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Show details for Air Emissions (RCRA)Air Emissions (RCRA)
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09/10/2014RESPONSE TO QUESTIONS ON PROCESSED CATHODE RAY TUBE (CRT) GLASS USED AS ALTERNATIVE DAILY COVERMemo
 Description: Grinding and stabilizing cathode ray tube (CRT) glass, a D008 hazardous waste, is considered treatment. Treatment of hazardous waste generally requires a RCRA Part B permit; however, a permit would not be required for treatment of CRT glass if such treatment is conducted by the generator of the hazardous CRT glass in compliance with applicable 40 CFR 262.34 generator requirements, as well as the Part 268 land disposal restrictions (LDRs), and the treatment is not thermal treatment. EPA Method 1311 must be used on CRT glass to determine compliance with the LDR treatment standards, and any underlying hazardous constituents in the CRT glass must be treated to attain the universal treatment standards in 268.48. If CRT glass is not excluded as a solid waste under 261.2(e)(1)(ii) or 261.4(a)(22), then that CRT glass would be subject to solid and hazardous waste regulations at the point of generation. The point of generation for CRT glass would be when a person decides to discard the glass and it becomes a solid waste, and the person making the decision is the generator of solid waste. CRT glass that has been treated in accordance with LDRs and that no longer exhibits hazardous characteristics may be disposed in a municipal or Subtitle D landfill, including use of treated CRT glass as alternative daily cover.
 
11/20/2012REGULATORY STATUS OF A WATER-SOLVENT CLEANING SOLUTIONMemo
 Description: In a situation where a waste phase separates (biphasic solution), the generator must make the hazardous waste determination not only at the point of generation, but also after the waste separates into phases. A generator may use either knowledge or testing to determine if a waste exhibits a characteristic. The COLIWASA sampling protocol can be used to sample each phase in a multi-phasic solution. Separating or physically removing the water phase from the ignitable solvent phase is considered treatment. Generators may treat their hazardous waste without a permit or interim status in accumulation tanks and containers that are managed in compliance with the generator accumulation provisions of 40 CFR 262.34.
 
01/01/2008Test Methods for Evaluating Solid Waste; Physical/Chemical Methods (SW-846)Publication
 Description: This document is the official compendium of analytical and sampling methods that have been evaluated and approved for use in complying with the RCRA regulations. SW-846 functions primarily as a guidance document setting forth acceptable, although not required, methods for the regulated and regulatory communities to use in responding to RCRA-related sampling and analysis requirements. To date, EPA has finalized Updates I, II, IIA, IIB, III, IIIA, IIIB, IVA and IVB to the Third Edition of SW-846 manual.
 
10/18/2005USE OF SW-846 METHODS 8081A, 8310, AND 6010Memo
 Description: Provides questions and answers discussing the following SW-846 test methods: 8081A for organo-chloride, 8310 for other pesticides analysis, and 6010 for analysis of metals. It is not appropriate to use method 8081A or 8310 to extract and determine pesticide residues (residues meaning parent and degradates) because the methods are not extraction methods. Method 6010 is not adequate for extraction of metals because it is not an extraction method.
 
02/01/2005Environmental Fact Sheet: Hazardous Waste SW-846 Process StreamlinedPublication
 Description: This fact sheet summarizes the final Methods Innovation Rule. The rule clarifies the difference between SW-846 methods that are required and those that are guidance methods in the regulations. In addition, some required uses of SW-846 methods remain regulated in situations where a particular procedure is the only one capable of properly measuring for sampling and analysis, known as a method-defined parameter. The rule also finalizes Update IIIB to the Third Edition of SW-846, removes unnecessarily required uses of Chapter Nine, and amends Chapter Seven to withdraw the cyanide and sulfide reactivity guidance.
 
09/20/2004METHODS INNOVATION RULE (MIR) AND RCRA WASTE SAMPLING DRAFT TECHNICAL GUIDANCE (TG) MODIFICATIONSMemo
 Description: The EPA released the RCRA Waste Sampling Draft Guidance (TG) simultaneously with the Methods Innovation Rule (MIR) for public review and comment. The Agency will be revising the draft document, and the MIR final rule is on a separate track than the finalization of the draft sampling guidance. Until a final guidance document is published, Chapter Nine is the applicable guidance.
 
01/20/2004SEMI-VOLATILE CONSTITUENT ANALYSIS AND ANALYTICAL LEVEL OF DETECTION LIMITATIONS OF THE TOXICITY CHARACTERISTIC LEACHING PROCEDURE (TCLP)Memo
 Description: A generator may use process knowledge regarding how a waste is generated and scientific knowledge regarding chemical reactions to identify the constituents of concern for analysis. It is not necessary to test for all TCLP consitituents if the waste is determined to be nonhazardous using process knowledge. If a waste is 100% solid as defined by TCLP method 1311, the results of the total constituent analysis may be divided by twenty to convert the total results into the maximum leachable concentration. If it is a filterable liquid, then the concentration of each analyte phase must be determined.
 
05/19/2003FLASH POINT TESTING OF A WASTE FIBROUS FILTER MATERIALMemo
 Description: Only liquid wastes are evaluated for ignitability using the flash point test in 261.21(a)(1). Non-liquid wastes, such as fibrous filter material, are assessed for ignitability using the narrative criteria found in 261.21(a)(2). No specific federal test has been developed for determining the ignitability of non-liquid wastes. State implementing agencies may have tests or guidance for determining non-liquid waste ignitability.
 
08/01/2002RCRA Waste Sampling Draft Technical GuidancePublication
 Description: This guidance was announced in the October 30, 2002 Methods Innovation Proposed Rule as a replacement for the current sampling guidance version of Chapter Nine found in EPA publication SW-846. The Agency received a number of comments on the proposed revision which are still under review and consideration. This review of the document will help EPA improve the guidance and ensure that it is most useful in its final form, but EPA is not at this time issuing the Technical Guidance. Upon completion of the review and evaluation of the comments, EPA will revise the document as appropriate and announce its availability in the Federal Register. Upon completion, the new guidance will update information regarding sampling activities which is currently provided in Chapter Nine of SW-846, which was last published in 1986. Until the completion of the Technical Guidance, Chapter Nine will remain the applicable guidance.
 
