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02/12/2009Safe Chemical Management in Your School (Video)Publication
 Description: This video provides information to help schools and community partners develop a responsible chemical management program. This video features two case studies of schools that are addressing chemical management in their facilities.
 
11/01/2008Building Successful Programs to Address Chemical Risks in Schools: A Workbook with Templates, Tips, and Techniques Publication
 Description: This workbook provides advice and templates developed by successful Schools Chemical Cleanout Campaign (SC3) programs in various states, localities, and tribes that can be used to help schools design their own SC3 program. The tips, techniques, and templates in this workbook can be applied and adapted for SC3 programs being developed and operated at the school, school district, or state level.
 
11/01/2008SC3: Protecting Students and Staff with Green CleaningPublication
 Description: This fact sheet describes green cleaning, its benefits, and how schools can build a green cleaning program. EPA’s Schools Chemical Cleanout Campaign (SC3) is working to encourage schools to use green cleaning practices to safely clean their classrooms and grounds.
 
01/01/2007Building Successful Programs to Address Chemical Risks in Schools: State, Tribal, and Local School Chemical Cleanout Programs Matrix and SummariesPublication
 Description: This document is part of the Schools Chemical Cleanout Campaign (SC3), which promotes the removal of unneeded, excessive, or dangerously mismanaged chemicals from K-12 schools. It summarizes successful state, tribal, and local programs to address chemical risks in schools, and describes the regulations, training, compliance assistance, and other resources of each program.
 
01/01/2007Industry Leaders Are Part of the SolutionPublication
 Description: This document encourages industry leaders to participate in the Schools Chemical Cleanout Campaign (SC3), which promotes the removal of unneeded, excessive, or dangerously mismanaged chemicals from K-12 schools.
 
05/16/2002REGULATORY STATUS OF VANADIUM-CONTAINING WASTE (SPENT STRETFORD SOLUTION)Memo
 Description: The consent decree in EDF v. Browner, Civ. No. 89-0598 (D.D.C.), required EPA to decide whether or not to list several categories of petroleum refining wastes and to prepare a report on other waste categories. EPA determined that sludges from the Stretford process (which contain vanadium salts), catalysts from sulfur complex and H2S facilities, and vanadium-containing Stretford or Beavon-Stretford solutions do not require listing determinations (SEE ALSO: Listing Background Document for 1992-1996 Petroleum Refining Listing Determination, Study of Selected Petroleum Refining Residuals, and 63 FR 42110; 8/6/98). Hazardous waste listing determinations are wastestream-specific, not constituent-specific. Vanadium does not present sufficient risk to provide a basis for listing. EPA is deferring the use of the persistence, bioaccumulative, and toxic (PBT) criteria for metals in its waste minimization program, since it is working to develop an Agency-wide approach. The Science Advisory Board (SAB) will review the 3MRA model, which estimates the chemical release, fate, exposure and resulting risks to human health and the environment (SEE ALSO: 64 FR 63382; 11/19/99).
 
07/24/2001RECYCLING OF PETROLEUM VAPORS AND LIQUID CONDENSATE FROM PETROLEUM PRODUCT STORAGE TERMINALSMemo
 Description: Volatile hydrocarbons released from petroleum products, which are absorbed on to carbon-containing filters or vapor recovery units (VRUs) and then returned to the front end of the petroleum refinery to be reused, are not solid wastes. The captured hydrocarbons are considered commercial chemical products being reclaimed, which are excluded from the definition of solid waste, even if they are non-listed commercial chemical products. State regulations may be more stringent than the federal regulations.
 
08/07/2000FEDERAL CONTROLS OF DRY CLEANING FLUID PERCHLOROETHYLENEMemo
 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.
 
02/19/1999REGULATORY STATUS OF PETROLEUM PRODUCT CONTAINED IN ABSORBENT PADSMemo
 Description: Absorbent pads used to absorb petroleum products (e.g., gasoline, kerosene, fuel oil) from spills and tank cleanings, which are processed to recover petroleum products, are off-specification CCPs being reclaimed and not wastes. Recovered petroleum products that are reprocessed or burned as fuels are not solid wastes. Residues from spill cleanups are viewed as off-specification products. CCPs not specifically listed in 261.33 have the same regulatory status as CCPs that are listed when determining regulatory status of recycled material (SEE ALSO: 50 FR 14219; 4/11/85).
 
07/24/1997REGULATORY DETERMINATION ON THE STATUS OF CERTAIN MANUFACTURING WASTESMemo
 Description: Warfarin tablets meeting a commercial chemical product (CCP) listing are still considered listed CCPs when tested by crushing or dissolving. The de minimis mixture rule exclusion in Section 261.3(a)(2)(iv)(D) applies to discharges of CCPs from rinsing and cleaning personal protective equipment (PPE). Discarded equipment meeting the definition of debris which is contaminated with a listed waste must be managed as a hazardous waste (HW) until it no longer contains the HW. Contaminated equipment can be washed using the alternative debris treatment standards to the point where it is no longer considered to contain a HW. Whether air filters from a manufacturing process meet a listing depends on site-specific factors. Air filters used in the production of a P or U listed commercial chemical product (CCP) do not fall within the scope of the Section 261.33 listings prior to the material (warfarin) becoming a CCP. Once the material meets the listing description (becomes a CCP), particles captured in the filters are a listed CCP when disposed (USE WITH CAUTION: see 56 FR 7200; 2/21/91). Air filters are regulated as a solid waste mixed with a listed hazardous waste. Air filters may qualify as hazardous debris and may be washed so as to no longer contain a listed hazardous waste.
 
06/01/1997USE AS INGREDIENT NOT WITHIN SOLVENT LISTINGQuestion & 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.
 
