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Air Emissions (RCRA)
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Chemicals (RCRA)
	02/12/2009	Safe Chemical Management in Your School (Video)	Publication
	Description: This video, part of the Schools Chemical Cleanout Campaign (SC3), 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.
	11/01/2008	Building 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.
	11/01/2008	SC3: Protecting Students and Staff with Green Cleaning	Publication
	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.
	01/01/2007	Building Successful Programs to Address Chemical Risks in Schools: Recommendations from an Evaluation of Selected Schools Chemical Management Programs	Publication
	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 describes existing school chemical management programs that have been implemented to improve the learning environment for children and to provide a healthy workplace for teachers and staff, factors that contributed to the success of these programs, barriers that had to be overcome, and the major recommendations drawn from the experiences of the program implementers themselves.
	01/01/2007	Building Successful Programs to Address Chemical Risks in Schools: State, Tribal, and Local School Chemical Cleanout Programs Matrix and Summaries	Publication
	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.
	01/01/2007	Industry Leaders Are Part of the Solution	Publication
	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.
	01/01/2007	Schools Chemical Cleanout Campaign	Publication
	Description: This document describes the Schools Chemical Cleanout Campaign (SC3), which promotes the removal of unneeded, excessive, or dangerously mismanaged chemicals from K-12 schools.
	01/01/2006	Chemicals in Schools: Partner for Healthy School Environments	Publication
	Description: This document describes ways that community partners, such as chemical suppliers, waste handlers, fire and police departments, colleges and universities, and government agencies, can help schools develop a chemical cleanout program.
	01/01/2006	Chemicals in Schools: Solutions for Healthy School Environments	Publication
	Description: This document describes ways that school leaders, such as administrators, teachers, facilities and maintenance staff, nurses, and parents, can help develop a school chemical cleanout and prevention program.
	05/16/2002	REGULATORY 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).
	07/24/2001	RECYCLING OF PETROLEUM VAPORS AND LIQUID CONDENSATE FROM PETROLEUM PRODUCT STORAGE TERMINALS	Memo
	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.
	08/07/2000	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.
	02/19/1999	REGULATORY STATUS OF PETROLEUM PRODUCT CONTAINED IN ABSORBENT PADS	Memo
	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).
	07/24/1997	REGULATORY DETERMINATION ON THE STATUS OF CERTAIN MANUFACTURING WASTES	Memo
	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.
	06/01/1997	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.
	04/07/1997	VACATED DITHIOCARBAMATE LISTING - CERCLA SECTION 103(A) STATUS	Memo
	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.
	04/01/1997	Draft Prioritized Chemical List	Publication
	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.
	08/01/1996	DEFINITION OF COMMERCIAL CHEMICAL PRODUCT FOR SOLID WASTE DETERMINATION VS. HAZARDOUS WASTE IDENTIFICATION	Question & 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.
	06/01/1996	HAZARDOUS WASTE LIQUID-CONTAINING PUMPS AND THE LIQUIDS IN LANDFILLS PROHIBITION	Question & 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.
	02/27/1996	CLARIFICATION OF THE ""MIXTURE RULE,"" THE ""CONTAINED-IN"" POLICY, LDR ISSUES, AND ""POINT OF GENERATION"" FOR U096	Memo
	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).
	02/15/1996	USE OF USED OIL AS A DUST SUPPRESSANT	Memo
	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.
	09/01/1995	ISOMERS OF P- AND U-LISTED WASTES	Question & 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.
	08/24/1995	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.
	02/17/1995	EPA'S CURRENT CONTAINED-IN POLICY AS IT APPLIES TO ENVIRONMENTAL MEDIA THAT CONTAIN P- AND U-LISTED HAZARDOUS WASTES	Memo
	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.
	02/15/1995	Environmental Fact Sheet: EPA Finalizes Listing of Wastes from the Production of Carbamates and Adds 58 Chemicals to the Off-Specifications Product List	Publication
	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.
	01/15/1995	CMA/EPA BIF Workshop; Edited Transcript	Publication
	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.
	12/01/1994	EPINEPHRINE RESIDUE IN A SYRINGE IS NOT P042	Question & 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.
	09/14/1994	EXPORT FROM JAPAN OF PHOSPHORUS OXYCHLORIDE CONTAINING BUBBLERS	Memo
	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.