02/13/2002STATUS OF UPDATE IVB TO SW-846Memo
 Description: EPA released SW-846 Update VIB in a notice of availability, which made the methods immediately available for use by the public. As a result of using the notice, a final rulemaking is not needed. Use of SW-846 Update VIB methods is restricted only in those limited cases where EPA regulations specify use of prior SW-846 methods.
 
11/01/2001USED OIL SPECIFICATIONS FOR METALS: TCLP VERSUS TOTALS ANALYSISQuestion & Answer
 Description: It is not appropriate to use the TCLP to determine if used oil that will be burned for energy recovery meets the §279.11 specification levels for metals. A totals analysis should be performed on the used oil in lieu of the TCLP. Chapter Two of SW-846 offers guidance on selecting appropriate test methods for specific constituents in different matrices, such as used oil.
 
10/30/2001ENVIRONMENTALLY AND ECOLOGICALLY SENSITIVE AREAS Memo
 Description: EPA provides, as a public service, information on the Internet regarding environmentally sensitive areas, test methods for solid wastes, and information about air and water. The document Sensitive Environments and the Siting of Hazardous Waste Management Facilities, May 1997 discusses sensitive types of environments that pose special challenges to the siting, expansion, and operation of hazardous waste management facilities. The Office of Solid Waste (OSW) web page provides links to a variety of methods-related information.
 
07/31/2000REGULATORY STATUS OF WASTE GENERATED BY CONTRACTORS AND RESIDENTS FROM LEAD-BASED PAINT ACTIVITIES CONDUCTED IN HOUSEHOLDSMemo
 Description: Lead-based paint (LBP) debris generated by contractors in households is excluded household hazardous waste. LBP waste from abatement, renovation, and remodeling in homes and other residences eligible for exclusion. LBP waste from households may be subject to state, local and/or tribal government regulation (SEE ALSO: 63 FR 70233; 12/18/1998).
 
05/25/2000TOTAL WASTE ANALYSIS ON POTW BIOSOLIDS AND CERCLA LIABILITYMemo
 Description: Generator must determine if waste exhibits toxicity characteristic (TC) by testing or applying knowledge. Using total constituent concentrations in waste is one type of generator knowledge. EPA does not presume waste is TC hazardous if 1/20th the total constituent concentrations in waste exceed TC regulation levels. RCRA Online letters do not constitute EPA policy. Domestic sewage exclusion would not exonerate sewage generators from potential liability under CERCLA 107(a)(3) if the generators’ discharges include CERCLA hazardous substances. A generator may be shielded from liability due to federally permitted release statutory provisions in CERCLA 107(j). Placement of biosolids on land may constitute normal application of fertilizer in CERCLA 101(22)(D) and exempt the generator from liability;. To evaluate normal application of fertilizer, EPA would consider, among other things, compliance with Clean Water Act 405(d) and application rates.
 
12/09/1999AGENCY ACTIVITIES IN RESPONSE TO THE 1996 HAZARDOUS WASTE CHARACTERISTICS SCOPING STUDYMemo
 Description: Hazardous Waste Characteristics Scoping Study identified a number of potential gaps in the hazardous characteristics regulatory program. EPA describes potential gaps and efforts to further address them. Discusses the release of final Air Characteristic Study report; review of TCLP test and concerns regarding alkaline waste and oily waste. Work on replacement guidance for withdrawn sulfide and cyanide reactivity test guidance proceeding at low level of activity due to competing priorities. Discusses development of tools for evaluation of ecological risks from waste.
 
12/08/1999INTERPRETATION OF THE RCRA IGNITABILITY CHARACTERISTIC WITH REGARD TO ACETONE WIPESMemo
 Description: Whether solvent-contaminated rags, wipers, or towels contain a listed hazardous waste, are mixed with a listed hazardous waste, only exhibit a characteristic, or are not a waste at all depends on site-specific factors best evaluated by Region or State implementing agency (SEE ALSO: RPC# 2/14/94-01). ASTM Method D4982-89, Method A is not appropriate for determining ignitability. Method 1030 assesses a solids tendency to burn vigorously and persistently, but does not address the mode of ignition. Ignitability for non-liquids should be determined using generator knowledge.
 
11/09/1999Method Precision and the MACT RuleMemo
 Description: EPA believes that emissions variability, including method precision, have been appropriately addressed in Hazardous Waste Combustion Maximum Achievable Control Technology (HWC MACT) rule and supporting documents.
 
03/01/1999Calling All New MethodsPublication
 Description: This fact sheet briefly explains how the Methods Team supports the development of new measurement technologies, and how to apply to have a method published in SW-846. This fact sheet is included in the series Monitoring Science in the RCRA Program (EPA530-E-99-001).
 
03/01/1999Introducing the Methods TeamPublication
 Description: This fact sheet provides details on the activities of the methods team, the focal point within OSW for expertise in analytical chemistry and characteristic testing methodology, environmental monitoring, and quality assurance. This fact sheet is included in the series Monitoring Science in the RCRA Program (EPA530-E-99-001).
 
03/01/1999Monitoring Science in the RCRA Program Publication
 Description: This series of fact sheets provides details on the activities of the methods team, the focal point within OSW for expertise in analytical chemistry and characteristic testing methodology, environmental monitoring, and quality assurance. The series includes information on Test Methods for Evaluating Solid Waste: Physical/Chemical Methods (SW-846), a multi volume compendium of EPA-accepted methods and monitoring guidance; the annual Waste Testing and Quality Assurance Symposium; and the Methods Information Communication Exchange Service, a hotline providing answers to questions and taking comments over the telephone on technical issues regarding the test methods compendium. The fact sheets also address performance-based measurement systems in the RCRA program and the OSW methods development, evaluation, and approval process.
 
03/01/1999ResourcesPublication
 Description: This fact sheet summarizes the availability of SW-846, Test Methods for Evaluating Solid Waste, Physical/Chemical Methods. This fact sheet is included in the series Monitoring Science in the RCRA Program (EPA530-E-99-001).
 
03/01/1999The Methods Information Communication Exchange (MICE) ServicePublication
 Description: This fact sheet reviews how to use the Methods Information Communication Exchange (MICE) Hotline. This fact sheet is included in the series Monitoring Science in the RCRA Program (EPA530-E-99-001).
 