04/07/1997VACATED DITHIOCARBAMATE LISTING - CERCLA SECTION 103(A) STATUSMemo
 Description: Dithiocarbamate U-listings (carbamate listings) vacated by the D.C. Circuit Court are not RCRA hazardous wastes. In addition, they are not hazardous substances under CERCLA Section 101 and 102, nor are they subject to CERCLA Section 103(a) reporting. Provides a list of vacated carbamate U-listings with CAS numbers.
 
04/01/1997Draft Prioritized Chemical ListPublication
 Description: The Draft Prioritized Chemical List is a relative ranking of more than 800 chemicals based on the chemicals' tendency to persist in the environment.
 
08/01/1996DEFINITION OF COMMERCIAL CHEMICAL PRODUCT FOR SOLID WASTE DETERMINATION VS. HAZARDOUS WASTE IDENTIFICATIONQuestion & Answer
 Description: Discusses the definition of commercial chemical product (CCP) for purposes of definition of solid waste v. for purposes of definition of P-listed or U-listed hazardous waste. For purposes of the P- and U-lists, EPA intended to include only those CCPs and manufacturing chemical intermediates known by generic name listed in Section 261.33. P- and U- listed wastes exclude manufactured articles such as thermometers and fluorescent lamps. For purposes of Section 261.2, CCP means all types of unused commercial products, whether chemicals or not. Off-specification thermometers going for reclamation are CCPs going for reclamation and are not solid wastes. Thermometers going for disposal are not U151 and are only regulated if characteristic.
 
06/01/1996HAZARDOUS WASTE LIQUID-CONTAINING PUMPS AND THE LIQUIDS IN LANDFILLS PROHIBITIONQuestion & Answer
 Description: Owners and operators have three options for disposing of containerized liquids in landfills: remove liquid, add sorbent or solidify, or eliminate by other means. There is no requirement to dismantle pumps containing free liquids prior to disposal in a landfill under the liquid in landfill prohibition. There is no requirement to remove or sorb free liquids in containers such as pumps holding liquids for use other than storage.
 
02/27/1996CLARIFICATION OF THE ""MIXTURE RULE,"" THE ""CONTAINED-IN"" POLICY, LDR ISSUES, AND ""POINT OF GENERATION"" FOR U096Memo
 Description: U096 spilled on soil is subject to the contained-in policy. The contained-in policy does not specify levels at which contained-in determinations must be made. EPA leaves contained-in determinations to the discretion of the implementing agency. Under the Section 261.3(a)(2)(iii) mixture rule exemption, mixture of hazardous waste listed solely for exhibiting a characteristic (e.g., U096) and solid waste that no longer exhibits a characteristic can be disposed in a subtitle D landfill, but must still meet land disposal restrictions treatment standards (SEE ALSO: 268.3; 61 FR 18780; 4/29/96; 66 FR 27266; 5/16/01).
 
02/15/1996USE OF USED OIL AS A DUST SUPPRESSANTMemo
 Description: EPA prohibits the use of used oil as dust suppressant. EPA does not have the authority under RCRA to regulate commercial dust suppressants or other commercial products other than waste-derived products and discarded commercial chemical products.
 
09/01/1995ISOMERS OF P- AND U-LISTED WASTESQuestion & Answer
 Description: If the generic mixed isomer name and CAS number of a compound appear on the P-list or U-list, any individual isomers of that compound and all mixtures of isomers of that compound meet the listing. When EPA designates a particular isomer, only that isomer is covered by the listing.
 
08/24/1995CARBAMATE LISTING DETERMINATION (60 FR 7824, FEBRUARY 9, 1995) AS IT RELATES TO THE LATEX PROCESS WASTES GENERATED BY A COMPANYMemo
 Description: K161 is limited to production wastes from dithiocarbamate acids and their salts. Latex process wastes containing dithiocarbamate (ethyl zimate) are not U407, as ethyl zimate is not the sole active ingredient (SUPERSEDED: U407 listing vacated by Dithiocarbamate Task Force v. EPA). Residue remaining in a container or inner liner removed from a container that held any listed CCP is a hazardous waste when discarded or intended for discard.
 
02/17/1995EPA'S CURRENT CONTAINED-IN POLICY AS IT APPLIES TO ENVIRONMENTAL MEDIA THAT CONTAIN P- AND U-LISTED HAZARDOUS WASTESMemo
 Description: The contained-in policy applies to P- and U-listed wastes in the same manner as other wastes. Although Section 261.33(d) states that “contaminated” soil and water from the cleanup of releases of P-listed and U- listed wastes are hazardous, they would not not be considered contaminated if they do not contain waste.
 
02/15/1995Environmental Fact Sheet: EPA Finalizes Listing of Wastes from the Production of Carbamates and Adds 58 Chemicals to the Off-Specifications Product ListPublication
 Description: Amends the list of hazardous wastes generated from specific sources to include the following additional wastes: K156 - organic waste from the production of carbamates and carbamoyl oximes; K157 - wastewaters from the production of carbamates and carbamoyl oximes; K158 - bag house dust and filter/separation solids from the production of carbamates and carbamoyl oximes; K159 - organics from the treatment of thiocarbamate wastes; K160- solids from the production of thiocarbamates and solids from the treatment of thiocarbamate wastes; K161 - purification solids, bag house dust, and floor sweepings from the production of dithiocarbamate acids and their salts (not including K125 and K126); and 58 specific materials (commercial chemical products or manufacturing chemical intermediates) that are hazardous wastes if discarded or intended to be discarded. Adds EPA Hazardous Waste Numbers K156 through K161 and the 58 specific toxic and acutely toxic products to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) list of hazardous substances and establishes CERCLA reportable quantities for these materials.
 
