creosote production wastewaters. Waste cannot be delisted unless it is sufficiently characterized to demonstrate that it is nonhazardous, including showing that the waste is not characteristic and is not hazardous for other reasons.
	12/11/1987	K035 LISTING AND INCLUSION OF SLUDGES FROM BIOLOGICAL TREATMENT OF CREOSOTE PRODUCTION WASTEWATERS	Memo
	Description: K035 includes sludges generated from the biological treatment of creosote production wastewaters. Waste cannot be delisted unless it is sufficiently characterized to demonstrate that it is nonhazardous, including showing that the waste is not characteristic and is not hazardous for other reasons.
	12/04/1987	WASTE FROM ELECTROLESS PLATING PROCESSES NOT COVERED UNDER REINTERPRETED F006 LISTING	Memo
	Description: Wastewater treatment sludge from an electroless plating operation is not F006, but must be evaluated for hazardous waste characteristics.
	11/10/1987	PICKLE LIQUOR RECOVERY UNIT AS AN INDUSTRIAL FURNACE	Memo
	Description: An industrial furnace in which spent pickle liquor (K062) is processed to produce a usable product hydrogen chloride and ferrous oxide is not an incinerator, but is a smelting, melting, and refining furnace. The unit is not regulated as an incinerator since the purpose is to produce a product and not to destroy a waste.
	10/26/1987	REACTOR VESSEL WASHOUT CONTAINING TRACE AMOUNTS OF SOLVENT	Memo
	Description: Reactor vessel washout containing residues of solvent (acetone, ethyl acetate, and xylene) and fragrance oils is not F003, but is process wastewater contaminated with solvent constituents. If the wastewater is ignitable, it is regulated as D001 until it is no longer characteristic.
	10/26/1987	SOLVENT-CONTAMINATED WASTEWATER FROM FRAGRANCE MANUFACTURE	Memo
	Description: Oil and trace solvents that remain in a reactor vessel following washing with acetone, ethyl acetate, and xylene do not meet the spent solvent definition. Subsequent soap and water washout is process wastewater containing solvent constituents that can be ignitable (D001) but is not F003 via the mixture rule. Residues generated from treating a D001 ignitable waste remain hazardous as long as they exhibit a characteristic.
	10/23/1987	LUBRICATING OIL CONTAMINATED WITH TCDD THROUGH USE AS AN ANALYTICAL STANDARD	Memo
	Description: Lubricating oil that is contaminated with dioxins from TCDD use as an analytical standard is not listed, but is hazardous if characteristic. Even if it is characteristic, the oil is subject to Part 266, Subpart E if the used oil is burned for energy recovery (SUPERSEDED: See Part 279).
	10/23/1987	SUPERNATANT FORMED IN LIME STABILIZATION OF WASTE PICKLE LIQUOR AS HAZARDOUS WASTE	Memo
	Description: Supernatant from the lime-stabilization of waste pickle liquor is derived from K062. The supernatant portion does not qualify for the 261.3(c)(2)(ii) exclusion, which applies only to sludge generated from the treatment process. A surface impoundment holding supernatant is subject to regulation.
	10/23/1987	SUPERNATANT FROM TREATMENT OF SPENT PICKLE LIQUOR (K062)	Memo
	Description: Supernatant from lime-stabilization of waste pickle liquor is derived from K062. The supernatant portion does not qualify for the 261.3(c)(2)(ii) exclusion, which applies only to sludge generated from the treatment process. A surface impoundment holding supernatant is subject to regulation.
	10/16/1987	THERMAL OXIDIZER AND HYDRODECHLORINATION PROCESS BY-PRODUCT K-WASTES	Memo
	Description: Thermal oxidation and hydrodechlorination are considered reclamation. Distillation bottoms ("polychlor material") from chlorinated benzenes production are by-products and are K085 (SEE ALSO: RPC# 4/21/88-01).
	10/09/1987	FILTER CAKE WASTE CONTAINING SOLVENT USED TO SOLUBILIZE PRODUCT	Memo
	Description: Filter cake waste generated in the production of methyldopa is not F005. EVEN IF TOLUENE IS USED FOR ITS SOLVENT PROPERTIES, if the solvent is not spent, the iron cake is a process waste contaminated with solvent, not a listed solvent waste.
	09/23/1987	F021 LISTING FOR SUBSTANCES CONTAINING CHLOROPHENOLIC COMPOUNDS	Memo
	Description: Wood chips and sawdust from wood treated with a pentachlorophenol (PCP) formulation (Noxtane) are not F-listed or K-listed. They could be characteristic. Discarded CCP Noxtane is F027 due to the active ingredient PCP.
	09/15/1987	INK FORMULATION WASTES AS BOTH K086 AND F001-005 WASTES	Memo
	Description: Wastes from ink formulation may meet both the K086 and F001-F002 spent solvent listing. If the solvent does not meet the before-use percentage criterion, the waste is K086 only.
	09/02/1987	LIME STABILIZED WASTE PICKLE LIQUOR SLUDGE EXCLUSION	Memo
	Description: Lime-stabilized waste pickle liquor (K062) sludge is exempt via the derived-from rule and is no longer listed. The stabilization of K062 is treatment and may require a permit.
	09/02/1987	WASTEWATERS EXCLUSION FROM THE DEFINITION OF F021 FOR PCP MANUFACTURE	Memo
	Description: All wastewaters from the production of pentachlorophenol (PCP) are excluded from the F021 listing as well as the other listings for dioxin-bearing hazardous waste.
	09/01/1987	STILL BOTTOM WASTE FROM POLYSTYRENE PRODUCTION	Memo
	Description: Diluent (carrier solubilizing process feedstocks or reactant ingredients) is a solvent use for F001-F005 (SUPERSEDED: see RPC# 2/11/88-02). Excess toluene recovered from Chevron's process is a F005 diluent. Secondary materials in a closed-loop reclamation process are exempt. Still bottoms and other wastes formed in the reclamation process are solid wastes.
	08/31/1987	MIXING LOW AND HIGH BTU WASTES - SHAM BURNING, BLENDING, MANIFESTING	Memo
	Description: Sham burning (less that 5000 Btu/lb heating value) determination is site-specific. Blending high and low Btu value waste may not render subsequent burning sham (SUPERSEDED: see 11/8/94-01; 266.100). A listed waste treatment residue retains the listing. EPA waste codes are not required on the manifest by EPA, but States or DOT may require them (SEE ALSO: RPC# 11/17/89-01).
	08/31/1987	MIXTURES OF WASTES AND LEGITIMATE BURNING FOR ENERGY RECOVERY	Memo
	Description: A sham recycling of waste by burning (less than 5000 Btu heating value) determination is site-specific. The blending of high and low Btu value waste may not render subsequent burning a sham (SUPERSEDED: RPC# 11/8/94-01; 266.100). A listed waste treatment residue retains its listing. EPA waste codes are not required on the manifest by EPA, but states or DOT may require them (SEE ALSO: RPC# 11/17/89-02).
	08/25/1987	CAUSTIC RINSING METAL PARTS	Memo
	Description: Small amounts of solvent (trichloroethylene) carried over (carryover) on metal parts from solvent degreasing do not meet the solvent listings. Caustic rinsewater containing solvent carryover is not a hazardous waste if it does not exhibit a characteristic.
	08/17/1987	MIXTURE OF F003 AND A SOLID WASTE AND DELISTING REQUIREMENTS	Memo
	Description: Still bottoms from methanol recovery are F003, and are regulated hazardous wastes at the source of generation. If still bottoms are mixed with a solid waste and the mixture does not exhibit a characteristic (SEE ALSO: 66 FR 27266; 5/16/01), it is not a hazardous waste via the 261.3(a)(2)(iii) exemption from the mixture rule for wastes listed solely for exhibiting a characteristic (SEE ALSO: 268.3).
	08/17/1987	TOLUENE AS A DILUENT OR CARRIER AND THE SCOPE OF THE F005 LISTING	Memo
	Description: Toluene added as a diluent and carrier in Chevron’s polystyrene production process is used as solvent. Waste (still bottoms) from a recovery tower is F005. Still bottoms from solvent recovery generated in a closed-loop recycling unit can be listed wastes.
	08/10/1987	INTERPRETATION OF THE F006 LISTING RELATIVE TO COLLIS, INC., CLINTON, IOWA	Memo
	Description: Since chromate conversion coating is no longer within the scope of electroplating operations, sludges from the treatment of associated wastewaters are not F006.
	08/07/1987	RINSE WATERS CONTAINING TCE SOLVENT	Memo
	Description: Small amounts of solvent (trichloroethylene) carried over (carryover) on metal parts from solvent degreasing do not meet the solvent F-listings. Caustic rinsewater containing solvent carryover is not a hazardous waste if it does not exhibit a characteristic.
	08/07/1987	WASTES FROM ENVIRONMENTAL CHEMISTRY LABORATORY	Memo
	Description: High temperature incineration is the recommended method of management for lab wastes that are not listed hazardous waste and that do not exhibit any characteristics, even though they are contaminated with dioxins.
	07/31/1987	BRIQUETTING OF FLUE DUST (K061) FOR STEEL PRODUCTION	Memo
	Description: Briquetting is not reclamation. Flue dust K061 that is mixed with sodium silicate binder and pressed into briquettes is not solid waste if it is directly reused in steel production and is not reclaimed.
	07/30/1987	CORRECTED LISTING DESCRIPTION FOR K062	Memo
	Description: Waste pickle liquor from an etching process classified under SIC Codes 3465 and 3449 is not K062.
	07/28/1987	F009 LISTING AND THE MIXTURE RULE TO ELECTROPLATING RINSEWATERS AND RESINS; ELECTROPLATING RINSEWATERS	Memo
	Description: Any residual (e.g., ion exchange canisters) from treating electroplating wastewaters for pollution control is F006 sludge. Electroplating rinsewaters are not listed, but the treatment of the rinsewater can create a listed F006 waste. If drops of stripping or cleaning solution (F009 when spent) on a part are carried over (carryover) to the rinsewater during the normal electroplating process, the rinsewater is not considered F009 via the mixture rule. Electroplating rinsewaters are not stripping or cleaning baths and cannot be F009. Sludges from the treatment of rinsewater could be F006 (SEE ALSO: RPPC 7/12/94-01; RPPC 4/7/88-01; RPPC 11/24/86-02).