08/07/1998CLARIFICATION REGARDING USE OF SW-846 METHODSMemo
 Description: SW-846 contains the analytical and test methods that EPA has evaluated and found to be among those acceptable for testing under Subtitle C. In most situations, SW-846 functions as guidance setting forth acceptable, although not required, methods. The methods are intended to be used and modified as needed. In addition, with the exception of method-defined parameters (e.g., TCLP) the methods need not be applied in a prescriptive manner. Advances in analytical instrumentation and techniques are continually reviewed by the Agency and periodically incorporated into SW-846. Attachments describe clarifications to certain SW-846 Final Update III methods.
 
05/26/1998USE OF METHOD 5035 OF SW-846Memo
 Description: In most situations, SW-846 functions as guidance setting forth acceptable, although not required, methods. Method 5035 was developed to improve accuracy of measuring volatile organic compounds lost through sample handling. Method 5035 was reviewed as part of Update III.
 
05/21/1998NOTICE OF INTENT TO REFORM IMPLEMENTATION OF RCRA-RELATED MONITORING AND NOTICE OF AVAILABILITY FOR PRELIMINARY UPDATE IVA OF SW-846 (""TEST METHODS FOR EVALUATING SOLID WASTE PHYSICAL/CHEMICAL METHODS"")Memo
 Description: OSW intends to reform implementation of RCRA-related monitoring by formally adopting a performance based measurement system (PBMS) (SEE ALSO: 63 FR 25430; 5/8/98). Implementation will include a proposal to change the regulations so that exclusive use of SW-846 will no longer be required. Preliminary Update IVA to SW-846 adds several new methods and revises other methods.
 
02/11/1998CHARACTERIZATION OF NITROCELLULOSE FILTER FABRIC WASTEMemo
 Description: Test Method 1030, although not required, may be a useful procedure to determine if a solid burns vigorously and persistently, the second component of the ignitability characteristic for solids. There are no reactivity characteristic test procedures for nitrocellulose filter fabric. This letter provides representative sampling guidance for nitrocellulose filter fabric. A statistician may be necessary to establish the level of confidence needed to make a decision regarding the entire waste based on an individual grab sample.
 
08/14/1997REGULATORY STATUS OF USED NICKEL CATALYSTMemo
 Description: Discusses the regulatory status of spent catalyst being reclaimed. A material is reclaimed if it is processed to recover a usable product, or if it is regenerated. The hazardous waste determination is the generator’s responsibility. Determination is made by evaluating the waste using a required test or by comparing the properties of the waste with the narrative standard. A lack of required test for ignitability of solids and reactivity does not prohibit consideration of test data where there is reason to question the generator’s RCRA determination.
 
08/01/1997EFFECTIVE DATE OF UPDATE III TO SW-846Memo
 Description: The effective date of the final rule for Update III of SW-846 (62 FR 32452; 6/13/97) was immediate; however, since the update is guidance and does not have regulatory effect, regions and states are encouraged to use discretion concerning the effective date, possibly giving the labs and lab users six months to begin using the new methods. Labs attempting to utilize the methods added in Update III may need to purchase new equipment or make changes to their standard operating procedures. Update III encourages performance based flexibility.
 
07/24/1997EFFECTIVE DATE OF UPDATE III TO SW-846Memo
 Description: Update III to SW-846 became effective immediately. Full implementation of the methods may require substantial adjustments by the laboratory community. EPA suggests regional offices use discretion concerning the immediate effective date to allow affected parties time to comply. Labs may need to purchase new equipment or make changes to their standard operating procedures.
 
05/22/1997HOW IGNITABLE SOLIDS AND SOLVENT CONTAMINATED RAGS OR SHOP TOWELS FIT INTO D001 CHARACTERISTIC OF IGNITABILITYMemo
 Description: Solvent contaminated rags and towels may be hazardous waste if they exhibit a hazardous waste characteristic. EPA recommends that states or regional offices make such determinations on a site-specific basis. EPA does not currently have a method to determine the ignitability of solids (SUPERSEDED: Method 1030 introduced in 62 FR 32451; 6/13/97). In determining the ignitability of rags, consider the type and amount of solvent used, the type and number of rags used, and how the rags are stored. Solvent contaminated rags with no free liquids are still capable of exhibiting the ignitability characteristic (D001). Rags placed in a container can force free liquid into the bottom of the container through force of gravity. Rags placed in an environment with oxygen present may meet criteria in 261.21(a)(2).
 
04/01/1997TREATMENT STANDARDS FOR D008 RADIOACTIVE LEAD TANKS AND CONTAINERSQuestion & Answer
 Description: D008 radioactive lead solids that are tanks or containers must be treated using macroencapsulation. The placement of waste in a container or tank is not considered macroencapsulation. The owner/operator may use an alternative treatment method if demonstrated to be an equivalent technology.
 
03/01/1997GROUNDWATER MONITORING: APPENDIX IX SAMPLING AND OFF-SITE RELEASESQuestion & Answer
 Description: During groundwater monitoring, statistically significant evidence of a release of hazardous waste constituents from regulated units requires the owner or operator to immediately sample groundwater for Part 264, Appendix IX constituents. The owner or operator may demonstrate that the source of the release was off site, but must still sample for Appendix IX constituents if statistical method in permit validates evidence of release. A single failure of test does not necessarily constitute evidence. Owners or operators who wish to avoid sampling requirement for off-site releases may specify a statistical detection method which can indicate that release did not originate from the facility regulated units.
 
11/01/1996Environmental Fact Sheet: Assurance Mechanisms Finalized for Local Government Owners of MSWLFsPublication
 Description: The Local Government Financial Test was proposed December 27, 1993 in response to comments from local governments requesting flexibility in meeting the financial assurance requirements of the Solid Waste Disposal Criteria promulgated on October 9, 1991. The Test allows local governments to meet their financial assurance obligations for closure, postclosure care and corrective action pursuant to the Criteria by demonstrating their financial strength. The effective date for these financial assurance requirements is now April 9, 1997 (small, dry, or remote landfills have until October 9, 1997 to comply).
 
10/02/1996JOHNSTON ATOLL CHEMICAL AGENT DISPOSAL SYSTEM (JACADS) RISK RELATED ISSUESMemo
 Description: Discusses the draft site-specific combustion risk assessment, current method for assessing the non-carcinogenic risks associated with dioxin exposure, most appropriate data subsets for determining carcinogenic potency factors, methods for assessing the risks associated with exposure to either the sulfur or brominated analogs of dioxin, EPA’s treatment of putative compound synergistic interactions when applied to the facility assessment. EPA has not yet developed a methodology for quantitative assessment of risks due to exposures to potential endocrine disruptors.
 