01/15/1995CMA/EPA BIF Workshop; Edited TranscriptPublication
 Description: This document presents the edited transcript from Chemical Manufacturers Association/EPA workshop on boilers and industrial furnaces (BIFs). It discusses waste analysis of feed streams, monitoring requirements, automatic waste feed cutoff, owner/operator inspections, Subpart BB inspection, recordkeeping, training for facility personnel, compliance testing, management of residues, and regulatory development. It also includes questions and answers, agenda for the workshop, list of questions generated at the workshop, list of speakers, and list of EPA combustion guidance documents.
 
12/01/1994EPINEPHRINE RESIDUE IN A SYRINGE IS NOT P042Question & Answer
 Description: Epinephrine in a syringe discarded after use is not P042. EPA considers residues remaining in dispensing instrument to have been used for their intended purpose.
 
09/14/1994EXPORT FROM JAPAN OF PHOSPHORUS OXYCHLORIDE CONTAINING BUBBLERSMemo
 Description: The purity of phosphorus oxychloride remaining in a bubbler canister indicates that the phosphorus oxychloride is unused. Therefore, the bubbler canister qualifies as a CCP being reclaimed and is not a solid waste.
 
06/08/1994APPLICABILITY OF 261.33 TO DIETHYLHEXYL PHTHALATE-CONTAINING CAPACITORS FROM FLUORESCENT LIGHT BALLASTSMemo
 Description: Capacitors that contain diethylhexyl phthalate (DEHP) that are removed from lamp ballasts have been used, and therefore are not U028. If DEHP from ballasts is reclaimed and then spilled or discarded, the listing could apply.
 
04/13/1994STATUS OF BERYLLIUM DUST, PO15Memo
 Description: The P015 listing applies to product beryllium powder, including dust and fines. The word dust was inadvertently deleted from the original listing for beryllium dust in 1988.
 
03/01/1994OFF-SPECIFICATION PARAFORMALDEHYDE MEETS COMMERCIAL CHEMICAL PRODUCT LISTINGQuestion & Answer
 Description: Paraformaldehyde is an off-specification form of formaldehyde and meets the U122 listing. When commercial chemical products (CCPs) undergo chemical changes and become off-specification, the original P or U code still applies.
 
09/20/1993DISCARDED OFF-GAS PIPING, EQUIPMENT, AND OFF-GAS SCRUBBER SOLUTION FROM A TANK SYSTEMMemo
 Description: Discarded off-gas scrubber solution is not listed hazardous waste because the gas contained in the solution is derived-from a product, not a waste. Liquid tank residuals are listed CCP. If container from which residues are removed is RCRA empty, residue not hazardous waste (SUPERSEDED: See the April 12, 2004 letter from Springer to Coles). Contains discussion of the triple rinsing requirement for acute (P-listed) waste.
 
09/01/1993NITROGLYCERINE PILLS AS COMMERCIAL CHEMICAL PRODUCTSQuestion & Answer
 Description: Discarded pills containing nitroglycerine as the sole active ingredient are P081 (SUPERSEDED: see 66 FR 27286; May 16, 2001 and RPC# 3/18/03-01). There is not a critical percentage or cut-off concentration in order to be the sole active ingredient for the P- and U-listed listings.
 
07/28/1993TRIPLE-RINSING REQUIREMENT APPLICABLE TO CONTAINERS HOLDING RESIDUES FROM THE INCINERATION OF ACUTE HAZARDOUS WASTESMemo
 Description: Incinerator ash and other residues from the treatment of P-listed acutely hazardous waste remain P-listed and acutely hazardous. Containers holding such residues must be rendered empty by triple rinsing. No formal EPA approval is necessary in order to use an alternative and equivalent method as a substitute for triple rinsing.
 
11/02/1992REGULATORY STATUS OF BERYLLIUM-CONTAMINATED EQUIPMENTMemo
 Description: If beryllium dust is used in glove box manufacturing, then beryllium dust residual on the boxes after production is considered used, and therefore is not P015. The P015 listing does not cover particles created during normal beryllium machining, unless the purpose of machining is to create beryllium dust or powder as a commercial chemical product (CCP).
 
11/01/1992BERYLLIUM DUST (P015); APPLICABILITYQuestion & Answer
 Description: The P015 listing only applies to beryllium dust (SUPERSEDED: See current Section 261.33(e) where listing now reads “Beryllium powder”).
 
11/01/1992RECLAIMED COMMERCIAL PRODUCTS: REGULATORY STATUSQuestion & Answer
 Description: Reclaimed creosote is classified as U051 if discarded. Creosote-contaminated soil is regulated as hazardous waste because it contains U051.
 
10/15/1992REGULATORY STATUS OF SOILS CONTAMINATED FROM RELEASES OF COMMERCIAL CHEMICAL PRODUCTSMemo
 Description: Product carbon tetrachloride released from a tank is U211. Soils containing hazardous waste must be managed as a hazardous wastes until or unless they no longer contain listed waste, exhibit characteristic, or are delisted pursuant to the contained-in policy. The health-based levels used in contained-in determinations are site-specific.
 
08/24/1992STATUS OF CYCLOPHOSPHAMIDE AS A HAZARDOUS WASTEMemo
 Description: P- and U-listings apply to all CCPs with the generic names listed in 261.33, regardless of Chemical Abstract Service (CAS) numbers (CAS numbers were added to P- and U-lists as an identification aid). Anhydrous cyclophosphamide and cyclophosphamide monohydrate, although described by different CAS numbers, are both U058.
 