	07/24/1987	WASTES GENERATED BY COKE AND COAL TAR PLANTS	Memo
	Description: There are no solids or organics content or % water limits for “primarily aqueous” wastewater streams. Addresses the industrial wastewater discharge exclusion (261.4(b)(2)) and “commonly defined by the industry as wastewaters,” and provides examples. The wastewater treatment unit (WWTU) exemption is not for surface impoundments. Discusses “trigger” levels for possible coke by-product K-listings. The listing will be based on 261.11 criteria, which are based on potential hazards and mismanagement, but are not based directly on waste minimization.
	07/21/1987	F003 10% RULE AND ASSOCIATED REGULATIONS	Memo
	Description: Discarded, used paint thinner that is 80% xylene, 9% toluene, and 11% glycol ethers before use is ignitable (D001) not F003, F005. Ignitable solvent rags are not subject to the land disposal restrictions (LDR) until third third (SEE ALSO: 55 FR 22520; 6/1/90 and RPC# 2/14/94-01).
	07/13/1987	LIME-STABILIZED WASTE PICKLE LIQUOR SLUDGE EXEMPTION FOR LIME-AMMONIA STABILIZED IRON OXIDE SLUDGE	Memo
	Description: Lime-ammonia stabilized iron oxide sludge derived from the stabilization of spent pickle liquor (K062) is exempt under the lime-stabilized waste pickle liquor sludge derived-from rule exemption.
	07/13/1987	WASTES FROM BRIGHT DIPPING UNDER THE REINTERPRETED F006 LISTING	Memo
	Description: A bright dipping is defined as a chemical etching operation. Wastewater treatment sludge from electroplating operations involving chemical etching is F006.
	07/06/1987	F006 LISTING DOES NOT INCLUDE ZINC PHOSPHATING WASTEWATER TREATMENT SLUDGES	Memo
	Description: Wastewater treatment sludge from zinc phosphating on steel is not within the scope of the F006 listing. If a facility is in SIC Codes 331 or 332 and spent pickle liquor is introduced to a wastewater treatment system, the sludge may be K062.
	07/02/1987	FEDERAL POLICY REGARDING DIOXIN DISPOSAL	Memo
	Description: Includes a clarification of the federal policy on the disposal of dioxin and dioxin- contaminated material, a summary of EPA efforts to regulate dioxin under CWA, CERCLA, and RCRA, and a description of F-listed dioxin wastes (F020, F021, F022, F023, F027, F028).
	07/02/1987	INTERPRETATION OF RCRA HAZARDOUS WASTE DEFINITION FOR SLOP OIL EMULSION SOLIDS	Memo
	Description: The K049 listing (slop oil emulsion solids) is not limited to skimmings from API separators.
	06/30/1987	ELECTROLESS ZINC PLATING WASTE NOT IN F006 LISTING	Memo
	Description: Zinc plating on carbon steel on segregated basis, sulfuric acid anodizing of aluminum, electroless zinc plating, and phosphating on steel are exempt from the F006 listing.
	06/25/1987	REGULATORY STATS OF HYDROCHOLORIC ACID CO-PRODUCT FROM PENTACHLOROPHENOL PRODUCTION	Memo
	Description: Discusses co-product v. by-product. A co-product is not a solid waste if it is produced intentionally and is ordinarily used in its existing state as a commodity. Hydrochloric acid from hydrogen chloride gas in pentachlorophenol (PCP) manufacture is a co-product, not F021.
	06/24/1987	F019 LISTING AND THE CONVERSION COATING PROCESS	Memo
	Description: Chemical conversion coating (chromating, phosphating, metal coloring, immersion plating) changes the surface properties of a part by converting the underlying or base metal. Zirconium phosphating of aluminum cans triggers F019 (SUPERSEDED: See 55 FR 5340; 2/14/90).
	06/22/1987	STATUS OF WASTES LISTED SOLELY FOR A CHARACTERISTIC UNDER THE MIXTURE RULE	Memo
	Description: F003 distillation still bottoms are hazardous waste via the derived-from rule, regardless of characteristics (SUPERSEDED: 66 FR 27266; 5/16/01). F003 is no longer listed if it is mixed with a solid waste and is not characteristic. The mixture rule does not specify what kind of solid waste can be mixed with it (SEE ALSO: 268.3).
	06/19/1987	REGULATORY STATUS OF VARIOUS TYPES OF PENTACHLOROPHENOL WASTES	Memo
	Description: F021 is for pentachlorophenol (PCP) manufacturing wastes, not for wood-preserving wastes like dip tank bottom sludge or discarded pentachlorophenol (PCP)-treated wood (SEE ALSO: F032). F027 is for unused PCP wood preservatives, not for used formulations which come in contact with wood that remains in process vessel or dip tank after treatment or contained-in treated wood (posts, poles, railroad ties); K001 for treatment sludges from wastewater from PCP or creosote wood preserving, not dip tank bottom sludge from PCP wood preserving facilities (SEE ALSO: 261.24 and 261.31)
	06/17/1987	METHANOL RECOVERY SYSTEM - CLARIFICATION OF WASTE STATUS	Memo
	Description: Volatilized methanol from a pharmaceutical production is not solid waste. Once it is condensed in carbon, the methanol and carbon are F003 (contained gas) (SUPERSEDED: see 56 FR 7200; 2/21/91). The removal of F003 from the carbon is exempt recycling.
	06/09/1987	USE/REUSE EXCLUSION TO RED WATER (K047) FROM WHICH SODIUM SULFITE IS RECOVERED AND WHICH IS USED AS A FUEL	Memo
	Description: A listed spent material, a sludge, and a by-product reclaimed and/or used as a fuel is a solid and hazardous waste. Recycling K047 is not an exempt use or reuse because sodium sulfite is recovered from K047 before reuse. Using K047 as a fuel is ineligible for the use or reuse exclusion.
	05/26/1987	PETROLEUM FACILITIES INCLUDED IN THE K051 LISTING FOR API SEPARATOR SLUDGE	Memo
	Description: Sludge generated in an API separator at a facility that is not a petroleum refinery is not K051. K051 covers facilities in SIC 2911 that perform the distillation of crude oil and/or unfinished petroleum derivatives.
	05/22/1987	F006 LISTING APPLIED TO PRINTING INDUSTRY	Memo
	Description: Electroplating wastewater treatment sludges generated by the printing industry are included in the F006 listing.
	05/20/1987	PAINT WASTES AND THE SPENT SOLVENT LISTINGS	Memo
	Description: Paint or paint sludge waste from a painting operation where paint has been thinned with waste xylene is not F003. Spent xylene used to clean spray guns is F003. A mixture of F003 and paint sludge produces F003 waste via the mixture rule (SEE ALSO: 66 FR 27266; 5/16/01). Sludge from the treatment of F003 remains F003, even if it no longer contains a solvent. Sludge may be land disposed if it meets treatment standards.
	05/20/1987	SOLVENT LISTINGS AND LAND DISPOSAL RESTRICTIONS	Memo
	Description: Discusses determining if solvent contaminated rags or wipers are listed hazardous waste (SUPERSEDED: RPC# 2/14/94-01). Product paint with a solvent ingredient is not listed, even if the solvent is added as a thinner after purchase. The addition of product solvent by the user is not solvent use. Listed solvents from ink formulation are both K086 and the appropriate F001-F005 when discarded. Lab solvents used as solvents are listed when spent. Technical grade F003 solvent can be F003 when spent. A solvent containing (before use) less than the technical grade of F003 and less than 10% F001, F002, F004, F005 is not listed.
	05/20/1987	SPENT PICKLE LIQUOR, DEFINITION AS HAZARDOUS	Memo
	Description: K062 spent pickle liquor that is destined for reclamation on site or off site is solid and hazardous waste subject to regulation until it enters an exempt recycling unit. Pickle liquor that is destined for reclamation becomes a spent material (and K062) when removed from the pickling line. That K062 can be reused does not affect its regulatory status if it is regenerated before reuse. Pickle liquor reused without reclamation may be exempt.
	05/20/1987	WASTE FROM CHEMICAL ETCHING USING CYANIDE	Memo
	Description: Chemical etching is an electroplating operation, and a cyanide-bearing stripping solution from the etching process is F009.
	05/14/1987	LABORATORY CARCASSES CONTAINING TCDD	Memo
	Description: Bird eggs and carcasses injected with dilute solutions of TCDD do not meet the listing descriptions for the dioxin wastes, F020-F023, F026-F028, and are not regulated under TSCA. They are infectious wastes per Part 241 and are best managed in high temperature incinerator (SEE ALSO: 60 FR 33912; 6/29/95).
	05/08/1987	WASTES FROM ZINC PLATING (SEGREGATED BASIS) ON CARBON STEEL EXCLUDED FROM F006	Memo
	Description: Wastewater treatment sludges from non-cyanide zinc plating processes (i.e., zinc plating (segregated basis) on carbon steel) are excluded from the F006 listing. The associated cleaning and stripping operations are also excluded. Such sludges are hazardous only if they are characteristic.
	05/05/1987	SPENT ION EXCHANGE RESINS AND FILTER AS HAZARDOUS WASTE	Memo
	Description: Filters as well as anionic and cationic ion exchange resins used to remove pollutants from electroplating rinsewater meet the definition of sludges and are F006, even if they are not characteristic. Waste from the regeneration of F006 ion exchange resins is F006 (except recovered metal that is sold as a product).
	04/30/1987	LABORATORY SAMPLE EXCLUSION APPLICABILITY TO SAMPLES AND WASTES FROM LABORATORY ANALYSIS - DIOXIN	Memo
	Description: The 261.4(d) exclusion for lab samples allows a laboratory to transport a sample back to the sample collector. Associated wastes generated during analysis (e.g., lab solvents or protective gear) are not excluded. Materials which contain listed waste must be managed as hazardous waste until they are decontaminated. Rinsate generated while decontaminating materials that contain acute hazardous waste are acute hazardous waste via the contained-in policy (SEE ALSO: 61 FR 18779; 4/29/96).