07/12/1996MANAGEMENT AND DISPOSAL OF WASTE VINYL MINI BLINDSMemo
 Description: Toxicity characteristic (D008) lead-containing mini blinds are not solid waste if they are returned to the manufacturer for resale in a reverse distribution system. Blinds from homes, apartments, and hotels are exempt household hazardous waste (HHW). Waste from hospitals, offices, day care centers, and non-residential buildings at military bases are not HHW. HHW and non-HHW must be segregated. A generator can test waste or apply knowledge. The most conservative approach assumes that the blinds are hazardous waste (HW). The generator is vulnerable for enforcement for an incorrect determination if subsequent EPA testing reveals that the waste is HW.
 
04/01/1996ABILITY OF A HAZARDOUS WASTE BURNING BIF TO SPIKE METALS AND USE OF TEST DATA IN LIEU OF A TRIAL BURNMemo
 Description: EPA does not recommend spiking toxic metals at high concentrations during BIF trial burns. Burning waste fuels with high metals content in trial burns, compliance tests, or normal operations is an environmentally unsound practice. The Combustion Strategy recommends that toxic metals burned in hazardous waste combustors be addressed in a multi-pathway risk assessment under Section 3005(c)(3) omnibus authority. Decisions to allow the use of data in lieu of a trial burn or compliance test are made on a site-specific basis. Data-in-lieu of provisions are not intended to allow the elimination of retesting requirements.
 
03/21/1996USE OF FOURIER TRANSFORM INFRARED SPECTROSCOPY (FTIRS) FOR HEADSPACE GAS SAMPLING ANALYSIS AND CHARACTERIZATIONMemo
 Description: Fourier Transform Infrared Spectroscopy (FTIRS) for headspace gas sampling analysis (e.g., analysis for drum headspace Volatile Organic Compounds) will be included in the next proposed update of SW-846 as draft method 8450.
 
01/31/1996APPROPRIATE SELECTION AND PERFORMANCE OF ANALYTICAL METHODS FOR WASTE MATRICES CONSIDERED TO BE "DIFFICULT-TO-ANALYZE"Memo
 Description: This memo presents OSW’s position on waste matrices that industry considers to be “difficult to analyze”. Chemicals or materials that have been intentionally added under the claim of treatment (e.g., iron filings added to foundry sands) can cause interference with analysis. Proper selection of appropriate analytical method and analytical conditions are demonstrated by adequate recovery of spiked analytes and reproducible results. Analytical performance problems with difficult-to-analyze matrices can be corrected by using an alternative method or by modifying the analytical conditions.
 
01/26/1996LAND DISPOSAL RESTRICTIONS; PHASE IV SUPPLEMENTAL PROPOSAL ON MINERAL PROCESSING WASTESMemo
 Description: The Phase IV Bevill proposal (61 FR 2338; 1/25/96) would clarify the distinction between in-process materials and wastes in the Bevill exemption for mining and mineral processing wastes. The notice proposes retaining the TCLP and the classification of several wastes, including five smelting wastes that were previously lifted, iron chloride waste acid, and wastes from lightweight aggregate production. The notice proposes to exclude processed scrap metal and shredded circuit boards that are destined for metal recovery and managed in containers. The notice proposes to significantly reduce the land disposal restrictions (LDR) paperwork requirements that apply to hazardous waste generally (SEE ALSO: Phase IV Final Rule, 63 FR 28556; 5/26/98).
 
01/01/1996Como Obtener Acceso al Centro de Información sobre la RCRA (Spanish - How to Access the RCRA Information Center)Publication
 Description: This document is the Spanish version of How To Access the RCRA Information Center. It includes an outline of the services it provides, how it can be accessed, and a comprehensive list of additional EPA points of contact which provide additional information pertaining to solid and hazardous waste. These points of contact, for example, include the RCRA, Superfund, and EPCRA Hotline, the Test Methods Hotline, and the Superfund Docket.
 
09/19/1995CLARIFICATION OF THE CHARACTERISTIC OF IGNITABILITY AS IT PERTAINS TO SOLIDS VS. LIQUIDSMemo
 Description: Flash point test does not define solids as ignitable (D001), but may be used as evidence of the ignitability characteristic. There is no definitive test for ignitability of solids (SEE ALSO: SW-846 method 1030 finalized in 6/13/97; 62 FR 32451).
 
09/14/1995CLARIFICATION OF CIRCUMSTANCES INITIATING EPA'S ""MANIFEST DISCREPANCY"" PROCEDURESMemo
 Description: The manifest discrepancy regulations do not apply to waste which loses the corrosivity characteristic during transit (transportation). The manifest discrepancy regulations are intended for situations where the quantity of waste is unaccounted for. The manifest is not a certification that shipped waste is indeed hazardous. A generator can apply knowledge conservatively, rather than incur the costs of testing each waste batch or stream.
 
08/24/1995THE DIFFERENCE BETWEEN THE DEFINITION FOR THE CHARACTERISTIC OF IGNITABILITY AS IT PERTAINS TO SOLIDS VS. LIQUIDSMemo
 Description: There is no official method for testing ignitability of solids or sludges. Method 1010, Pensky-Martens, has some use for liquid wastes with non-filterable, suspended solids. Flash point testing is only appropriate for liquids. OSW developed and proposed SW-846 test method 1030 based on the DOT burn rate test in Section 173.124 and Appendix E (SUPERSEDED: SW-846 method 1030 finalized in 6/13/97; 62 FR 32451). If using the DOT method, separate the solid/liquid phases and test separately. Supplement tests with generator knowledge.
 
06/22/1995DETERMINATION ON WHETHER A GENERATOR'S FLUORESCENT TUBES ARE NONHAZARDOUSMemo
 Description: A generator is responsible for determining if a waste exhibits a characteristic. Testing one spent fluorescent mercury lamp tube to determine if all waste lamps exhibit the characteristic is not representative sampling. Selection of randomly chosen bulbs is more appropriate (see Chapter 9, SW-846). States authorized for the universal waste (UW) rule may add lamps to the state UW list and set management standards (SEE ALSO: 64 FR 36466; 7/6/99). The UW rule streamlines regulations for hazardous waste batteries (battery), pesticides, and mercury thermostats (SEE ALSO: 70 FR 45508; 8/5/05).
 