	06/08/1994	APPLICABILITY OF 261.33 TO DIETHYLHEXYL PHTHALATE-CONTAINING CAPACITORS FROM FLUORESCENT LIGHT BALLASTS	Memo
	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.
	04/13/1994	STATUS OF BERYLLIUM DUST, PO15	Memo
	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.
	03/01/1994	OFF-SPECIFICATION PARAFORMALDEHYDE MEETS COMMERCIAL CHEMICAL PRODUCT LISTING	Question & 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.
	09/20/1993	DISCARDED OFF-GAS PIPING, EQUIPMENT, AND OFF-GAS SCRUBBER SOLUTION FROM A TANK SYSTEM	Memo
	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.
	09/01/1993	NITROGLYCERINE PILLS AS COMMERCIAL CHEMICAL PRODUCTS	Question & 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.
	07/28/1993	TRIPLE-RINSING REQUIREMENT APPLICABLE TO CONTAINERS HOLDING RESIDUES FROM THE INCINERATION OF ACUTE HAZARDOUS WASTES	Memo
	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.
	11/02/1992	REGULATORY STATUS OF BERYLLIUM-CONTAMINATED EQUIPMENT	Memo
	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).
	11/01/1992	BERYLLIUM DUST (P015); APPLICABILITY	Question & Answer
	Description: The P015 listing only applies to beryllium dust (SUPERSEDED: See current Section 261.33(e) where listing now reads “Beryllium powder”).
	11/01/1992	RECLAIMED COMMERCIAL PRODUCTS: REGULATORY STATUS	Question & Answer
	Description: Reclaimed creosote is classified as U051 if discarded. Creosote-contaminated soil is regulated as hazardous waste because it contains U051.
	10/15/1992	REGULATORY STATUS OF SOILS CONTAMINATED FROM RELEASES OF COMMERCIAL CHEMICAL PRODUCTS	Memo
	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.
	08/24/1992	STATUS OF CYCLOPHOSPHAMIDE AS A HAZARDOUS WASTE	Memo
	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.
	04/15/1992	Batch-Type Procedures for Estimating Soil Adsorption of Chemicals; Technical Resource Document	Publication
	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.
	03/01/1992	COMMERCIAL CHEMICAL PRODUCT DEFINITION IN §261.33	Question & 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.
	04/12/1991	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).
	02/15/1991	Environmental Fact Sheet: Interim Final Rule Suspending Application of the Toxicity Characteristic for Used Chlorofluorocarbon Refrigerants Being Reclaimed	Publication
	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.
	01/29/1991	TECHNICAL AMENDMENT TO LIST OF COMERCIAL CHEMICAL PRODUCTS IN 40 CFR 261.33 AND LIST OF HAZARDOUS CONSTITUENTS IN APPENDIX VIII	Memo
	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.
	08/20/1990	REGULATORY STATUS OF MANUFACTURING PROCESS WASTE WITH XYLENE AND PESTICIDE CONSTITUENTS	Memo
	Description: The presence of xylene and pesticide constituents in manufacturing process waste does not necessarily trigger the hazardous waste listings.
	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).
	05/01/1990	HAZARDOUS WASTE IDENTIFICATION	Question & 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.
	04/05/1990	DIMETHYL BENZENE-LISTING CLARIFICATION	Memo
	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.
	03/29/1990	INCINERATOR RESIDUES FROM TRIAL BURN	Memo
	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.
	02/14/1990	END-USERS OF CHLORDIMEFORM EXEMPTION	Memo
	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.
	02/09/1990	DINOSEB FORMULATIONS, REGULATORY STATUS	Memo
	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.
	11/01/1989	40 CFR SECTION 261.33: SPILLS OF COMMERCIAL CHEMICAL PRODUCTS	Question & Answer
	Description: Section 261.33(d) applies to all spill residues regardless of where the spill occurs.
	10/05/1989	WASTE CODE LISTINGS AND TECHNICAL CORRECTIONS	Memo
	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.
	09/28/1989	OFF-SPEC COMMERCIAL CHEMICAL PRODUCTS AT BOTTLING FACILITY	Memo
	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).
	08/21/1989	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.
	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.
	06/23/1989	REGULATION OF CANCELLED PESTICIDES	Memo
	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).