	04/27/1987	RESIDUALS FROM TREATMENT OF RESTRICTED WASTES NOT COVERED BY LESS-THAN-1% SOLVENT EXTENSION	Memo
	Description: Solvent contaminated rags are subject to the national capacity variance for F001-F005 solvent-containing sludges, solids, soils, and solvent-waste mixtures containing less than one percent of F-listed solvent constituents (SEE ALSO: RPC# 2/14/94-01).
	04/18/1987	SOIL CONTAMINATED WITH USED AND UNUSED PESTICIDES; SOIL CONTAMINATED WITH PESTICIDE	Memo
	Description: Soil contaminated with discarded unused 2,4,5-T contains F027. Soil contaminated with 2,4,5,-T used as pesticide does not contain a listed waste, but is hazardous if it is excavated for discard and is characteristic. Incinerators burning F-listed dioxin wastes must achieve 99.9999% destruction and removal efficiency.
	04/17/1987	CLEAN SOLVENT FROM RECYCLED SOLVENT-CONTAINING WASTE - STILL BOTTOMS	Memo
	Description: Clean solvent from a recovery process that is beneficially used is not a solid waste and is not subject to the land disposal restrictions (LDR). Still bottoms from solvent recovery are F-listed in 261.31 and are subject to Part 268.
	04/17/1987	USED OIL DESTINED FOR RECYCLING	Memo
	Description: The decision to not list used oil (51 FR 41900; 11/18/86) did not constitute a decision to not regulate used oil. EPA will issue used oil management standards and combustion controls (SEE ALSO: Part 279). Used oil mixed with hazardous waste or PCBs is currently regulated. Burning off-specification used oil is regulated.
	04/15/1987	SPENT AND RECLAIMED SOLVENTS, BLENDING OF RECLAIMED XYLENE	Memo
	Description: Blending recycled solvents to produce marketable solvent is not regulated. A solvent and chemical mixture from a blending error that is sold as a fuel becomes a solid and hazardous waste when it is determined that it is not suitable for solvent use. Hazardous waste fuel blending tanks are regulated.
	04/14/1987	SOLVENT LISTINGS FOR PAINT WASTES/REMOVER AND SPILL RESIDUE	Memo
	Description: Outdated virgin paint remover is not F-listed solvent because it has not been used. Used paint stripper may be an F-listed solvent, depending on the before-use concentration of F001-F005 constituents. A spent paint waste formulation is not an F-listed solvent. Tpe proper classification of spill residue containing 1,1,1- trichloroethane requires knowledge of the chemical prior to spilling.
	04/09/1987	F027 LISTING - USED AND UNUSED FORMULATIONS IN WOOD PRESERVING	Memo
	Description: F027 covers unused formulations, such as those which contacted wood or which remain in a dip or process tank after preservation. Dipping a piece of wood in a container of unused preservative in order to claim it as used is a sham. The preservative can be used even if not spent (i.e., still has value).
	04/01/1987	SOLVENT DRIPPINGS FROM DEGREASING OPERATIONS	Question & Answer
	Description: Solvent remaining on a metal part after degreasing (carryover) is not F001. A mixture of solvent, grinding sand, and metal flakes from a cooling system is hazardous only if it is characteristic (SEE ALSO: RPC# 3/1/87-03 ).
	03/31/1987	SPENT PICKLE LIQUOR, REUSE OF	Memo
	Description: Spent pickle liquor (K062) that is reused as a neutralizer may not qualify for the direct reuse exemption from the definition of solid waste (SW) depending on site-specific factors. K062 stored without being used for neutralization is clearly SW. The use in manner constituting disposal regulations only apply to wastes or waste-derived material that is placed on the land as a product.
	03/26/1987	F019 LISTING AND DEFINITION OF CONVERSION COATING	Memo
	Description: EPA is evaluating data to determine if Continental Can Company’s can washer sludges are F019. Discusses whether zirconium phosphating is chemical conversion coating (SEE ALSO: 55 FR 5340; 2/14/90).
	03/16/1987	K062 LISTING APPLIES ONLY TO FACILITIES WITHIN THE IRON AND STEEL INDUSTRY	Memo
	Description: Pickle liquor wastes from industries not in the iron and steel industrial classifications are hazardous only if they are characteristic. Because spent pickle liquor is generally corrosive (D002) and usually contains high concentrations of chromium and lead, it is probably characteristic.
	03/06/1987	AUTOMOTIVE FLUIDS, REGULATION OF	Memo
	Description: Automotive fluids are not listed hazardous waste, but they may be characteristic. Some brake and automatic transmission fluids are ignitable (D001). Used crankcase oil may be ignitable and may exhibit EP (extraction procedure) for lead (SUPERSEDED: see 261.24). Used oil (UO) that is recycled by burning is subject to 266 Subpart E; other UO recycling is exempt (SUPERSEDED: see Part 279). Brake fluid, power steering fluid, and automatic transmission fluid would all be considered UO. Antifreeze and windshield wiper fluid are not UO (SEE ALSO: 279.1).
	03/06/1987	AUTOMOTIVE FLUIDS, STATUS OF	Memo
	Description: Automotive fluids are not listed hazardous waste, but they may be characteristic. Some brake and automatic transmission fluids are ignitable (D001). Used crankcase oil may be ignitable and may exhibit EP (extraction procedure) for lead (SUPERSEDED: see 261.24). Used oil (UO) that is recycled by burning is subject to 266 Subpart E; other UO recycling is exempt (SUPERSEDED: see Part 279). Brake fluid, power steering fluid, and automatic transmission fluid would all be considered UO. Antifreeze and windshield wiper fluid are not UO (SEE ALSO: 279.1).
	03/06/1987	DRYCLEANING INDUSTRY WASTES	Memo
	Description: Perchloroethylene (PCE) condensed and recovered during fabric drying in a dry cleaning machine is a process waste, not an F-listed solvent. It is hazardous only if it is characteristic. PCE condensate from distillation or spent filter cartridge steam stripping is hazardous because it is derived from F002.
	03/03/1987	ASH RESIDUE GENERATED FROM INCINERATION OF K045	Memo
	Description: The mixture rule exclusion applies only to mixtures of solid waste (SW) and hazardous waste listed solely for characteristic, not residues from treating wastes listed for characteristic. K045 incineration residue is K045 even if the ash is not reactive (SEE ALSO: 66 FR 27266; 5/16/01).
	03/01/1987	SOLVENT DRIPPINGS FOR DEGREASING OPERATIONS (REPEATED IN APRIL 1987)	Question & Answer
	Description: Solvent remaining on a metal part after degreasing (carryover) is not F001. A mixture of solvent, grinding sand, and metal flakes from a cooling system is hazardous only if it is characteristic (SEE ALSO: RPC# 4/1/87-02) (Repeated in April 1987).
	03/01/1987	SOLVENT MIXTURE RULE	Question & Answer
	Description: Discusses the applicability of the solvent mixture rule to F003. Wastes that meet both the F003 and F005 listings must receive both waste codes on the manifest and on generator notification. A technical or commercial grade xylene solution meets the F003 listing.
	02/19/1987	PROCESS WASTES CONTAINING INKS, PAINTS, AND ADHESIVES	Memo
	Description: Waste paint, ink, and adhesive are not listed. These are hazardous only if characteristic. Products with ingredient or added solvent not are not listed solvents. A mixture of a listed solvent and a product destined for discard are F-listed via the mixture rule (SEE ALSO: 66 FR 27266; 5/16/01).
	02/05/1987	APPLICABILITY OF LAND DISPOSAL RESTRICTIONS (LDR) TO PAINT SLUDGE WASTES	Memo
	Description: Paint sludge waste from a water-wall paint spray booth is a manufacturing process waste, not an F-listed solvent.
	02/02/1987	STILL BOTTOMS FROM LISTED SOLVENT RECLAMATION	Memo
	Description: Still bottoms from F003 may be delisted pursuant to 260.20 and 260.22. If F003 is mixed with another solid waste and no longer exhibits a characteristic, it is no longer considered hazardous (SEE ALSO: current 261.3(a)(2)(iii); 66 FR 27266; 5/16/01).
	02/01/1987	F006	Question & Answer
	Description: Sludge generated off site from a mixture of corrosive (D002) electroplating rinsewater and other acid wastes is F006.
	02/01/1987	SMALL QUANTITY GENERATOR DETERMINATION	Question & Answer
	Description: A recycler who receives spent F005 solvents from off site must count both the still bottoms from solvent reclamation and the reclaimed solvent that is burned for energy recovery toward the monthly quantity determination. Reclaimed solvent used for solvent properties is not counted because it is beneficially reused.
	01/28/1987	APPLICABLIITY OF F006 LISTING TO BRIGHT-DIPPING OPERATIONS	Memo
	Description: Since bright-dipping is considered chemical etching, it is an electroplating operation and associated wastewater treatment sludges are F006.
	01/28/1987	MIXTURES OF PICKLE LIQUOR AND OTHER WASTES AND THE LIME STABILIZED WASTE PICKLE LIQUOR SLUDGE EXEMPTION	Memo
	Description: The derived-from rule exemption applies to lime-stabilized waste pickle liquor (K062) whether or not the spent pickle liquor has been mixed with other nonlisted process wastes generated by the iron and steel industry.
	01/28/1987	WASTES FROM ELECTROSTATIC WATERFALL CURTAIN PAINTING OPERATIONS	Memo
	Description: Electrostatic painting is not an electroplating operation. The treatment sludge resulting from use of a waterfall curtain in electrostatic painting operations is not F006.
	01/27/1987	ELECTROCHEMICAL MACHINING WASTES AND THE SCOPE OF THE F006 LISTING	Memo
	Description: Chemical etching and milling (which includes bright dipping, electropolishing, electrochemical machining) is an electroplating operation and associated wastewater treatment sludges are F006.
	01/27/1987	MIXTURES OF SOLID AND HAZARDOUS WASTES	Memo
	Description: A mixture of solid waste and waste listed solely for a characteristic (F003) is no longer listed hazardous waste if it does not exhibit characteristics. Such listed waste remains listed before mixing even if it exhibits no characteristics as generated (SEE ALSO: 268.3; 66 FR 27266; 5/16/01).
	01/27/1987	SOLVENTS USED AS COOLANTS AND APPLICABILITY OF SOLVENT LISTINGS	Memo
	Description: Spent coolant with 1,1,1,-trichloroethane (111-TCE) as an ingredient is not listed if it is not commingled with 111-TCE used in degreasing (F001). Coolant is only a hazardous waste if it is characteristic. Future changes to the toxicity characteristic might address TCE (SEE ALSO 55 FR 11862; 3/29/90).