02/24/1995REGULATORY ISSUES PERTAINING TO WASTES CONTAMINATED WITH EXPLOSIVE RESIDUESMemo
 Description: Section 261.23(a)(8) should not be used because it references DOT regulations which have been changed. Debris/media mixed with explosives are reactive if they continue to exhibit a characteristic. The Bureau of Alcohol, Tobacco, and Firearms (BATF) methods may be used to determine reactivity for Section 261.23(a)(6) and (7), but would not be enforceable.
 
02/10/1995CLARIFICATION OF THE LDR PHASE II REGULATION THAT APPEARED IN THE FEDERAL REGISTER ON SEPTEMBER 19, 1994Memo
 Description: SW-846 need not be used to demonstrate compliance with the universal treatment standards (UTS). When organic waste are combusted, nondetect values within an order of magnitude of UTS are acceptable. Notification for F001-F005, F039, D001, D002, D012-43 must include the constituents to be monitored if monitoring will not involve all UTS constituents.
 
01/26/1995CHARACTERIZATION OF WASTE STREAMS FROM POLYMERIC COATING OPERATIONSMemo
 Description: Manufacturing process units may include distillation columns, flotation units, or discharge trays or screens. Rags and wipers can only be defined as listed if they contain a hazardous waste. If a rag or wiper contains a listed waste, it is a hazardous waste via the contained-in policy or it is considered mixed with a listed hazardous waste (SEE ALSO: 2/14/94-01). The final regulatory determination for wipers should be made by the State or Regional office. No test method has been promulgated for spontaneous combustion. A generator is responsible for comparing properties of his/her waste with the narrative definition. The Paint Filter Liquids test is the current test to determine whether a material contains a liquid for the characteristic of ignitability (D001).
 
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.
 
12/15/1994Technical Document: Acid Mine Drainage PredictionPublication
 Description: Examines acid generation prediction methods as they apply to noncoal mining sites. Reviews acid forming processes at mine sites. Summarizes current methods used to predict acid formation, including sampling, testing, and modeling. Presents case histories from active mining sites and sites on the National Priorities List.
 
10/12/1994CLARIFICATION ON WHETHER OR NOT A LABORATORY MUST USE THE ""SW-846 'A' ORGANIC METHODS"" WHICH WERE RECENTLY PROMULGATEDMemo
 Description: Any reliable analytical test method may be used to meet the requirements of Parts 260 through 270 which do not require the use of a specific method or application. Chapter 2 of SW-846 allows flexibility in using SW-846 methods.
 
10/07/1994ABILITY TO PASS THE RCRA FINANCIAL TEST FOR ENVIRONMENTAL OBLIGATIONSMemo
 Description: A firm may use the delayed recognition method for RCRA financial test even though it uses the immediate recognition method in accounting for purposes of SEC compliance. A firm’s Chief Financial Officer (CFO) may sign the certification.
 
09/14/1994QUALIFICATIONS NECESSARY TO PERFORM ENVIRONMENTAL REMEDIATION TASKSMemo
 Description: Discusses the methods for demonstrating that someone is a qualified groundwater scientist. The principles of the qualified groundwater scientist definition can be applied to related scientific disciplines such as environmental engineering. RCRA does not regulate the contents of a professional engineering certification.
 
07/26/1994DETERMINATION ON THE LEGALITY AND APPROPRIATENESS OF USING INCINERATION FOR TWO P078 WASTE STREAMSMemo
 Description: The land disposal restrictions (LDR) treatment standard for P078 is ADGAS. Liquid P078 absorbed onto debris or into a rinsate liquid meets the standard. An equivalent method variance is not necessary in such cases. Residues from incineration are subject to the treatment standards.
 
07/14/1994TREATMENT STANDARD FOR K106 (LOW MERCURY SUBCATEGORY) NON-WASTEWATER RESIDUES FROM RETORTING/ROASTING (RMERC) UNITSMemo
 Description: K106 low mercury subcategory residues from retorting/roasting units will need further treatment if the residues exceed the mercury TCLP level.
 
04/01/1994FINANCIAL ACCOUNTING STANDARDS BOARD STATEMENT 106 AND ITS AFFECTS ON THE RCRA FINANCIAL TESTMemo
 Description: A firm may use the delayed recognition method for the RCRA financial test even though it uses the immediate recognition method in its accounting for purposes of SEC compliance. The firm’s Chief Financial Officer (CFO) may sign the certification.
 
03/10/1994ISSUES CONCERNING THE COMPARISON OF SFE EXTRACTION RESULTS TO THOSE OBTAINED USING SONICATION(3550) RATHER THAN SOXHLET(3540,3541)Memo
 Description: Target analyte recoveries using Method 3550 are lower than those obtained using Soxhlet extraction, Methods 3540 or 3541. Validation OF NEW EXTRACTION PROCEDURES should be done with the comparison of results to the Soxhlet extraction.
 
03/10/1994RESPONSE TO REQUEST FOR A VARIANCE TO USE PALLADIUM FOR GRAPHITE FURNACE ANALYSIS IN SEVERAL SW-846 METALS METHODSMemo
 Description: Analyst may optimize SW-846 methods to meet his/her specific needs. Allowable modifications include adjustment of the sample size or injection volumes, dilution or concentration of the sample, and the modification or replacement of equipment.
 
02/16/1994ACCEPTABILITY UNDER THE RCRA LAND DISPOSAL RESTRICTIONS OF TWO METHODS OF MACROENCAPSULATION FOR MIXED WASTES AT ROCKY FLATSMemo
 Description: The definition of macroencapsulation entails the use of a jacket or inert inorganic material and not merely placement in a tank or container because of the void spaces between the debris and the container. Discusses possible placement with variance from treatment standard, equivalent method variance, or no-migration variance. Discusses the performance standards for immobilization technologies.
 
01/26/1994RESPONSE TO PROPOSED PROCEDURE TO DECOMMISSION ALUMINUM CHAFF ROVING BUNDLESMemo
 Description: Aluminum chaff roving bundles could exhibit the reactivity characteristic (D003) for their propensity to release flammable hydrogen gas when they are exposed to moisture. The Part 268 land disposal restrictions (LDR) treatment standard for these wastes is deactivation, which is best achieved by washing them with an acidic solution (SUPERSEDED: treatment standard is deactivation and meet 268.48 standards, see 268.40). Compliance is evaluated based on the removal of the characteristic, not based on following a specified method of deactivation.
 