04/15/1992Batch-Type Procedures for Estimating Soil Adsorption of Chemicals; Technical Resource DocumentPublication
 Description: Describes laboratory batch procedures for assessing the capacity of soils and soil components of liners for waste management facilities to attenuate chemical constituents from solution. Documents procedures for organic and inorganic constituents, and scientific basis and rationale. Examples demonstrate application of procedures and use of data in designing soil liners for pollutant retention.
 
03/01/1992COMMERCIAL CHEMICAL PRODUCT DEFINITION IN 261.33Question & Answer
 Description: Discarded unused commercial chemical product (CCP) with two active ingredients cannot be P-listed or U-listed waste because the listed chemical is not the sole active ingredient. Functionally inert components are not active ingredients.
 
04/12/1991NOTIFICATION OF ERRORS IN THE TECHNICAL AMENDMENT TO THE THIRD THIRD LAND DISPOSAL RESTRICTIONS (LDRS), PUBLISHED JANUARY 31, 1991Memo
 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).
 
02/15/1991Environmental Fact Sheet: Interim Final Rule Suspending Application of the Toxicity Characteristic for Used Chlorofluorocarbon Refrigerants Being ReclaimedPublication
 Description: This fact sheet discusses the interim final rule suspending the application of toxicity characteristics for reclaiming used chlorofluorocarbon refrigerants, how the recycling used refrigerants is gaining acceptance, and that venting certain chemicals, including refrigerants, will be prohibited effective July 1, 1992.
 
01/29/1991TECHNICAL AMENDMENT TO LIST OF COMERCIAL CHEMICAL PRODUCTS IN 40 CFR 261.33 AND LIST OF HAZARDOUS CONSTITUENTS IN APPENDIX VIIIMemo
 Description: EPA has removed strontium sulfide (P107) from the P-list of hazardous waste at 261.33 and from Part 261, Appendix VIII, the list of hazardous constituents.
 
08/20/1990REGULATORY STATUS OF MANUFACTURING PROCESS WASTE WITH XYLENE AND PESTICIDE CONSTITUENTSMemo
 Description: The presence of xylene and pesticide constituents in manufacturing process waste does not necessarily trigger the hazardous waste listings.
 
06/14/1990RCRA WASTE CLASSIFICATION OF LABORATORY STANDARDSMemo
 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.
 
06/13/1990USED OIL AND IDENTIFICATION OF LISTED HAZARDOUS WASTEMemo
 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).
 
05/01/1990HAZARDOUS WASTE IDENTIFICATIONQuestion & Answer
 Description: Mercury spilled from a used thermometer is a spent material and is a solid waste when reclaimed. Mercury-contaminated soil is a hazardous waste if it exhibits a characteristic. P-list and U-list designation for spill residues applies to a unused CCP, not used mercury.
 
04/05/1990DIMETHYL BENZENE-LISTING CLARIFICATIONMemo
 Description: Benzene dimethyl (U239, CAS No. 1330-20-7), a synonym for xylene, is listed for ignitability only (typographical error in CFR). The 4/22/88 Federal Register (53 FR 13382) added CAS numbers and chemical synonyms to P- and U-lists.
 
03/29/1990INCINERATOR RESIDUES FROM TRIAL BURNMemo
 Description: The residues from an incinerator trial burn that uses carbon tetrachloride and chlorobenzene are U211 and U037. Using a material for an incinerator trial burn is intent to dispose.
 
02/14/1990END-USERS OF CHLORDIMEFORM EXEMPTIONMemo
 Description: Chlordimeform not listed, but may be ignitable (D001). Not subject to regulation if returned to the manufacturer for resale or reclamation. If there is a valid market, continued use as product is not solid waste (SW). The burden of proof is on the party making the claim. Canceled pesticides are SW if discarded (abandoned), intended for discard, or fuel.
 
02/09/1990DINOSEB FORMULATIONS, REGULATORY STATUSMemo
 Description: Discussion of the CESQG. A generator may treat hazardous waste up to 90 days without a permit. Dinoseb sole active ingredient in formulation is P020. Dinoseb and naptalam active ingredients are not listed. Dinoseb major constituent (95%) is a technical grade CCP and is listed if discarded unused. Dinoseb salts are not included.
 
11/01/198940 CFR SECTION 261.33: SPILLS OF COMMERCIAL CHEMICAL PRODUCTSQuestion & Answer
 Description: Section 261.33(d) applies to all spill residues regardless of where the spill occurs.
 
10/05/1989WASTE CODE LISTINGS AND TECHNICAL CORRECTIONSMemo
 Description: Warfarin is the common name associated with the chemical listed as P001. The U036 listing covers all formulations in which chlordane is the sole active ingredient. There is no CAS number associated with U051 because EPA wants to include all forms of creosote. Discussion of corrections to U126 and U161.
 
09/28/1989OFF-SPEC COMMERCIAL CHEMICAL PRODUCTS AT BOTTLING FACILITYMemo
 Description: Product solvent that is discarded because it was contaminated with another product while being containerized is an off-specification CCP and is a P-listed or U-listed waste if the solvent is listed in 261.33. RCRA waste codes and regulations applicable to wastes do not necessarily correspond to DOT hazardous material descriptions. Wwastes are defined as hazardous under RCRA, in part, based on characteristics, such as ignitability (D001) and corrosivity (D002).
 
08/21/1989P AND U-LISTED WASTESMemo
 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.
 
06/28/1989SOLVENT AND COMMERCIAL CHEMICAL PRODUCT WASTE STREAMSMemo
 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.
 
06/23/1989REGULATION OF CANCELLED PESTICIDESMemo
 Description: Until the FIFRA regulations are amended to reflect RCRA Subtitle C storage standards, the regulations applicable to storage of suspended or canceled U-listed pesticides (silvex and 2,4,5-T) are determined on a case-by-case basis (SUPERSEDED).
 