	03/20/1989	REGULATORY STATUS OF CANCELLED HERBICIDE DINOSEB	Memo
	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.
	03/17/1989	BERYLLIUM WASTE DUST	Memo
	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.
	03/14/1989	PESTICIDE STANDARDS FOR FORMALDEHYDE AND PARAFORMALDEHYDE	Memo
	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.
	03/10/1989	CHARACTERIZATION OF BERYLLIUM WASTES	Memo
	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.
	11/02/1988	WASTE LISTINGS FOR COMMERCIAL CHEMICAL PRODUCTS - MERCURY	Memo
	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)
	09/30/1988	AEROSOL CANS, ON-SITE DEPRESSURIZATION OF	Memo
	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).
	07/21/1988	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).
	05/19/1988	DISCARDED COMMERCIAL CHEMICAL PRODUCTS	Memo
	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.
	05/03/1988	CHLORDANE AND HEPTACHLOR PESTICIDE WASTE	Memo
	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.
	04/25/1988	REGULATORY STATUS OF ANTINEOPLASTIC DRUG WASTES	Memo
	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.
	03/14/1988	ECOSCINT A & ECOSCINT O	Memo
	Description: Ecoscint A and Ecoscint O are not listed. They would be hazardous waste if they exhibit a characteristic.
	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.
	01/14/1988	WASTE GENERATED BY AN INCINERATOR TRIAL BURN OF SAND SPIKED WITH TRICHLOROBENZENE AND HEXACHLOROETHANE	Memo
	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.
	09/09/1987	MATERIALS CONTAMINATED WITH PESTICIDE PRODUCTS	Memo
	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.
	06/17/1987	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.
	06/16/1987	CONTAINERS USED TO HOLD LISTED CHEMOTHERAPY DRUGS	Memo
	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.
	05/18/1987	CARBON SCRUBBER WASTES IN WHICH PRODUCT MATERIALS ARE CAPTURED	Memo
	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.
	05/18/1987	SPENT CARBON REGULATION	Memo
	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.
	05/13/1987	PACKAGES CONTAINING RESIDUAL URETHANE COATING CHEMICALS	Memo
	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.
	03/11/1987	CONTAMINATED GROUNDWATER, REGULATORY STATUS OF	Memo
	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.
	12/08/1986	COMMERCIAL CHEMICAL PRODUCT P LISTING APPLIES ONLY TO UNUSED PRODUCT, NOT USED RESIDUES	Memo
	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.
	12/05/1986	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.
	11/03/1986	FLOATING PLASTIC BALLS USED TO CONTROL VAPORS FROM TANKS CONTAINING LISTED PRODUCT	Memo
	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.
	09/15/1986	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.
	09/04/1986	REJECT SUBSTRATES CONTAINING VENADIUM PENTOXIDE REGULATION UNDER RCRA	Memo
	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.
	08/21/1986	RELISTING HAZARDOUS WASTE	Memo
	Description: EPA intends to redefine hazardous waste listings by.
	06/03/1986	REQUEST FOR COMMENT ON MEMORANDUM CONCERNING THE CLEANUP OF RESIDUES OF COMMERCIAL CHEMICAL PRODUCTS WITHIN A WAREHOUSE STORAGE AREA	Memo
	Description: Listed or characteristic CCPs spilled in a warehouse are subject to RCRA Subtitle C regulation unless immediately cleaned up.
	05/06/1986	HEALTH ASSESSMENT INFORMATION IN LISTING DECISIONS; LISTING OF TF-1, AN ELECTRICAL TRANSFORMER FLUSHING AGENT	Memo
	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.
	05/01/1986	FORMALDEHYDE-BASED TOILET DEODORANTS	Memo
	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.
	04/02/1986	MERCURY THERMOMETERS, RECLAIMED OFF-SPEC AND BROKEN	Memo
	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.
	01/30/1986	ANTI-NEOPLASTIC AGENTS IN HOSPITAL WASTES, DISPOSAL OF	Memo
	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.
	12/13/1985	PESTICIDE APPLICATOR WASHING RINSE WATER	Memo
	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.
	11/01/1985	SOLVENT MIXTURE RULE	Question & 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.
	09/10/1985	DIOXIN-CONTAINING WASTE RINSEATES, DISPOSAL BY DEEP WELL INJECTION	Memo
	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).