01/01/1994USE OF TOTAL WASTE ANALYSIS IN TOXICITY CHARACTERISTIC DETERMINATIONSQuestion & Answer
 Description: The maximum theoretical leachate concentration limits for the TCLP can be calculated from the results of a total waste analysis using a specific formula. Discusses the use of a total waste analysis for liquid wastes, solid wastes, and dual-phase wastes. Discusses maximum theoretical extract concentration (MTEC).
 
12/23/1993REQUIREMENTS FOR DISPOSAL OF DISCHARGED M-44 CYANIDE CAPSULES THAT ORIGINALLY CONTAINED A SODIUM CYANIDE PESTICIDEMemo
 Description: A person generating less than one kilogram of acute hazardous waste per calendar month is a CESQG. The weight of containers holding hazardous waste need not be counted towards the category limits. Both on- and off-site facilities managing a CESQG's acute hazardous waste must meet the criteria of 261.5(f)(3). There is no formal EPA approval needed in order to use alternative and equivalent method instead of triple rinsing when emptying containers holding acute hazardous waste. Cyanide-containing capsules can become empty and exempt according to 261.7.
 
12/07/1993INAPPROPRIATE USE OF METHOD 1311 (TCLP) AS AN ALTERNATIVE EXTRACTION PROCEDUREMemo
 Description: Method 1311 (TCLP) is the leaching procedure, not extraction procedure (EP). The TCLP is not an appropriate sample preparation procedure for extractable total petroleum hydrocarbons (TPH) or for volatile TPH fractions (e.g., gasoline). Discusses suggested methods for preparation of extractable TPH in soil.
 
11/29/1993REGULATORY INTERPRETATION OF A MOBILE MERCURY RETORTING PROCESS FOR MERCURY CONTAMINATED SOILS FROM NATURAL GAS PIPELINE METERSMemo
 Description: Mercury roasting and retorting are two methods of reclamation. Discussion of what roasting and retorting furnaces accomplish. Reclamation is a type of recycling. Recycling is generally not subject to regulation, unless recycling is taking place in a BIF. Roasting and retorting meet the definition of industrial furnace (BIF) since they are smelting, melting, or refining furnaces. Retorting solely for metal recovery is conditionally exempt from BIF rules (SEE ALSO: 64 FR 52827; September 30, 1999). Discussion of the elements of the exemption.
 
11/22/1993RCRA HAZARDOUS WASTE DETERMINATION OF SPENT NUCLEAR REACTOR FUELSMemo
 Description: The Naval Nuclear Propulsion Program’s (NNPP) spent reactor fuel does not exhibit any characteristics of hazardous waste. Discusses the application of the TCLP to radioactive mixed waste.
 
11/08/1993CLARIFICATION ON THE LEVEL OF SULFIDE FOR DETERMINING IF A WASTE IS HAZARDOUS UNDER THE REACTIVITY CHARACTERISTICMemo
 Description: If a waste contains greater than 500 mg/kg total releasable sulfide, then the waste is usually considered to meet the narrative definition of a characteristically reactive(SUPERSEDED: see RPC# 4/21/98-01). Discusses contrasting releasable sulfide methods.
 
10/20/1993RESPONSE TO SPECIFIC QUESTIONS REGARDING HAZARDOUS WASTE IDENTIFICATION AND GENERATOR REGULATIONSMemo
 Description: The absence of free liquids precludes applicability of the ignitability characteristic (D001) as defined in 261.21(a)(1). The proposed rule change (58 FR 46052; 8/31/93) suggests using the pressure filtration step from TCLP (Method 1311) as a definitive demonstration for the absence of free liquids for D001 and D002.
 
10/12/1993APPLICABILITY OF THE PAINT FILTER LIQUIDS TEST TO SORBENTSMemo
 Description: Provides clarification on the performance of the paint filter liquids test (PFT, Method 9095). PFT is designed to verify that sorbed wastes do not contain free liquids for the purpose of the hazardous waste landfill regulations. PFT was not designed to evaluate the performance of one sorbent product relative to other sorbents. No wastes, whether sorbed or not, may be placed in a hazardous waste landfill if they release free liquids as determined by the PFT.
 
09/23/1993GUIDANCE ON INDIRECT EXPOSURE ASSESSMENTS FOR HAZARDOUS WASTE COMBUSTION SOURCESMemo
 Description: Provides guidance on indirect exposure assessments for hazardous waste combustion sources. This memo transmits for review and comment the draft addendum to the 1990 Office of Research and Development (ORD) report, "Methodology for Assessing Health Risks Associated with Indirect Exposure to Combustor Emissions.” It also includes EPA’s initial recommendations on dealing with additional risk assessment issues such as the choice of risk levels and how to consider other air emission sources.
 
08/18/1993APPLICABILITY OF LAND DISPOSAL RESTRICTIONS TO THE WASTE CODE CARRY THROUGH PRINCIPLEMemo
 Description: Residues from the treatment of waste with a land disposal restrictions (LDR) equivalent method variance may lose the waste code provided certain conditions are met. Discusses the applicability of the derived-from rule to such residues (SEE ALSO: 66 FR 27266; May 16, 2001).
 
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.
 
07/07/1993QUALITY ASSURANCE PROJECT PLANS AND DATA QUALITY OBJECTIVES FOR RCRA GROUND-WATER MONITORING AND CORRECTIVE ACTION ACTIVITIESMemo
 Description: Discusses the application of the data quality objective (DQO) process to groundwater monitoring, and corrective action programs. DQO is the overall level of uncertainty that a decision maker is willing to accept in a decision making process. Quality assurance project plans are used to ensure DQOs are defined and documented. Chapter One of SW-846 outlines the minimum elements of a quality assurance programs for all data collection activities.
 
06/01/1993SAMPLE HOLDING TIMES AND VALIDITY OF ANALYTICAL RESULTSQuestion & Answer
 Description: Discusses the use of the TCLP analytical results when sample holding times are exceeded.
 
05/06/1993WASTE MANAGEMENT OPTIONS FOR ZINC-CARBON BATTERIESMemo
 Description: Zinc-carbon batteries that contain cadmium are subject to land disposal restrictions (LDR) only if they fail the TCLP and extraction procedure (EP) (SUPERSEDED: see 63 FR 28556; May 26, 1998). Zinc-carbon batteries are not subject to the cadmium battery recycling standard. The applicable D006 treatment standard is based on stabilization (SEE ALSO: Part 273).
 