03/20/1989REGULATORY STATUS OF CANCELLED HERBICIDE DINOSEBMemo
 Description: Canceled dinoseb herbicide product becomes solid waste at point it is to be sent for disposal. The dinoseb is U015 when discarded unused if it is technical grade or if dinoseb is the sole active ingredient. Congress clearly intended RCRA Subtitle C to cover transportation of hazardous waste. The waste management system is a "cradle-to-grave" system.
 
03/17/1989BERYLLIUM WASTE DUSTMemo
 Description: Solidified and containerized beryllium dust and other filtration elements collected by a vacuum hood and directed through a two stage filtration system are solid waste if they are abandoned by land disposal. The waste is not P015 or listed, but is hazardous if characteristic.
 
03/14/1989PESTICIDE STANDARDS FOR FORMALDEHYDE AND PARAFORMALDEHYDEMemo
 Description: Formaldehyde and paraformaldehyde added to pesticides to preserve the formulation are not considered active ingredients for purposes of P- and U-lists, even though FIFRA defines them as active ingredients for FIFRA purposes. Discussion of the intent of the sole active ingredient provision.
 
03/10/1989CHARACTERIZATION OF BERYLLIUM WASTESMemo
 Description: Beryllium dust and associated wastes from the grinding and polishing of beryllium that are collected in air filtration equipment would generally not match the listing description for CCP beryllium powder (P015). The waste could be characteristic. The solidification or stabilization of hazardous waste with concrete is treatment and may trigger permitting requirements.
 
11/02/1988WASTE LISTINGS FOR COMMERCIAL CHEMICAL PRODUCTS - MERCURYMemo
 Description: The determination of whether mercury-containing thermometers, batteries (battery), and switches are CCPs and solid waste are U151 when discarded depends on the contamination and usage of the material. (SEE ALSO: 70 FR 45508; 8/5/05)
 
09/30/1988AEROSOL CANS, ON-SITE DEPRESSURIZATION OFMemo
 Description: The region is in the best position to determine if aerosol cans are hazardous waste. Generally, cans are hazardous if they contain a listed or characteristic CCP and are not empty per 261.7 and/or if the cans themselves exhibit a characteristic. The region determines if depressurizing aerosol cans meets the definition of treatment. Waste aerosol cans generated in military housing are exempt household hazardous waste (HHW).
 
07/21/1988CHLOROFLUOROCARBON RECYCLINGMemo
 Description: Used refrigerants meet the definition of a spent material. Used CFC refrigerant is not F-listed spent solvent but may exhibit a characteristic. Used refrigerant is not U121 or U075 because it has been used. The P-listings and U-listings do not apply to used chemicals. Cylinders containing used refrigerants to be reclaimed are solid waste (SW). Generators may use knowledge of similar operations at different facilities to characterize waste (SEE ALSO: 261.4(b)(12)). An owner of refrigeration equipment and a company or individual performing servicing may be generators of used refrigerant waste (i.e., cogenerators).
 
05/19/1988DISCARDED COMMERCIAL CHEMICAL PRODUCTSMemo
 Description: The P- and U-lists apply to commercial and technical grades of a product, and to formulations in which chemical is sole active ingredient. Sole active ingredient means the only chemically active component for the function of the product. If a waste is not listed, the generator must test or apply knowledge to determine if waste exhibits a characteristic.
 
05/03/1988CHLORDANE AND HEPTACHLOR PESTICIDE WASTEMemo
 Description: CCPs (pesticides) must be discarded or intended for discard to be P- or U-listed hazardous waste. Materials are "discarded" when abandoned, applied to the land, or used to produce a fuel. Products containing small amounts of other chemicals as manufacturing impurities still have a sole ingredient. There is no percentage cutoff for active ingredient. An active ingredient performs the function of a product. Fillers, carriers, and propellants are not active ingredients. Chlordane product (U036) that contains small amount of heptachlor (P059 if CCP) has only one active ingredient (chlordane) because heptachlor is a manufacturing impurity. Technical grade means all commercial grades of chemical. There is no exact criteria define technical grade. Product purity varies from compound to compound.
 
04/25/1988REGULATORY STATUS OF ANTINEOPLASTIC DRUG WASTESMemo
 Description: Antineoplastic drugs that have been diluted are not spent materials because they are not contaminated and have not been used for their intended function. Excess portions of unused antineoplastic drugs listed in 261.33 that have been diluted are solid waste when discarded and are P-listed or U-listed hazardous wastes if drug is sole active ingredient.
 
03/14/1988ECOSCINT A & ECOSCINT OMemo
 Description: Ecoscint A and Ecoscint O are not listed. They would be hazardous waste if they exhibit a characteristic.
 
02/11/1988SPENT PIPELINE FILTER CARTRIDGESMemo
 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.
 
01/14/1988WASTE GENERATED BY AN INCINERATOR TRIAL BURN OF SAND SPIKED WITH TRICHLOROBENZENE AND HEXACHLOROETHANEMemo
 Description: A mixture of sand and unused CCP hexachloroethane (U131) for use in an incinerator trial burn is a hazardous waste. Ash derived from burning the mixture carries U131 via the derived-from rule.
 
09/09/1987MATERIALS CONTAMINATED WITH PESTICIDE PRODUCTSMemo
 Description: Listed CCPs (chlordane, heptachlor) are not waste when applied to the land in a manner consistent with their normal use nor when later found in soil, a swimming a pool, carpet, or a wallboard. Unintentionally spilled pesticides (e.g., in soil or carpet) are considered discarded and can be P-listed or U-listed hazardous waste.
 
06/17/1987METHANOL RECOVERY SYSTEM - CLARIFICATION OF WASTE STATUSMemo
 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.
 