	12/29/1986	ELECTRIC ARC FURNACE DUST AFTER ENCAPSULATION TREATMENT PROCESS	Memo
	Description: Bodner Metal and Iron’s electric arc furnace dust is K061 until it is delisted. Any waste for which delisting is sought must be evaluated for the originally listed constituents of concern and any Appendix VIII constituents reasonably expected to be present, as well as hazardous waste characteristics.
	12/22/1986	PROPOSAL OF UNREGULATED DIOXIN WASTES	Memo
	Description: Incineration is an appropriate management method for nonhazardous dioxin wastes (wastes that are not characteristic and are not covered by F-listings).
	12/12/1986	WASTE LISTINGS F006 AND K062, SCOPE OF	Memo
	Description: Includes a reinterpretation of the scope of the F006 listing. F006 includes only common and precious metals electroplating, anodizing, chemical etching and milling, and cleaning and stripping when associated with these processes. Chemical conversion coating (see F019), electroless plating, and printed circuit board manufacturing are not included in the F006 listing. Wastewater treatment sludges from circuit board manufacturing operations that include processes within the scope of the listing (e.g., chemical etching) are F006. Spent pickle liquor generated by a facility not in SIC codes 331 or 332 is not K062.
	12/11/1986	DRY CLEANING CARTRIDGE FILTERS, DISPOSAL OF	Memo
	Description: Valclene or trichlorotrifluoroethane that is used in dry cleaning operations is F002. SQGs generating certain spent solvents qualify for a two-year national capacity variance until 11/8/88. CESQGs are not subject to land disposal restrictions (LDR).
	12/11/1986	SPENT PICKLE LIQUOR FINAL RULE REGARDING SCOPE OF THE K062 LISTING, CORRECTION NOTICE	Memo
	Description: Discusses EPA’s rationale for modifying the spent pickle liquor (K062) listing (SEE ALSO 51 FR 19320; 5/28/86). EPA intends the listing to apply to spent pickle liquor from steel finishing operations from facilities within the iron and steel industry. EPA responds to the allegation that the Administrative Procedures Act was violated by modifying the scope of the listing.
	12/10/1986	LABORATORY WASTES (INCLUDING CARCASSES, BEDDING, CAGES) CONTAINING DIOXIN	Memo
	Description: Lab wastes (carcasses, cages, bedding, and dry wastes) generated by an analyst performing research involving 2,3,7,8-tetrachlorodibenzo- p-dioxin (TCDD) may be infectious wastes under 241.101(h), but not are not listed dioxin wastes F020-F023, F026, or F027. EPA has not yet promulgated criteria for identifying infectious wastes under Part 261 Subpart C.
	12/05/1986	SOLVENTS USED AS REACTANT AND SOLVENT WASTES GENERATED BY A PRODUCTION PROCESS	Memo
	Description: Process waste containing xylene used as a reactant in the formulation of sodium xylenesulfonate CCP is not F003. Still bottoms from the distillation of excess reactant xylene are not F003. Spent xylene and still bottoms from xylene recovery are not U239. Characteristic still bottoms are not subject to the F001-F005 treatment standards promulgated in the solvents and dioxins rule (51 FR 40638; 11/7/86).
	12/05/1986	SOLVENTS USED AS REACTANT NOT LISTED AS SPENT SOLVENT OR COMMERCIAL CHEMICAL PRODUCT	Memo
	Description: Process waste containing xylene used as a reactant in the formulation of sodium xylenesulfonate CCP is not F003. Still bottoms from the distillation of excess reactant xylene are not F003. Spent xylene and still bottoms from xylene recovery are not U239.
	11/24/1986	REGULATORY STATUS OF ELECTROPLATING RINSEWATER CONTAINING CYANIDES	Memo
	Description: Discussion of F006 listing for rinsewater treatment sludge. Electroplating rinsewater is not listed. Cyanide plating and stripping solution carryover to rinsewater in a process does not make the rinsewater F007 or F009 via the mixture rule. Spent rinsewater and listed spent bath mixed after removal from plating process is listed (SEE ALSO: RPC# 7/12/94-01; RPC# 7/28/87-02; RPC# 4/7/88-01).
	11/07/1986	SOLVENT LISTINGS, SCOPE OF	Memo
	Description: Solvent waste from painting is not F-listed if the solvent is an ingredient in the paint. Solvent used to strip paint can be F-listed because it is used as solvent (i.e. to dissolve or solubilize paint constituents).
	11/07/1986	SOLVENT LISTINGS, SCOPE OF	Memo
	Description: The F001-F005 listings do not cover wastes where solvents were used as reactants or ingredients in the formulation of CCPs, but do cover solvents used for their solvent properties. If a solvent is less than 10% by volume F001, F002, F004, or F005 constituents before use, the waste does not meet the spent solvent listing (SEE ALSO: F003; 50 FR 53315; 12/31/85). Mixtures of F001-F005 and wastewaters are typically listed via the mixture rule. Solvent- contaminated process wastes are generally not listed because the solvent contaminants were not used for their solvent properties. Discussion of the mixture rule exemption for solvent- wastewater mixtures.
	10/22/1986	INCINERTION OF LABORATORY WASTES CONTAMINATED WITH TCDD	Memo
	Description: Lab wastes such as paper towels, pipets, and laboratory gloves, that have come into contact with TCDD laboratory standards are not covered by the dioxin listings, F020-F023, F026-F028. Incineration may be a reasonable method of disposal for these wastes.
	10/21/1986	REGULATORY STATUS OF USED WOOD PRESERVATION CONTAINING PENTACHLOROPHENOL (PCP)	Memo
	Description: A mixture of unused pentachlorophenol (PCP) formulation (F027) and used PCP formulation that is spilled, disposed, or intended for disposal, is F027 via the mixture rule. As F027 does not include used PCP formulations, it is only hazardous waste if mixed with a listed or characteristic waste.
	10/21/1986	WASTES COVERED UNDER THE DIOXIN LISTING	Memo
	Description: Discussion of the applicability of F020 and F023 listings to wastes from the production of 2,4,5-trichlorophenol (TCP) and hexachlorophene. Wastewaters from 2,4,5-TCP process are not F020 or F023, but sludges from their treatment meet the listings. Clarification of highly purified 2,4,5-trichlorophenol. F020 and F023 wastes are regulated as acutely hazardous.
	10/12/1986	HAZARDOUS WASTE LISTING FOR F006 WASTE	Memo
	Description: The F006 listing does not cover chemical conversion coating, electroless plating, or printed circuit board manufacturing (unless the circuit board operation involves a F006-covered process, such as chemical etching). Chemical conversion coating includes chromating, phosphating, immersion plating, and coloring. The F006 listing covers sludges from anodizing and etching processes. Facilities that handle only wastes from excluded processes have never managed a hazardous waste, do not need a permit or interim status, are not subject to corrective action, and are not subject to closure. A F006 delisting petition is unnecessary for sludges from excluded processes.
	10/04/1986	REINTERPRETATION NARROWING THE SCOPE OF THE F006 LISTING	Memo
	Description: A reinterpretation of the scope of the F006 listings. F006 includes only common and precious metals electroplating, anodizing, chemical etching and milling, and cleaning and stripping when associated with these processes. Chemical conversion coating (see F019), electroless plating, and printed circuit board manufacturing are not included in the F006 listing. Wastewater treatment sludges from circuit board manufacturing operations that include processes within the scope of the listing (e.g., chemical etching) are F006.
	09/25/1986	REINTERPRETATION OF THE F006 LISTING	Memo
	Description: A reinterpretation of the scope of the F006 listings. F006 includes only common and precious metals electroplating, anodizing, chemical etching and milling, and cleaning and stripping when associated with these processes. Chemical conversion coating (see F019), electroless plating, and printed circuit board manufacturing are not included in the F006 listing. Wastewater treatment sludges from circuit board manufacturing operations that include processes within the scope of the listing (e.g., chemical etching) are F006.
	09/15/1986	DEFINITION OF SOLID WASTE	Memo
	Description: Ignitable discarded paint with xylene is D001 as the xylene is not spent F003, nor a discarded unused CCP (U239). A mixture of waste listed solely for a characteristic with a solid waste is not hazardous waste if the mixture is not characteristic (SEE ALSO: 268.3; 66 FR 27266; 5/16/01). Spent toluene is F005, not F002. A pyridine osmium tetroxide mixture is not P- or U-listed because the mixture is not a pure or technical grade of the chemical or a sole active ingredient.
	09/12/1986	WOOD TREATMENT CYLINDER CREOSOTE SUMPS	Memo
	Description: A sump collecting nonhazardous creosote from drips, leaks, or spills from wood treatment operations may be considered a solid waste management unit (SWMU) (SEE ALSO: 55 FR 50450; 12/6/90, F034 listing in 261.31, 264 Subpart W, 265 Subpart W, and 55 FR 30798; 7/27/90).
	09/12/1986	WOOD TREATMENT CYLINDER CREOSOTE SUMPS	Memo
	Description: A sump used to collect creosote drippage, leakage, or other spillage from wood treatment is solid waste management unit (SWMU), and potentially subject to corrective action (even if waste in the sump is not hazardous).
	09/11/1986	COMMERCIAL FERTILIZER THAT CONTAINS K061 WASTE	Memo
	Description: A zinc micronutrient fertilizer containing electric arc furnace dust (K061) is exempt from regulation if it is produced for the general public's use and handling is commensurate with zinc fertilizer management. A discussion of the definition of zinc micronutrient fertilizer.
	09/11/1986	COMMERCIAL FERTILIZERS CONTAINING K061 WASTES	Memo
	Description: Zinc micronutrient fertilizer containing electric arc furnace dust (K061) is exempt from regulation if it is produced for the general public's use and handling is commensurate with zinc fertilizer management. Discussion of the definition of zinc micronutrient fertilizer.
	08/21/1986	EXEMPTION FOR COMMERCIAL FERTILIZERS ONCE THE FERTILIZER IS PRODUCED	Memo
	Description: K061 as fertilizer is use in manner constituting disposal. Fertilizer production waste is K061 via the derived-from rule. Once K061-derived zinc fertilizer is produced for general public use, it is exempt. Fertilizer should be handled as a comparable fertilizer product. Zinc fertilizer made with HW is not commercial fertilizer until it is reacted with sulfuric acid, granulated, and sized.