04/29/1993ION CHROMATOGRAPHIC PROCEDURE FOR THE ANALYSIS OF HEXAVALENT CHROMIUMMemo
 Description: Method 218.6 is EPA’s ion chromatographic procedure for analysis of hexavalent chromium. EPA intends to incorporate this method into SW-846.
 
04/23/1993INTERPRETATION OF ""AQUEOUS"" AS APPLIED TO THE CORROSIVITY CHARACTERISTICMemo
 Description: Aqueous means amenable to pH measurement. The corrosivity characteristic (D002) references Method 9040. The scope and application of 9040 notes that it applies only to aqueous wastes and those wastes where the aqueous phase constitutes at least 20% of the total volume of the waste.
 
04/19/1993USE OF PAINT FILTER LIQUIDS TEST TO DETERMINE FREE LIQUIDS IN A WASTEMemo
 Description: The paint filter liquids test Method 9095 was developed to determine free liquids in waste. The test is not intended for use in determining if a waste contains any bound or absorbed liquid or if a liquid is aqueous. The aqueous phase must be present to evaluate waste for pH (SEE ALSO: RPC# 2/16/90-01).
 
04/08/1993CLARIFICATION ON ANALYTICAL QUANTITATION USING GC/MS METHODSMemo
 Description: Clarification on analytical quantitation using GC/MS methods. Discusses five-point versus one-point calibration.
 
04/02/1993REVISIONS TO THE TCLPMemo
 Description: Discusses the use of the method of standard additions (MSA) in metallic contaminants in TCLP wastes.
 
03/11/1993CLARIFICATION OF METHOD 8260 CALIBRATION STANDARDS AND ""WASTE TYPE""Memo
 Description: The calibration criteria for method 8260 were established for 5 ml samples. Contains guidance on running 25 ml samples. The “waste type” in the QA/QC step of the TCLP refers to materials which have significant differences in chemical constituents or physical properties. Discusses frequency of matrix spiking.
 
03/03/1993AVAILABILITY OF CRITERIA USED TO EVALUATE THE CHARACTERISTIC OF REACTIVITYMemo
 Description: EPA has test procedures to determine the reactivity of wastes that release hydrogen cyanide or hydrogen sulfide gas when they are mixed with weak acid. There is no EPA test for waste that releases hydrogen gas when it is mixed with water. Many reactive properties, such as water reactivity, are difficult to quantify (SUPERSEDED: the test procedures have been withdrawn, see RPC# 4/21/98-01).
 
01/18/1993HAZARDOUS WASTE TESTING ISSUESMemo
 Description: EPA has no data that trivalent chromium oxidizes to hexavalent chromium in a landfill. The TCLP is based on co-disposal scenario. Methods 9010 and 9012 are suggested for a concentration of total cyanide and cyanide amenable to chlorination.
 
01/12/1993NOTES ON RCRA METHODS AND QA ACTIVITIESMemo
 Description: Discusses the method and formula for using totals analysis to determine the theoretical maximum concentration of contaminants that could leach from a waste when using the TCLP, and the maximum theoretical extract concentration (MTEC) (SEE ALSO: RPC# 1/1/94-01). EPA’s current regulations for characterizing waste include determining the average property of the universe or whole, even when the waste is heterogeneous (i.e., contains hot spots).
 
12/22/1992CLARIFICATION ON MATRIX SPIKES FOR METHOD 8310Memo
 Description: Provides clarification of frequency of matrix spikes for method 8310.
 
12/07/1992MANAGEMENT OF USED FLUORESCENT LAMPSMemo
 Description: EPA test results indicate that fluorescent lamps often exhibit the toxicity characteristic for mercury (D009) as determined using the TCLP.
 
11/05/1992CLARIFICATION OF NEWLY LISTED WASTES AND HAZARDOUS DEBRISMemo
 Description: Characteristic debris treated to meet the land disposal restrictions (LDR) performance standards and contaminant restrictions that no longer exhibits a characteristic, is not hazardous waste. If a mixture of a material is comprised primarily of debris, by volume, based on visual inspection, the entire mixture is debris. Non-debris mixtures may be treated via equivalent method variance or variance from treatment standard. Analysis of leachability reduction of microencapsulated waste may be achieved by determining the constituent leachability before and after treatment using TCLP.
 
09/21/1992CALCULATION OF TCLP CONCENTRATIONS FROM TOTAL CONCENTRATIONSMemo
 Description: A generator may use total analysis in lieu of the TCLP analysis to determine if analyte could possibly be above regulatory level by dividing total concentration by 20 and comparing result with the regulatory limit. Discusses the maximum theoretical extract concentration (MTEC) (SEE ALSO: RPC# 1/1/94-01 “Use of Total Waste Analysis in Toxicity Characteristic Determinations”).
 
09/16/1992RCRA STATUS OF LEAD-BASED PAINT ABATEMENT DEBRIS AND LEAD PAINT CONTAINING DEMOLITION DEBRISMemo
 Description: Revising the toxicity characteristic levels for lead based on groundwater modeling, rather than extraction procedure levels, would result in most lead-based paint abatement wastes no longer testing hazardous. The revision of the toxicity characteristic level for lead may occur as part of Hazardous Waste Identification Rule. EPA considered extending the household hazardous waste exclusion to lead-based paint (LBP) abatement wastes from renovation (SEE ALSO: 63 FR 70233, 70241; 12/18/98).
 
09/04/1992STATUS OF FLUORESCENT LAMPS UNDER RCRAMemo
 Description: CESQG or household hazardous waste (HHW) fluorescent light bulbs may be land disposed in Subtitle D landfill regardless of characteristic properties. Land disposal restrictions (LDR) do not apply to D009 mercury-containing fluorescent light bulbs that pass the extraction procedure (EP) test (SUPERSEDED: see 63 FR 28556; 5/26/98). The bulbs are subject to LDR because they exhibit the EP toxicity characteristic and toxicity characteristic (TC), and could be considered debris per 268.45.
 
09/01/1992“AQUEOUS” AS APPLIED TO THE CORROSIVITY CHARACTERISTICQuestion & Answer
 Description: Aqueous liquid wastes must be tested for both pH and the rate of steel corrosion to determine corrosivity. For D002, aqueous defined as waste for which the pH is measurable. Aqueous nonliquids subject to pH test only. Provides examples of aqueous nonliquids.
 