06/16/1987CONTAINERS USED TO HOLD LISTED CHEMOTHERAPY DRUGSMemo
 Description: Several chemotherapy drugs are U-listed wastes. In order to minimize exposure, EPA recommends against rendering vials holding these drugs empty under 261.7. Instead, the entire volume of waste, including the vials themselves, should be weighed.
 
05/18/1987CARBON SCRUBBER WASTES IN WHICH PRODUCT MATERIALS ARE CAPTUREDMemo
 Description: EPA regulates listed waste contained-in another material, such as spent carbon scrubbers (SEE ALSO: 66 FR 27266; 5/16/01). Unused Phorate pesticide that is volatilized into the air during production and captured in carbon filters is P094 (USE WITH CAUTION: see 56 FR 7200; 2/21/91). If Phorate is reclaimed or reused rather than destroyed, it is not a solid waste.
 
05/18/1987SPENT CARBON REGULATIONMemo
 Description: EPA regulates listed waste contained-in another material, such as spent carbon scrubbers (SEE ALSO: 66 FR 27266; 5/16/01). Unused Phorate pesticide that is volatilized into the air during production and captured in carbon filters is P094 (USE WITH CAUTION: see 56 FR 7200; 2/21/91). If Phorate is reclaimed or reused rather than destroyed, it is not a solid waste.
 
05/13/1987PACKAGES CONTAINING RESIDUAL URETHANE COATING CHEMICALSMemo
 Description: Containers holding listed or characteristic residues should be emptied according to 261.7 to ensure that containers are no longer subject to Subtitle C regulation. 261.7 applies to all hazardous wastes, not just P-listed and U-listed CCPs.
 
03/11/1987CONTAMINATED GROUNDWATER, REGULATORY STATUS OFMemo
 Description: Interim status standards, not 264 standards, are imposed under 3008(h) orders. A treatment system for contaminated groundwater should be handled as a change during interim status. The leakage of hazardous waste compounds from process areas meets the definition of discarded. 264.1 and 265.1 provide exemptions for immediate response activities.
 
12/08/1986COMMERCIAL CHEMICAL PRODUCT P LISTING APPLIES ONLY TO UNUSED PRODUCT, NOT USED RESIDUESMemo
 Description: Ash from burning aluminum and/or magnesium phosphide for fumigation is a hazardous waste only if it is characteristic. The P006 listing does not apply because the aluminum phosphide has been used.
 
12/05/1986SOLVENTS USED AS REACTANT AND SOLVENT WASTES GENERATED BY A PRODUCTION PROCESSMemo
 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).
 
12/05/1986SOLVENTS USED AS REACTANT NOT LISTED AS SPENT SOLVENT OR COMMERCIAL CHEMICAL PRODUCTMemo
 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.
 
11/03/1986FLOATING PLASTIC BALLS USED TO CONTROL VAPORS FROM TANKS CONTAINING LISTED PRODUCTMemo
 Description: Floating hollow plastic balls used to control vapors from industrial process tanks containing product carbon disulfide are hazardous wastes, since carbon disulfide is listed as P022. Cleaning may render the balls nonhazardous.
 
09/15/1986DEFINITION OF SOLID WASTEMemo
 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.
 
09/04/1986REJECT SUBSTRATES CONTAINING VENADIUM PENTOXIDE REGULATION UNDER RCRAMemo
 Description: P010 does not apply to reject vanadium pentoxide substrates, since they have been used and do not qualify as CCPs. Crushing reject substrates does not make them process wastes. Discarded vanadium pentoxide substrates are hazardous if characteristic.
 
08/21/1986RELISTING HAZARDOUS WASTEMemo
 Description: EPA intends to redefine hazardous waste listings by.
 
06/03/1986REQUEST FOR COMMENT ON MEMORANDUM CONCERNING THE CLEANUP OF RESIDUES OF COMMERCIAL CHEMICAL PRODUCTS WITHIN A WAREHOUSE STORAGE AREAMemo
 Description: Listed or characteristic CCPs spilled in a warehouse are subject to RCRA Subtitle C regulation unless immediately cleaned up.
 
05/06/1986HEALTH ASSESSMENT INFORMATION IN LISTING DECISIONS; LISTING OF TF-1, AN ELECTRICAL TRANSFORMER FLUSHING AGENTMemo
 Description: The presence of Appendix VIII hazardous constituents or a combination of P-listed and U-listed ingredients are not the only factors in the listing determination for solvent TF-1. Concentration, migration potential, persistence, quantity generated, and management history are part of the determination. To be listed under on P- or U-list it must be a pure or technical grade of a listed solvent, or contain a sole active ingredient.
 
05/01/1986FORMALDEHYDE-BASED TOILET DEODORANTSMemo
 Description: The intended use of toilet deodorants requires them to ultimately enter sewers/ cesspools, this is not disposal. Toilet deodorants disposed unused with formaldehyde as the sole active ingredient are hazardous wastes.
 
04/02/1986MERCURY THERMOMETERS, RECLAIMED OFF-SPEC AND BROKENMemo
 Description: Unused off-specification and broken thermometers are CCPs and are not solid waste when reclaimed. Neither listed nor characteristic CCPs are solid waste when reclaimed.
 
01/30/1986ANTI-NEOPLASTIC AGENTS IN HOSPITAL WASTES, DISPOSAL OFMemo
 Description: Seven antineoplastics are U-listed hazardous waste. Antineoplastics are not regulated as class. Hospitals generating less than 100 kg/mo exempt as CESQG. There is no EPA guidance for a proper incineration destruction temperature.
 
12/13/1985PESTICIDE APPLICATOR WASHING RINSE WATERMemo
 Description: Airplane washwater is not listed hazardous waste via the mixture rule because the pesticide residue on the aircraft is used and not a discarded CCP. The washwater may be characteristic. Pesticide residue remaining in spray tanks has not been used and is a CCP.
 