	08/21/1986	RELISTING HAZARDOUS WASTE	Memo
	Description: EPA intends to redefine hazardous waste listings by.
	08/18/1986	LABORATORY WASTE GENERATED IN RESEARCH USING TCDD STOCK SOLUTIONS	Memo
	Description: Lab wastes, including animal carcasses, bedding, feces, urine, paper, gloves, syringes, etc., generated by an analyst performing research using stock solutions of tetrachlorodibenzo-p-dioxin (TCDD) are infectious wastes per Part 241, but are not covered by the listings for F020-F023, F026, or F027.
	08/04/1986	PRE-COAT WASTE CONTAINING 2-ETHOXYETHANOL (EXTRUDING PROCESS WASTE)	Memo
	Description: Using solvents as reactants or ingredients in products is not solvent use. Wastes from processes where solvents were used as reactants are not F-listed. Waste from process where 2-ethoxyethanol was used as ingredient in pre-coating cannot be F-listed solvent waste, although it may exhibit a characteristic.
	07/09/1986	CHARACTERISTIC HAZARDOUS WASTES GENERATED AT PRIMARY METAL SMELTING AND REFINING SITES	Memo
	Description: Data on the hazardousness of wastes generated at primary metal smelting and refining sites.
	07/02/1986	WASTES GENERATED IN A PROCESS USING METHYLENE CHLORIDE TO RECOVER ALKALOIDS FROM PLANT MATTER; WASTES GENERATED FROM EXTRACTION PROCESS	Memo
	Description: A filter cake from an extraction process with listed methylene chloride is not listed, but may be hazardous if characteristic. Wastewater stripped from solvent wastewater is not listed, but may be hazardous if characteristic. Spent solvent from an extractor is listed hazardous waste.
	06/24/1986	MECHANICAL PLATING WASTES IN THE F006 LISTING, NON-INCLUSION OF	Memo
	Description: A mechanical plating operation is not an electrolytic process and so wastewater treatment sludges from mechanical plating are not covered by the F006 listing.
	06/02/1986	PAINTING CONTRACTOR WASTES-SMALL QUANTITY GENERATOR	Memo
	Description: Methylene chloride is a listed waste (F002) when used as a solvent and can be toxic. Muriatic acid is likely to be corrosive (D002) but not toxic. Generators who produce greater than 100 kg/mo are subject to regulation. CESQGs may dispose of hazardous waste in any state approved landfill.
	06/01/1986	SPENT SOLVENT LISTINGS	Question & Answer
	Description: A solvent-containing effluent wastewater stream from a liquid-liquid extraction is not a spent solvent covered by the spent solvent listings, since the effluent became contaminated during the use of virgin solvent (production process).
	05/23/1986	LIME SLUDGE IMPOUNDMENT SLUDGE, DELISTING OF	Memo
	Description: A lime sludge surface impoundment containing K049 and K051 may be subject to permitting and closure requirements even if no waste management occurs based on a Regional interpretation.
	05/22/1986	SLUDGES GENERATED FROM THE FIRST CLEANING STAGES OF PHOSPHATING PROCESS	Memo
	Description: Wastewater treatment sludges from the initial cleaning steps in the electroplating process that are kept separate from wastes from subsequent portions of process may not carry the F006 listing (SEE ALSO: 51 FR 43350; 12/2/86).
	05/09/1986	HEALTH ASSESSMENT INFORMATION IN LISTING DECISIONS	Memo
	Description: EPA uses health assessment information such as the relative carcinogenic potencies, along with other evaluations of potential exposure and mismanagement, in deciding whether a waste is hazardous.
	05/02/1986	ACTIVATED CARBON CANISTERS USED TO COLLECT SOLVENT VAPORS GENERATED DURING PAINT APPLICATION	Memo
	Description: F-listings do not apply to solvents such as 1,1,1-trichloroethane, Freon 113, and methylene chloride that are used as ingredients or reactants in CCPs (e.g., paint). Activated carbon used to collect solvents volatilized during paint application would only be hazardous waste if characteristic. Solvent use includes use as a cleaning or degreasing agent, as a medium for chemical reactions, as extractants, and as diluents.
	05/02/1986	F006 AND F019 ELECTROPLATING LISTINGS	Memo
	Description: Electroplating operations producing F006-F009 include six processes, including chemical conversion coating (e.g., chromating) (SUPERSEDED: see 51 FR 43350; 12/2/86). For F006, “zinc plating (segregated basis) on carbon steel...” means a non-cyanide zinc plating process. Phosphating on aluminum is covered by F019, not F006.
	05/01/1986	SPENT SOLVENTS	Question & Answer
	Description: Clumps of varnish removed from spent methylene chloride that are used as a stripper meet the F002 listing due to the derived-from rule. Methylene chloride is no longer F002 once it has been reclaimed (after varnish clumps have been removed).
	04/09/1986	WASTEWATER TREATMENT SLUDGE EXEMPTION FOR ANODIZING OF ALUMINUM	Memo
	Description: The sulfuric acid anodizing of aluminum includes coloring and sealing of unsealed anodic coatings. A summary of coloring by dyes, sealing in hot nickel/cobalt acetate solutions. Processes not developed at the time of the exclusion still may be excluded. A discussion of electroplating operations developed after the listing are included in the listing.
	04/07/1986	ENVIRONMENTAL RELEASES FROM WOOD PRESERVING PLANTS	Memo
	Description: A summary of EPA regulations applicable to releases from wood preserving facilities. The wood preserving process wastewater effluent is subject to the CWA (SEE ALSO: 261.4(a)(9)). The storage or mixing tanks, kraft bags can be empty containers under section 261.7. Discusses the applicability of the F020, F021, F026, F027 listings. Dioxin wastes are acutely hazardous and are subject to the 1 kg threshold. Wastewater treatment sludges from creosote and pentachlorophenol (PCP) are K001. An explanation of the closure of units used to treat these process wastewaters. The applicability of the EP (extraction procedure) toxicity characteristic (SUPERSEDED: see 261.24) to wood preserving wastes. A discussion of section 3004(u) and (v) corrective action at wood preserving facilities.
	04/07/1986	WOOD PRESERVING AND SURFACE PROTECTION FACILITIES, CONTROLLING ENVIRONMENTAL RELEASES FROM	Memo
	Description: A summary of EPA regulations applicable to releases from wood preserving facilities. The wood preserving process wastewater effluent is subject to the CWA (SEE ALSO: 261.4(a)(9)). The storage or mixing tanks, kraft bags can be empty containers under section 261.7. Discusses the applicability of the F020, F021, F026, F027 listings. Dioxin wastes are acutely hazardous and are subject to the 1 kg threshold. Wastewater treatment sludges from creosote and pentachlorophenol (PCP) are K001. An explanation of the closure of units used to treat these process wastewaters. The applicability of the EP (extraction procedure) toxicity characteristic (SUPERSEDED: see 261.24) to wood preserving wastes. A discussion of section 3004(u) and (v) corrective action at wood preserving facilities.
	03/24/1986	SOLVENT MIXTURES, FINAL RULE TO LIST - PERMIT MODIFICATIONS	Memo
	Description: Facilities permitted to manage F001-F005 waste codes before 12/31/85, may handle newly listed solvent wastes without a major permit modifications.
	03/20/1986	DETERMINATION OF THE PRESENCE OF WASTEWATER TREATMENT SLUDGES AND/OR THE PRESENCE OF WASTEWATER	Memo
	Description: Wastewater management generates a wastewater treatment sludge. To prove wastewater management has created a sludge, one need only show that the the unit or soil after contact with wastewater is physically or chemically different from the virgin unit or soil. Even when fully treated, industrial wastewater remains a wastewater for listings. Management of electroplating or wood preserving wastewater at any point in the wastewater treatment train creates an F006 or K001 sludge, regardless of the actual sludge contaminants or concentrations. Discussion of the delisting option.
	03/03/1986	SPENT CARBON USED TO REMOVE DISSOLVED PENTACHLOROPHENOL (PCP) FROM GROUNDWATER	Memo
	Description: Spent carbon used to treat groundwater contaminated by product pentachlorophenol (PCP) spill is acute hazardous waste F027. Under other circumstances, carbon is not regulated (SEE ALSO: 261.24 and 261.31: F032).
	02/12/1986	UNRINSED CONTAINERS WHICH FORMERLY CONTAINED AN UNUSED FORMULATION OF PENTACHLOROPHENOL	Memo
	Description: Discussion of the treatment, storage, and disposal options for dioxin wastes. An unrinsed container which contained unused pentachlorophenol (PCP) is F027 subject to all regulations applicable to acute hazardous waste (HW). Residues from the incineration of an acute HW remain acutely hazardous (SUPERSEDED: See F028 listing in 261.31). Incinerators burning dioxin wastes must meet 99.9999% Destruction and Removal Efficiency (DRE).
	02/11/1986	WOOD TREATED WITH CREOSOTE, DISPOSAL OF	Memo
	Description: Creosote-treated wood is unlikely to be a HW. It is not listed (K001, K035) and it is unlikely to be characteristic. The FIFRA regulations prohibit burning of creosote-treated wood.
	02/01/1986	LAND DISPOSAL BAN OF SOLVENTS	Question & Answer
	Description: New solvent wastes listed by 12/31/85 Federal Register (50 FR 53315) are subject to the land disposal restrictions (LDR) under authority of 3004(g)(4).
	01/27/1986	PRIMARY AND SECONDARY PRODUCTION OF STEEL IN ELECTRIC ARC FURNACES	Memo
	Description: Discussion of the distinction between primary and secondary production of steel in electric arc furnaces for purposes of K061 listing. Dusts and sludges from the primary production of steel in an electric arc furnace are K061. K061 does not apply to similar wastes from foundry use of an electric arc furnace in secondary steel production.