	07/22/1985	PESTICIDE APPLICATOR WASHING RINSEWATER	Memo
	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).
	06/27/1985	SCRAP DEHP AND SMALL CAPACITORS CONTAINING DEHP, DISPOSAL REQUIREMENTS FOR	Memo
	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.
	05/17/1985	EMBALMING FLUIDS, USED	Memo
	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.
	05/14/1985	DISCARDED COMMERCIAL CHEMICAL PRODUCTS	Memo
	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.
	05/01/1985	SOLID WASTE DETERMINATION - ACRYLONITRILE ASH	Question & 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.
	04/10/1985	PERCHLOROETHYLENE AND SURFACTANT, DISTILLATION OF RESIDUE CONTAINING	Memo
	Description: Product perchloroethylene mixed with surfactant is still the CCP U210. CCPs being reclaimed are not solid wastes. The residue from distillation is hazardous.
	04/05/1985	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.
	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).
	01/16/1985	COMMERCIAL CHEMICAL PRODUCTS USED IN AIR BAGS - EFFECT ON RECYCLE OF FERROUS SCRAP FROM AUTOMOBILES	Memo
	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.
	12/26/1984	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.
	11/29/1984	CORROSIVE SOLIDS, COMMERCIAL CHEMICAL PRODUCTS, REACTIVE WASTES DEFINED	Memo
	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).
	09/20/1984	DIBUTYLTIN DIFLUORIDE NOT A LISTED RCRA WASTE	Memo
	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.
	08/01/1984	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.
	06/06/1984	DEODORANTS FOR PORTABLE TOILETS	Memo
	Description: Formaldehyde is not the sole active ingredient in portable toilet deodorants, and they are not listed hazardous waste.
	05/30/1984	BALLAST FLUID CLASSIFICATION	Memo
	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.
	03/01/1984	XYLENE (U239) SPILLED ONTO SOIL	Question & 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).
	11/01/1983	SALTS AND ESTERS OF P- AND U-LISTED WASTES	Question & 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).
	11/01/1983	USED COMMERCIAL CHEMICAL PRODUCT	Question & 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.
	08/01/1983	ANTINEOPLASTIC DRUGS	Question & Answer
	Description: Discusses U-listed antineoplastic (anticancer) drugs, including Cyclophosphamide (Cytoxin), Daunomycin, Melphalan, Mytomycin C, Streptozotocin.
	03/12/1983	CLARIFICATION OF REGULATORY STATUS OF MANUFACTURING WASTES CONTAINING COMPOUNDS LISTED IN 261.33	Memo
	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.
	02/01/1983	BENZENE LEAK INTO GROUNDWATER	Question & 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.
	02/01/1983	SOLUBLE CYANIDE SALTS	Question & Answer
	Description: P030 applies only to compounds that form hydrogen cyanide (HCN) when exposed to acidic conditions.
	09/18/1981	PESTICIDES CONTAINING A 261.33(E) COMPOUND AS A SOLE ACTIVE INGREDIENT	Memo
	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.
	06/19/1981	P-WASTE LISTING FOR CATALYST	Memo
	Description: The P120 listing applies to all oxides of vanadium's +5 oxidation state.
	05/13/1981	APPLICABILITY OF 261.33 TO DISCARDED PRODUCTS	Memo
	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).
	05/07/1981	APPICABILITY OF 261.33(F) LISTING TO SEWER AND CESSPOOL ADDITIVES CONTAINING ORTHODICHLOROBENZENE	Memo
	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.
	03/12/1981	MANUFACTURING WASTE CONTAINING COMMERCIAL CHEMICAL PRODUCTS IN 261.33	Memo
	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.
	11/18/1980	ASBESTOS AS A HAZARDOUS WASTE	Memo
	Description: Technical grade asbestos is a U-listed hazardous waste (SUPERSEDED: see 45 FR 78532; 11/25/80).
	11/18/1980	REGULATION OF RINSATE FROM TRIPLE RINSING OF CONTAINERS	Memo
	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)
	11/17/1980	RAILROAD TIES AS HAZARDOUS WASTES UNDER THE MIXTURE RULE, SMALL QUANTITY GENERATOR	Memo
	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)).
	09/04/1980	COMMERCIAL CHEMICAL PRODUCTS UNDER 261.33	Memo
	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.
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
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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