11/01/1985SOLVENT MIXTURE RULEQuestion & Answer
 Description: If a spilled product has two or more active ingredients (e.g., toluene and benzene) then the spill residue would not be classified as a P-listed or U-listed waste. The contaminated soil is only hazardous if it exhibits a characteristic.
 
09/10/1985DIOXIN-CONTAINING WASTE RINSEATES, DISPOSAL BY DEEP WELL INJECTIONMemo
 Description: Rinsate from containers that held 2,4,5-T and other pesticide formulations is an acute hazardous waste. A deep well injection facility must be permitted to handle dioxin-containing wastes in order to dispose of these wastes. A generator may petition EPA to exclude waste if the waste does not meet listing criteria (SEE ALSO: 261.7).
 
07/22/1985PESTICIDE APPLICATOR WASHING RINSEWATERMemo
 Description: Airplane washwater is not a hazardous waste (HW) via the mixture rule because pesticide residue on an aircraft is not a discarded CCP because it has been used (released into the environment as a result of use) and is not a listed HW. Washwater is only HW if characteristic (SEE ALSO: RPC# 12/15/92-01).
 
06/27/1985SCRAP DEHP AND SMALL CAPACITORS CONTAINING DEHP, DISPOSAL REQUIREMENTS FORMemo
 Description: Contaminated diethylhexyl phthalate (DEHP) generated in a manufacturing process is U028. The capacitors are not U028. Gloves and rags used to clean up spills or leaks of DEHP are listed. The materials contaminated as a result of handling during the manufacturing would not be listed.
 
05/17/1985EMBALMING FLUIDS, USEDMemo
 Description: Unused embalming fluid containing formaldehyde as the sole active ingredient is a listed waste if disposed. Section 261.33 does not apply to wastes which result from the intended use of a product. Used embalming fluid is neither listed nor characteristic and so it is not a hazardous waste.
 
05/14/1985DISCARDED COMMERCIAL CHEMICAL PRODUCTSMemo
 Description: Section 262.11 outlines the generator’s responsibility for identifying hazardous wastes. The P- and U-listings apply only to unused CCPs, not to process wastes containing chemicals listed in 261.33. The U122 formaldehyde listing does not apply to waste containing used formaldehyde or fish contaminated with formaldehyde. Discarded fish and formaldehyde must be evaluated for characteristics. EPA regulates certain chemicals in their unused form but not all wastes containing the same chemicals.
 
05/01/1985SOLID WASTE DETERMINATION - ACRYLONITRILE ASHQuestion & Answer
 Description: A burned product is viewed as discarded. Ash from the product acrylonitrile that burns in a warehouse fire meets the U009 listing via derived-from rule.
 
04/10/1985PERCHLOROETHYLENE AND SURFACTANT, DISTILLATION OF RESIDUE CONTAININGMemo
 Description: Product perchloroethylene mixed with surfactant is still the CCP U210. CCPs being reclaimed are not solid wastes. The residue from distillation is hazardous.
 
04/05/1985SOIL CONTAMINATED WITH TOLUENEMemo
 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.
 
01/18/1985K001-LISTED WASTES FROM WOOD PRESERVING PROCESSESMemo
 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).
 
01/16/1985COMMERCIAL CHEMICAL PRODUCTS USED IN AIR BAGS - EFFECT ON RECYCLE OF FERROUS SCRAP FROM AUTOMOBILESMemo
 Description: Air bag inflator canisters containing sodium azide (P105) would not be a CCP and thus is not a listed hazardous waste, since sodium azide is not a sole active ingredient. There are no de minimis exits from 261.33. EPA is considering new regulations covering mixtures of CCPs. Deployed air bag canisters are not listed.
 
12/26/1984CONTAMINATED GROUNDWATER, RCRA REGULATORY STATUSMemo
 Description: Generators do not use Appendix VIII in hazardous waste (HW) determination. Wastes containing Appendix VIII constituents are not HW unless they are listed or characteristic. Collected groundwater contaminated with listed or characteristic waste is regulated as HW. Discussion of the contained-in policy.
 
11/29/1984CORROSIVE SOLIDS, COMMERCIAL CHEMICAL PRODUCTS, REACTIVE WASTES DEFINEDMemo
 Description: Solid forms of sodium hydroxide and potassium hydroxide are not D002 corrosive wastes because there is no test for corrosive solids. Formaldehyde residues in potato starch are not a P-listed or U-listed hazardous waste. The CCP comment in the regulations is in brackets and thus is not part of the regulations. Reactive cyanide and sulfide levels are outlined (SUPERSEDED: see RPC# 4/21/98-01).
 
09/20/1984DIBUTYLTIN DIFLUORIDE NOT A LISTED RCRA WASTEMemo
 Description: Dibutyltin difluoride is not a listed waste. Dibutyltin difluoride contaminated protective clothing would be hazardous only if it exhibits a characteristic. It is a generator’s responsibility to determine whether a waste is listed or exhibits a characteristic.
 
08/01/1984METHYL CHLOROFORMQuestion & 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.
 
06/06/1984DEODORANTS FOR PORTABLE TOILETSMemo
 Description: Formaldehyde is not the sole active ingredient in portable toilet deodorants, and they are not listed hazardous waste.
 
05/30/1984BALLAST FLUID CLASSIFICATIONMemo
 Description: Process wastes containing listed P-list and U-list chemicals are not listed. The P-list and U-list is only for CCPs, which are commercially pure or technical grade substances in which the chemical is the sole active ingredient. Formaldehyde used to control growth in a ship ballast is not listed.
 