	01/07/1986	EXCLUSION FROM REGULATION FOR CHARACTERISTIC AND LISTED WASTES - LEACHATE LEVELS; DELISTING CRITERIA/LEACHATE LEVELS	Memo
	Description: There is delisting criteria for variable constituent levels depending on waste volume. For delisting, EPA considers the original listing constituents and other factors. A mixture of solid waste (SW) and hazardous waste (HW) listed solely for a characteristic is not HW if not characteristic under the 261.3(a)(2)(iii) mixture rule exemption for wastes listed solely for exhibiting a characteristic (SEE ALSO: 268.3; 66 FR 27266; 5/16/01). The leachate test used depends on the nature of the waste. Discussion of the use of extraction procedure (EP) for Oily Waste (SUPERSEDED: See 261.24).
	01/01/1986	SPENT SOLVENT MIXTURES	Question & Answer
	Description: Discusses the applicability of F003 to solvent mixtures. The 10 percent threshold does not apply to F003. Solvent mixture must contain only F003 listed solvents to meet the F003 listing (SEE ALSO: 66 FR 27266; 5/16/01) or contain solvent from F003 and meet the 10% threshold for F001, F002, F004, or F005 (SEE ALSO: RPC# 6/1/94-01).
	11/14/1985	SPENT SULFURIC ACID PICKLE LIQUOR USED TO PRODUCE FERTILIZER	Memo
	Description: Waste pickle liquor from steel finishing (K062) is a spent material. K062 used as an ingredient in a fertilizer is use constituting disposal, and is a solid waste and hazardous waste. Fertilizer product is derived from K062 and regulated under Part 266, Subpart C. If produced for the general public use, the product is exempt (SUPERSEDED: see 266.20(b)). K062 is not eligible for a delisting if it is characteristic. Petitioners have the option of withdrawing a petition rather than having EPA publish a denial in the Federal Register.
	10/15/1985	HEAT TREATING OPERATIONS AND THE F006 LISTING	Memo
	Description: Heat treating is not within the scope of the electroplating operations for F006 (SEE: F010-F012). When parts (dies) are removed from salt bath and rinsed, salt bath residues that carry over (carryover) from the part to the rinsewater are not F011 and do not render rinsewater listed via mixture rule (SEE ALSO: RPC# 7/12/94-01; RPC# 7/28/87-02; RPC# 4/7/88-01; RPC# 11/24/86-02).
	10/03/1985	PICKLE LIQUOR AND SCOPE OF K062 LISTING	Memo
	Description: Spent pickle liquor from any source, including hot dip galvanizing, is K062 (SUPERSEDED: SEE 51 FR 19320; 5/28/86). Hot dip galvanizing is excluded from the electroplating definition. The time for processing a delisting petition is directly dependent upon EPA receiving a complete application.
	09/26/1985	CHLORINATED DIOXIN WASTES (F023)	Memo
	Description: Mixing and formulating tank wastes generated in tanks that were used in the past to manufacture chemicals derived from 2, 4, 5-trichlorophenol meet the F023 listing. If the company replaces mixing tanks, any subsequent waste generated would not be F023, or, the company could submit a delisting petition showing dioxins and furans are below levels of concern.
	09/18/1985	WATER/METHANOL MIXTURE WASTESTREAM	Memo
	Description: A mixture of F003 and wastewater is exempt if mixture is not ignitable. Another option for exemption is to discharge to a sewer. RCRA 3005(h) requires a waste minimization plan (SUPERSEDED: see current 261.3(a)(2)(iii), 268.3).
	09/03/1985	WASTEWATER TREATMENT SLUDGES FROM ELECTROPLATING OPERATIONS	Memo
	Description: Electroplating is defined as the application of a surface coating, usually, but not always, by electrodeposition to provide corrosion protection, erosion resistance, anti-frictional characteristics, or decoration. Phosphate conversion coating (process triggering F019) involves producing insoluble crystalline phosphate on surface of metal to provide base for lubricants. Iron/manganese/phosphate process is an electroplating operation. Sludges from associated rinsewater treatment meet the F006 listing (SUPERSEDED: See 51 FR 43350; 12/2/86).
	08/23/1985	PETROLEUM REFINERY WW, MIXTURE AND DERIVED-FROM RULES	Memo
	Description: The mixture rule applies to a mixture in a wastewater treatment system of a wastewater and derived-from listed hazardous waste (HW). Dewatering supernatant from listed petroleum wastewater treatment sludge may not be a derived-from HW if it is chemically equivalent to influent refinery wastewater where the sludge is initially generated (SEE ALSO: RPC# 3/5/93-02). Discussion of the point of generation for K048-K052.
	07/23/1985	CLASSIFICATION OF REGULATIONS APPLICABLE TO DIOXIN AND FURAN CONTAMINATED LABORATORY WASTES	Memo
	Description: The presence of dioxin in lab wastes (stock solutions, clean up materials, chromatographic columns) does not make wastes F-listed for dioxin. However, unused hazardous waste samples or residues from their analysis are still hazardous waste.
	07/17/1985	SURFACE IMPOUNDMENTS/LAND TREATMENT UNITS REGULATION IF ASSOCIATED WWT SLUDGES ARE LISTED	Memo
	Description: Since any pollution abatement technique such as land treatment, disposal, or storage of a wastewater will invariably form a sludge, F-listed, K-listed, and characteristic sludges can be formed in situations where wastewaters are stored or disposed (i.e., not specifically treated). Discussion of the point of generation.
	07/16/1985	CREOSOTE TREATED CROSS TIES, DISPOSAL OF, FIFRA INTERFACE	Memo
	Description: Creosote-treated railroad cross ties are not likely characteristic. FIFRA may place controls on their handling and disposal. U051 creosote and K001 and K035 do not apply to treated cross ties destined for disposal.
	07/16/1985	SPENT PICKLE LIQUOR USED IN PRODUCTION OF FERRIC CHLORIDE	Memo
	Description: Spent pickle liquor (K062) is a spent material and a solid waste (SW) when reclaimed. Discussion of ferrous chloride recovery from K062 reclamation. Beneficial reuse of waste after reclamation does not affect SW status before and during reclamation. The use of K062 in ferric chloride production is not exempt use or reuse.
	07/01/1985	K051 AND HSWA; K051 SLUDGE RE-USED ON-SITE, EXEMPTION	Question & Answer
	Description: Petroleum coke produced from on-site reuse of K051 is exempt from standards for hazardous waste fuel unless coke product exhibits characteristic per section 3004(q)(2)(A) (SEE ALSO: Section 261.4(a)(12)).
	07/01/1985	THE SOLVENT MIXTURE RULE	Question & Answer
	Description: The phrase “ten percent (or more) by volume” means the sum of percentages of each listed solvent constituent present. A single solvent need not be present at a concentration of ten percent. A discussion of a proposed solvent rule (50 FR 18378; 4/30/85) which changed the scope of the spent solvent listing and solvent percentage rule.
	06/24/1985	SPENT SOLVENT MIXTURE (NALCAST 6015/WATER/WAX)	Memo
	Description: Solvent mixture (Nalcast 6015) used to clean wax from metal parts is used as a solvent, and is spent when it has served its intended purpose and can no longer be used without further processing. Spent solvent listings apply only to the technical grade or pure forms of a solvent, not to solvent mixtures (SUPERSEDED: SEE 261.31 and 50 FR 53315; 12/31/85). Water-wall spray booth residues are not hazardous unless they exhibit a characteristic.
	06/19/1985	SPENT ION EXCHANGE RESIN	Memo
	Description: Spent ion exchange resin generated during the removal of metal from electroplating rinse waters meets the F006 listing.
	06/17/1985	WOOD TREATMENT PLANT DRIP AREAS AS SWMUS, REGULATION OF	Memo
	Description: Ground areas at wood treatment plants receiving drippage from treated wood (kick-back) are solid waste management units (SWMUs) subject to corrective action (SEE ALSO: 55 FR 30798; 7/27/90 and current 261.31).
	06/03/1985	TOLUENE-LADEN FILTER RESIDUE GENERATED FROM AN INK PRODUCTION PROCESS	Memo
	Description: Filter cake containing toluene residue as a contaminant is not F005, since solvent listings do not apply to wastes containing solvents that were used in industrial processes. Solvents used for solvent properties are typically not consumed or physically or chemically altered during the process. The treatment of a residue on site to decrease the solvent content may require a permit unless it is conducted in a generator accumulation unit.
	06/01/1985	SOLVENT MIXTURE	Question & Answer
	Description: The solvent mixture rule applies to a solvent mixture before it becomes a waste. If the mixture meets the 10% criterion before use, the waste meets the applicable solvent listing regardless of the percentage of solvent in the waste.
	05/31/1985	F019 LISTING FOR WWT SLUDGES IN ALUMINUM ANODIZING	Memo
	Description: Wastewater treatment sludges from chemical conversion coating are either F006 or F019. F019 wastes are a subset of F006 wastes (SUPERSEDED: See 51 FR 43350; 12/2/86).
	05/24/1985	CLARIFICATION ON THE USE OF SOLVENTS AS REACTANTS IN MANUFACTURING PROCESSES	Memo
	Description: The use of solvents as reactants (chemical feedstocks in manufacturing process) or process intermediates is not a solvent use. Excess toluene, methanol, and m-cresol used as reactants are not F-listed. Solvents used as reaction or synthesis media (i.e., to dissolve chemicals to enhance their ability to undergo a chemical reaction) is a solvent use.
	05/14/1985	APPLICABILITY OF K021 LISTING	Memo
	Description: K021 (aqueous spent antimony catalyst waste from fluoromethanes production) applies to aqueous waste contaminated with spent catalyst and organics from reactor purging, not to the spent catalyst (reactor purge stream) before it is filtered, washed, and oxidized.
	05/13/1985	ZINC PHOSPHATING ON CARBON STEEL AND THE F006 LISTING	Memo
	Description: Phosphating (chemical conversion coating) on carbon steel is an electroplating operation and associated wastewater treatment sludges could be F006 (SUPERSEDED: See 51 FR 43350; 12/2/86).
	04/17/1985	WASTES FROM ALKALINE SURFACE CLEANING AND THE F006 LISTING	Memo
	Description: Electroplating operations include six process categories (SUPERSEDED: See 51 FR 43350; 12/2/86). The cleaning step before electroplating using alkaline (basic) rather than acidic cleaning solutions is considered an electroplating operation. Variations in composition of F006 sludges are expected. Even if a sludge is not characteristic, it can be regulated as F006 until it is delisted.
	04/10/1985	APPLICABILITY OF F006 V. K062 TO GALVANIZING WASTES	Memo
	Description: Hot dip galvanizing is zinc plating on carbon steel and associated wastewater treatment sludges are excluded from F006. For F006, segregated basis means no cyanides were used in the process. Lime-stabilized waste pickle liquor sludge from steel finishing is not K062 unless it is characteristic.
	04/05/1985	SOIL CONTAMINATED WITH TOLUENE	Memo
	Description: Soil contaminated with toluene is not automatically considered to be a hazardous waste because toluene is listed in Appendix VIII of Part 261. The soil would be hazardous under the contained-in policy if toluene-containing waste from section 261.31, 261.32, or 261.33 were spilled. Soil may be hazardous if it exhibits a characteristic.
	04/02/1985	APPLICABILITY OF ELECTROPLATING LISTINGS TO WASTES FROM PHOSPHATING PROCESSES	Memo
	Description: Phosphating and chemical conversion coating are electroplating operations and associated wastewater treatment sludges can be F006 (SUPERSEDED: See 51 FR 43350; 12/2/86).
	04/01/1985	F SOLVENT WASTES	Memo
	Description: The F solvent listings apply only to solvents designated in the “F” series. Only solvents used separately are covered by F001-F005 (i.e., technical grade solvents are covered but solvent mixtures are not) (SUPERSEDED: SEE 261.31 and 50 FR 53315; 12/31/85). If individually used solvent waste streams are mixed after generation, the mixture is a mixture of F-listed waste streams.
	04/01/1985	HAZARDOUS WASTE DETERMINATION	Question & Answer
	Description: The use as a reaction medium is considered use as a solvent. Methylene chloride used as a reaction medium meets the F002 listing. Spent materials are solid wastes when reclaimed. The recycling process is exempt.
	03/29/1985	IMPLEMENTATION OF DIOXIN LISTING REGULATION	Memo
	Description: Discussion of the compliance dates for notification and submittal of new and revised Part A permit applications for dioxin listings (F020-F023, F026-F028). Wastes from the production of chlorophenoxy acids, or their ester, ether, amine, or other salt derivatives are F020 (including 2,4,5-T). F023 processes are thesame as F020. F020-F023, F026 do not cover wastewaters but cover sludges from their treatment. Packaging is not part of the formulating process.
	03/12/1985	EXCLUSION FROM RCRA PERMITTING REQUIREMENTS FOR LESS THAN 90-DAY ACCUMULATORS OF DIOXIN CONTAINING WASTES	Memo
	Description: Generators may accumulate dioxin hazardous waste on-site for 90 days without permit or interim status. Accumulation rules apply whether or not a permit is needed for the rest of the facility. Dioxin-contaminated wastes from labs/laboratories (clothing, glass) are not listed dioxin wastes. Unused samples of these wastes carry the listing.
	03/04/1985	DIOXIN IN WASTES FROM WOOD PRESERVING PROCESSES USING PENTACHLOROPHENOL	Memo
	Description: F-listed dioxin wastes are rarely generated at wood preserving facilities, although if wood preserving facility makes chlorophenolic formulations or discards unused chlorophenolic formulations, they would generate F-listed dioxin wastes. EPA may amend K001 to address chlorinated dioxins and furans (see also: 261.31: F032-F035). F021 and F027 are listed for acute toxicity (H), while F028 is listed as a toxic waste (T).
	02/22/1985	SECONDARY SLUDGES FROM BIOLOGICAL TREATMENT OF REFINERY WASTEWATERS	Memo
	Description: K048 does not apply to sludge generated by a dissolved air flotation (DAF) device used in secondary (biological) wastewater treatment systems.
	02/13/1985	DIOXIN STANDARD USED TO TEST GAS CHROMATOGRAPHY COLUMNS, HANDLING OF	Memo
	Description: Wastes and contaminated equipment from the use of dioxins as lab standards (and most other lab wastes) do not meet the listing description for dioxin-bearing F020, F021, F022, F023, F026, F028 as they do not result from any of the manufacturing processes specified in the listings.
	02/07/1985	POLICY ON DISPOSAL OF DIOXIN-CONTAMINATED WASTES	Memo
	Description: Discussion of management practices and a summary of TSCA regulations for the handling of dioxin-bearing wastes prior to the creation of hazardous waste listings for dioxins.
	01/18/1985	ACCEPTABLE LEVELS OF RESIDUAL CONTAMINANTS IN THE EPA INCINERATOR RESIDUES	Memo
	Description: Provides conservative concentration-based levels for 20 toxic constituents beneath which dioxin-bearing ash would not present substantial hazard to human health or the environment when managed at nonhazardous waste facilities. Discussion of necessary delisting for incinerator trial burn dioxin residues (SEE ALSO: F020-F023, F026-F028) (SEE ALSO: RPC# 4/1/85-08).
	01/18/1985	K001-LISTED WASTES FROM WOOD PRESERVING PROCESSES	Memo
	Description: EPA is aware of no single analytical method with which to determine the presence of creosote. U051 applies to raw creosote that is discarded. K001 applies to wastes from wood preserving processes that use creosote and/or pentachlorophenol (PCP).
	12/26/1984	CONTAMINATED GROUNDWATER, RCRA REGULATORY STATUS	Memo
	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.
	12/11/1984	ELECTROPLATING SLUDGE, EXCLUSION PETITION	Memo
	Description: For delistings of an electroplating sludge, total, free (amenable to chlorination), leachable, and photodegradable cyanides must be analyzed. Total and free cyanides are analyzed using Method 9010. Leachable cyanides are analyzed using the extraction procedure (EP) toxicity test (SUPERSEDED: See 261.24). Photodegradable cyanides are analyzed using Method 9011.
	12/07/1984	OILY WASTEWATER TREATMENT PONDS, PERMITTING COVERAGE OF	Memo
	Description: The regulatory status of and options for permitting and managing oily sludges generated in refinery wastewater treatment ponds and surface impoundments is discussed (SUPERSEDED: see 261.31, F037 and F038 listings).
	12/07/1984	OIL/WATER EMULSIONS GENERATED BY PETROLEUM REFINERY WW SYSTEMS-K049 WASTE	Memo
	Description: Slop oil emulsion solids (K049) are generated in the first vessel where the emulsion stratifies. Oil reclaimed in slop oil/oil recovery systems is not a hazardous waste (SEE ALSO: 261.4(a)(12)). Emulsion breaking in surface impoundments/earthen devices is considered storage. Non-reclaimed emulsion is a hazardous waste even if it is reclaimable. Storage not directly related to the reclamation process needs a permit.
	11/23/1984	WASTE INK AND SOLVENT MIXTURES GENERATED FROM PRINTING FACILITIES	Memo
	Description: Waste solvent-containing inks are not listed spent solvents. These wastes may exhibit the ignitability characteristic (D001).
	11/01/1984	VERTAC RULE	Question & Answer
	Description: The Vertac rule, promulgated under Part 755 of TSCA, in part, requires notification by persons who manage wastes containing detectable concentrations of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) (SUPERSEDED: see 50 FR 2006; 1/14/85, and 261.31).
	10/25/1984	SPENT PICKLE LIQUOR SLUDGE, LIME-STABILIZED, IN IRON AND STEEL AND PORCELAIN ENAMELING INDUSTRIES	Memo
	Description: The K062 listing applies to spent pickle liquor from all steel finishing industries, regardless of industry category (SUPERSEDED: see 261.32, and 51 FR 19320; 5/28/86). Promulgation of the exclusion from the derived-from rule for lime-stabilized waste pickle liquor sludge renders certain delisting petitions moot. Since the derived-from exclusion for lime-stabilized pickle liquor sludge applies only to the sludge, the supernatant retains the K062 listing.
	10/23/1984	SPENT PICKLE LIQUOR GENERATED FROM PORCELAIN ENAMEL INDUSTRY, DELISTING OF	Memo
	Description: Spent pickle liquor and sludge generated from treatment are K062. A delisting petition is necessary to change the status of such hazardous waste and the status of electroplating F006-F009 wastes at the same facilities.
	09/24/1984	ZINC PLATING, WASTEWATER TREATMENT SLUDGES GENERATED FROM	Memo
	Description: Zinc plating on carbon steel is exempt only when segregated from other hazardous waste streams. Chemical conversion coating (CCC) is an electroplating operation (SUPERSEDED: see 51 FR 43351; 12/2/86). Zinc plating wastewaters mixed with CCC wastewaters are not excluded from the F006 listing.
	09/06/1984	DELISTING OF WASTE GENERATED FROM ZINC PHOSPHATING ON CARBON STEEL	Memo
	Description: Phosphating is electroplating. Zinc phosphating on carbon steel is not F006 (SUPERSEDED: phosphating is chemical conversion coating no longer electroplating, see 51 FR 43351; 12/2/86).
	09/01/1984	PRECIOUS METAL ELECTROPLATING SLUDGE	Question & Answer
	Description: Sludge from precious metal electroplating is not F008 (SUPERSEDED: see 261.31, 50 FR 614; 1/4/85).
	09/01/1984	WASTEWATER FROM WOOD PRESERVING	Question & Answer
	Description: The K001 listing does not cover wastewater from wood preserving processes that use creosote and/or pentachlorophenol (PCP) (SEE ALSO: F032, F034).
	08/01/1984	BAGHOUSE DUST GENERATED FROM REMELTING PRIMARY PRODUCED STEEL	Question & Answer
	Description: Baghouse dust from remelting steel is K061. Remelting is considered primary production.
	08/01/1984	METHYL CHLOROFORM	Question & Answer
	Description: Off-specification methyl chloroform produced from the reclamation of listed solvent (F002) is considered an off-specification CCP when discarded and meets the U226 listing.
	07/30/1984	DRAGOUT FROM F007 - SPENT CYANIDE PLATING BATH SOLUTIONS	Memo
	Description: Chlorination tank bath solutions and sludges contaminated with plating bath dragout (carryover) are F007. The sludge may be F006 if wastewaters from an electroplating operation enter the chlorination tank (SEE ALSO: RPC# 7/12/94-01; RPC# 4/7/88-01; RPC# 11/24/86-02).