03/01/1984XYLENE (U239) SPILLED ONTO SOILQuestion & Answer
 Description: If unused xylene is spilled onto the ground, contaminated soil is not U239 if the soil is not ignitable, due to the mixture rule exclusion in 261.3(a)(2)(iii) (SUPERSEDED: see RPC# 3/22/94-03; RPC# 11/4/92-01).
 
11/01/1983SALTS AND ESTERS OF P- AND U-LISTED WASTESQuestion & Answer
 Description: Commercial chemical products (CCPs) are regulated under 261.33 only if the chemical is specifically listed in 261.33(e) or (f). If the parent compound is listed but the salt or ester of that compound is not, then only the parent compound is controlled. 302.4 lists CCPs by CAS number (SEE ALSO: RPC# 9/1/95-01).
 
11/01/1983USED COMMERCIAL CHEMICAL PRODUCTQuestion & Answer
 Description: Chemicals listed in 261.33 no longer qualify as commercial chemical products (CCPs) after they have been used, and do not meet a P-listing or U-listing. Tetrachloroethylene (PCE) in a transformer is U210 if it leaked prior to putting the transformer in service.
 
08/01/1983ANTINEOPLASTIC DRUGSQuestion & Answer
 Description: Discusses U-listed antineoplastic (anticancer) drugs, including Cyclophosphamide (Cytoxin), Daunomycin, Melphalan, Mytomycin C, Streptozotocin.
 
03/12/1983CLARIFICATION OF REGULATORY STATUS OF MANUFACTURING WASTES CONTAINING COMPOUNDS LISTED IN 261.33Memo
 Description: P-and U-listings do not apply to manufacturing process wastes with compounds listed in 261.33 because EPA unable to establish reliable concentration levels indicating when such wastes containing P-listed or U-listed chemicals pose enough of a hazard to deserve regulation.
 
02/01/1983BENZENE LEAK INTO GROUNDWATERQuestion & Answer
 Description: Benzene that leaked into groundwater prior to 11/19/80 is classified as hazardous waste (HW) if it was pumped and treated after 11/19/80. Benzene-contaminated groundwater is U019. When the site is reactivated, the facility must comply with HW regulations.
 
02/01/1983SOLUBLE CYANIDE SALTSQuestion & Answer
 Description: P030 applies only to compounds that form hydrogen cyanide (HCN) when exposed to acidic conditions.
 
09/18/1981PESTICIDES CONTAINING A 261.33(E) COMPOUND AS A SOLE ACTIVE INGREDIENTMemo
 Description: Diluted Aldicarb (P070) solution is disposal of product if it is the sole active ingredient. A commercial applicator may mix, apply, rinse, and dispose of pesticide on farmer property if follows label. The farmer exemption does not apply to an off-site shipment for disposal or if on-site disposal of other farmer’s pesticides.
 
06/19/1981P-WASTE LISTING FOR CATALYSTMemo
 Description: The P120 listing applies to all oxides of vanadium's +5 oxidation state.
 
05/13/1981APPLICABILITY OF 261.33 TO DISCARDED PRODUCTSMemo
 Description: CCPs are not solid wastes until the decision is made to discard them. Pharmaceutical chemical (U245) becomes a hazardous waste at the point the decision is made to discard (after returned to manufacturer) (reverse distribution system).
 
05/07/1981APPICABILITY OF 261.33(F) LISTING TO SEWER AND CESSPOOL ADDITIVES CONTAINING ORTHODICHLOROBENZENEMemo
 Description: Use of orthodichlorobenzene (U070) to unclog sewer pipes and septic tanks is not disposal of unused CCP and is not listed. CCPs are not hazardous waste until they are discarded. Normal use is not disposal. Organic solvents in cesspool/ sewer lines may contaminate groundwater and soil.
 
03/12/1981MANUFACTURING WASTE CONTAINING COMMERCIAL CHEMICAL PRODUCTS IN 261.33Memo
 Description: P-listed and U-listed CCPs are products usually containing high concentrations of toxics or pesticides of high toxic activity. 261.33 does not include all process wastes due to the problems of establishing de minimis concentration thresholds. Process wastes that contain P-listed and U-listed chemicals are not P-listed or U-listed.
 
11/18/1980ASBESTOS AS A HAZARDOUS WASTEMemo
 Description: Technical grade asbestos is a U-listed hazardous waste (SUPERSEDED: see 45 FR 78532; 11/25/80).
 
11/18/1980REGULATION OF RINSATE FROM TRIPLE RINSING OF CONTAINERSMemo
 Description: Mixture created by rinsing listed CCP from container with washwater is hazardous waste via the mixture rule. Container rinsewater is solid waste because it is discarded. (SEE ALSO: RPC# 7/21/89-01)
 
11/17/1980RAILROAD TIES AS HAZARDOUS WASTES UNDER THE MIXTURE RULE, SMALL QUANTITY GENERATORMemo
 Description: Products that contain listed CCPs, such as railroad ties or asbestos insulation, are not listed CCPs when they are discarded. The mixture rule applies to CCPs being mixed with solid wastes. The point of generation for a CCP is “instantly when the act of discarding takes place.” Incorporating CCPs like creosote and asbestos into a product is not mixing with solid waste. A company with several operations on one site is a single generator. Even if each operation qualified as an SQG, the total site waste production may make all operations LQGs. If a facility is an LQG, all wastes must be handled as LQG waste, even wastes that are produced in small quantities or intermittently (SUPERSEDED: see current 261.5, 262.34(d)).
 
09/04/1980COMMERCIAL CHEMICAL PRODUCTS UNDER 261.33Memo
 Description: Wastestreams containing chemicals on the P-list and U-list are not P-listed or U-listed if the chemical is not an unused discarded product.
 
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