	07/30/1984	SPENT ACID FROM ELECTROPOLISHING OF STAINLESS STEEL	Memo
	Description: Electropolishing is a process which utilizes acids to impart a shiny finish to stainless steel. All spent acids from electropolishing are K062 spent pickle liquor. The K062 listing includes all spent acids used in the pickling and/or cleaning of steel.
	07/27/1984	K062 - SPENT PICKLE LIQUOR LISTING	Memo
	Description: Steel finishing operations for purposes of the K062 listing is clarified. K062 is not limited to the iron and steel industry. Sludge from the treatment of pickling acid-containing wastewater is F006 if it is from an electroplating operation, or it is K062 if it is not or separate from an electroplating operation. K062 covers all acids for pickling steel.
	07/25/1984	WASTEWATER TREATMENT EFFLUENT FROM PROCESSES THAT GENERATE K001 AND F006 WASTEWATER TREATMENT SLUDGE	Memo
	Description: The F006 and K001 listings apply to sludge generated anywhere in the wastewater treatment process. Effluent from the wood preserving waste treatment train is not K001. The definition of a material leaving a sand filter is the same as the material entering the filter. Wastewater passing through a filter remains wastewater.
	06/13/1984	ZINC PLATING (SEGREGATED BASIS) ON CARBON STEEL	Memo
	Description: Chemical conversion coating includes phosphating, coloring, chromating, immersion plating, and chrome passivating. Zinc plating (segregated basis) wastewater treatment sludge is not listed (SEE ALSO: 51 FR 43350; 12/2/86 clarifying that chemical conversion coating CCC is not F006, but F019).
	06/01/1984	USE AS SOLVENT V. USE AS INGREDIENT	Question & Answer
	Description: Use as solvent versus use as an ingredient is discussed. Use in extraction or as a carrier is considered solvent use. Use as a reactant or as a chemical intermediate is considered use as an ingredient. Examples are provided.
	05/15/1984	RESIDUE FROM STREAM-STRIPPING OF PROCESS WASTE CONTAINING TOLUENE	Memo
	Description: Spent solvent listings apply only to pure or technical grade solvents (SUPERSEDED: see 261.31, F001-F005). Industrial process wastestreams containing solvent constituents are not listed; thus, wastes derived from these industrial process wastestreams are not listed.
	05/03/1984	EMISSION CONTROL DUST/SLUDGE FROM ELECTRIC ARC FURNACE AT FOUNDRY NOT A K061 WASTE	Memo
	Description: Emission control dust from foundries is not K061. Foundry emission control dust may still be characteristic.
	05/01/1984	API SEPARATOR SLUDGE, EXCLUSION OF WATER FRACTION FROM K051 LISTING	Question & Answer
	Description: The water fraction produced when separating water from API separator sludge is not K051.
	05/01/1984	DEFINITION OF ELECTROPLATING	Question & Answer
	Description: EPA’s definition of electroplating is discussed (SUPERSEDED: see 51 FR 43350; 12/2/86).
	05/01/1984	STORAGE OF WASTEWATER TREATMENT SLUDGE	Question & Answer
	Description: A facility placing F006 into a smelter for dewatering immediately upon receipt does not need storage permit to accept the waste. After dewatering, the material is no longer F006. Residues (fines) that are generated from smelting are F006.
	04/26/1984	WASTEWATER TREATMENT SLUDGES FROM WOOD PRESERVING PROCESSES USING CREOSOTE AND/OR PENTACHLOROPHENOL	Memo
	Description: Wood preserving oil/water separator sludges and thermal dehydrator sludges may be K001 if creosote and/or pentachlorophenol (PCP) was used. Storage/work tank sludges mixed with the above sludges are listed. Historic estimation rates of waste generation are provided.
	04/10/1984	MIXTURES OF SPENT SOLVENTS - F001-F005, REGULATORY STATUS OF	Memo
	Description: Spent solvent listings only apply to pure or technical grades of solvents. Mixtures of different solvents are hazardous only if they are characteristic (SUPERSEDED: see 261.33, F001-F005).
	04/01/1984	API SEPARATOR WASTEWATER AND SLUDGE	Question & Answer
	Description: Wastewater from an API separator is not hazardous if it is not characteristic. Sludge precipitated from this wastewater in a surface impoundment is K051. Solids from filtering such wastewater are K051. The definition of an API separation system is discussed.
	04/01/1984	CARBON FILTERS IN DRY CLEANING FOR FILTERING PERCHLOROETHYLENE	Question & Answer
	Description: Carbon filters used to filter spent perchloroethylene from the dry cleaning industry are F002. The weight of filters is counted toward the monthly generator determination.
	04/01/1984	EFFLUENT FROM API SEPARATOR	Question & Answer
	Description: Supernatant from an API separator is not K051. Separation is not mixing. EPA is reevaluating its policy on run-off from active portions of hazardous waste management units.
	03/05/1984	CYANIDE-SALT CONTAINING WASTES IN METAL HEAT TREATING OPERATIONS	Memo
	Description: Both complex and free cyanide forms are included in the metal heat-treating F010, F011, and F012 listings. Cyanide may change form during the process.
	03/01/1984	AMBIENT WATER QUALITY CRITERIA LEVELS (AWQCLS) FOR ALIPHATIC HYDROCARBON WASTE	Question & Answer
	Description: The Ambient Water Quality Criteria Levels (AWQCLs) mentioned in the F024 interim final rule (49 FR 5308; 2/10/84), which lists certain aliphatic hydrocarbon wastes, are addressed in the background document and also discussed in the 11/28/80 Federal Register (45 FR 79318).
	02/01/1984	WASTEWATER TREATMENT SLUDGE FROM ETCHING SEMICONDUCTOR SILICON WAFERS	Question & Answer
	Description: Wastewater treatment sludge from etching semiconductor silicon wafers is an F006 waste. Chemical etching is electroplating (SEE ALSO: 54 FR 43351;12/2/86).
	10/21/1983	LEACHATE FROM A MUNICIPAL LANDFILL, REGULATION OF	Memo
	Description: Leachate from municipal landfills must be handled as hazardous if it is characteristic. The landfill is the generator of the waste. Nonhazardous leachate can be recycled into the landfill. Hazardous leachate must go to a TSDF or POTW unless the landfill is an exempt small quantity generator (SUPERSEDED: for landfill leachate recirculation, see 258.28) (SEE ALSO: 261.31 (F039 listing), 261.5, 262.34).
	10/01/1983	WASTES LISTED FOR CONTAINING CHLORINATED BENZENES	Question & Answer
	Description: The F002 listing is just for monochlorinated benzene and o-dichlorobenzene. K105 includes wastes from the production of all chlorinated benzenes.
	07/20/1983	SOLAR CELL AND HIGH TECH INDUSTRIES HAZARDOUS WASTE	Memo
	Description: Wastes from the production of solar cells and other high tech industrial equipment, including spent solvents, electroplating wastes, and discarded products, may be hazardous waste if they are listed or characteristic. Not all wastes from such production are listed or characteristic.
	07/11/1983	K061, EMISSION CONTROL DUST/SLUDGE FROM PRODUCTION OF STEEL IN ELECTRIC FURNACES	Memo
	Description: The K061 listing applies to steel produced in electric furnaces, but does not include blast furnaces or foundries. Facilities using scrap metal as raw material are included, but the listing does not include iron making.
	06/10/1983	SPENT SOLVENT LISTINGS & LEACHATE FROM SANITARY LFS THAT RECEIVED HAZARDOUS WASTE	Memo
	Description: Spent 1,1,1-TCE from a cleaning process is F002. Process waste containing TCE is not listed unless it is mixed with listed solvent, although it may be characteristic. Sanitary landfill leachate containing listed solvent is listed HW.
	06/06/1981	K052 LISTING FOR WASTES GENERATED BY PETROLEUM INDUSTRY	Memo
	Description: The K052 listing is limited to only those leaded tank bottoms that are generated at or as part of a petroleum refinery. Provides definition of petroleum refinery. Only those tanks that are directly part of a refinery and generate leaded bottoms are listed.
	04/20/1981	REGULATION OF PAINT WASTE DISPOSAL	Memo
	Description: F017, F018, and K078-K082 listings for paint wastes are suspended (46 FR 4614; 1/16/81). Paint wastes are still subject to hazardous waste characteristics (SEE ALSO: K078-K082 paint wastes required to have listing decision by 9/30/88 pursuant to EDF v. Browner consent decree).
	12/02/1980	K061 HAZARDOUS WASTE LISTING FOR STEEL FOUNDRIES	Memo
	Description: K061 applies only to the primary production of steel, and not steel foundries.
	11/13/1980	REFINERY WASTEWATER	Memo
	Description: Non-listed refinery wastewater is hazardous waste if it is mixed with listed refinery waste (K048, K049, K051). The storage of K048 before recycling is regulated.
	01/10/1980	APPLICABILITY OF 40 CFR 261.5 TO K047	Memo
	Description: K047 (pink/red water from TNT operations) is listed for its potential to dewater over time and become reactive.
Jobs Through Recycling Program
K-wastes
Land Disposal Restrictions
Land Disposal Units
Land Treatment Units
Landfills
Large Quantity Generators (LQG)
Legislation (hazardous waste)
Liability (Hazardous Waste)
Listing Hazardous Waste
Manifest
Medical Waste
Mercury Wastes
Military Munitions
Mining Waste
Miscellaneous Units
Mixed Waste (radioactive waste)
Municipal Solid Waste
Native American - Tribes
Native Americans - Tribes
Natural Gas
Nonhazardous Waste
Oil
Oil Filters
P-wastes
PCBs
Permits and Permitting
Petitions
Petroleum Refining Wastes
Polychorinated Biphenyls (PCBs)
Post-closure (hazardous waste)
Procurement
Public Participation
Radioactive Mixed Waste
Reactive Wastes
Recycling
Reducing Waste
Siting (waste facilities)
Small Quantity Generators (SQG)
Solid Waste
Solvents
Source Reduction
Special Wastes
State Programs (RCRA)
Storage
Surface Impoundments
Tanks
Test Methods
Toxicity Characteristic
Transporters
Treatment
TSDFs
U-wastes
Underground Storage Tanks (UST)
Universal Waste
Used Oil
Variances
Waste Determinations for Combusted Non-Hazardous Secondary Materials
Waste Minimization
Waste Piles
Waste Reduction
Wood Preserving Wastes
(Not Categorized)

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