08/26/1992CLARIFICATION ON SAMPLING AND DATA INTERPRETATIONMemo
 Description: Generators are not required to test or to specifically use the SW-846 methods except where specified in the regulations. Persons who demonstrate that their method of sampling and data interpretation is scientifically and statistically correct can use that procedure in place of the SW-846 method.
 
06/16/1992DESIGNATION OF AMERICIUM BERYLLIUM SOURCES UNDER RCRAMemo
 Description: Discusses the tentative determination that americium beryllium (AmBe) sealed source wastes are not RCRA hazardous wastes. AmBe sealed sources are not P015, and are not ignitable (D001), corrosive (D002), or reactive (D003). EPA does not expect stainless steel casings to fail the toxicity characteristic. Beryllium residues discarded during sealed source manufacturing process may be P015. Solder from sealed sources may be evaluated using a combination of testing and mass balance approaches. The theoretical TCLP concentration can be based on solder composition or by testing.
 
06/03/1992HOLDING TIMES FOR GROUNDWATERMemo
 Description: The holding times for aqueous samples are listed in the holding time tables in Chapters 2 and 4 of SW-846. The holding time tables for volatiles and semivolatile in Chapter 11 are being deleted from SW-846.
 
03/09/1992CORROSIVITY CHARACTERISTIC AS IT APPLIES TO SOLIDSMemo
 Description: corrosive solids (i.e., lye, and solid acids) are not covered under the corrosivity characteristic (D002). Aqueous is not defined (SUPERSEDED: see RPC# 1/7/93-02; RPC# 4/23/93-01). A test method for corrosive solids is proposed.
 
03/06/1992VALIDITY OF METHOD 3060, HEXAVALENT CHROMIUM DIGESTIONMemo
 Description: EPA requires the use of specific test methods only where specified in the regulations. For all other applications, the use of the SW-846 methods is not mandatory. Method 3060 for hexavalent chromium is valid until the 3rd edition of SW-846 is promulgated.
 
12/19/1991USED AUTOMOBILE ANTIFREEZE DISPOSALMemo
 Description: Used antifreeze from households is exempt from regulation. Used antifreeze from business is hazardous waste only if characteristic. Small business may be able to enjoy the reduced CESQG regulation. Industry data indicates used antifreeze may fail TCLP.
 
12/17/1991HANDLING AND ANALYSIS OF SAMPLES CONTAINING VOCS (VOLATILE ORGANIC COMPOUNDS)Memo
 Description: Discusses the handling of aqueous samples for test methods. Headspace from the sample storage should not invalidate sample. Macro bubbles from the storage or improper sample collection may affect the sample if they are larger than 1/4”, The data from samples with excessive headspace should be the minimum values or thrown out.
 
12/01/1991SW-846 TEST METHODSQuestion & Answer
 Description: The test methods found in SW-846 are generally not required, but are intended as guidance for both hazardous waste identification and compliance with the land disposal restrictions (LDR) treatment standards. In certain instances, such as delisting and characteristic testing, EPA requires the use of the SW-846 methods.
 
10/29/1991TCLP EXTRACTIONS APPLIED TO LIQUID WASTES, OILS AND SOLVENT-BASED PRODUCTSMemo
 Description: Provides suggested analytical steps when inconclusive results are obtained from application of the TCLP to solvent and oily wastes. Generators may always apply their knowledge in lieu of testing. TCLP analysis is unnecessary for used oil destined for recycling.
 
10/09/1991EXEMPTION FROM PARTICLE SIZE REDUCTION STEP IN TCLPMemo
 Description: Generator knowledge may include previous testing data on similar waste. The generator must test or apply knowledge to make a determination of hazardous waste characteristics. The TCLP particle size reduction method is up to the lab’s best professional judgment.
 
10/01/1991ANALYTICAL METHODS FOR CONDUCTING TESTING UNDER THE TC RULEMemo
 Description: Up until June 21, 1990 the analytical methods for the toxicity characteristic of arsenic, selenium, and mercury were 7060, 7061,7740, 7470, and 7471. On June 21, 1990, the Agency promulgated method 6010.
 
09/11/1991USE OF ASTM METHOD D-56 IN IGNITABILITY DETERMINATIONSMemo
 Description: Addresses the possible use of ASTM method D-56 to test the flash point of a potentially ignitable (D001) liquid as an alternative to the two methods specified in 261.21.
 
09/06/1991DETERMINATION OF THE IGNITABILITY CHARACTERISTICMemo
 Description: There is no test method for ignitable solids (D001), the generator should apply knowledge (SEE ALSO: SW-846 Method 1030 (62 FR 32451; June 13, 1997). The analyses of solids may help determine if any detectable compounds are known to be ignitable. Meeting any, not all, of the ignitability properties renders a waste hazardous. There is no specific definition of “liquid” for purposes of the Pensky-Martens closed tester (SEE ALSO: RPC# 10/20/93-01) (SEE ALSO: 60 FR 3092; June 13, 1997).
 
07/31/1991TC RULE HAZARDOUS WASTE DETERMINATIONMemo
 Description: Pulp and paper mill wastes should be sampled at an outlet from the bleach plant (point of generation), prior to commingling (mixing) with other wastestreams, to determine whether they exhibit the toxicity characteristic for chloroform (D022). The dilution of characteristic hazardous waste at a pulp and paper mill is acceptable for CWA compliance provided there is no specified method of treatment (58 FR 29860; 5/24/93). The definition of aggressive biological treatment (ABT) units for the purposes of the F037 and F038 listings does not apply to the exemption for biological treatment units from the surface impoundment minimum technical requirements.
 
07/09/1991METHODOLOGIES EMPLOYED IN USED OIL SAMPLINGMemo
 Description: Discusses the 1989-1990 used oil sampling data that was gathered to support the used oil characterization effort. Used oil was analyzed for compositional characteristics and analyzed via TCLP. 7 types of used oils were analyzed. The results do not reflect regional variations as all samples, where possible, were taken from the Washington, D.C. area. Addresses the role of TCLP and other methods used in the determination (SEE ALSO: 57 FR 41566; 9/10/92).
 
07/03/1991TCLP AND LEAD PAINT REMOVAL DEBRISMemo
 Description: Provides general guidance for the representative sampling of lead-based paint abatement wastes (debris and abrasives) from drums, roll off boxes, and other containers. Shipments of LBP abatement wastes from a field site (bridge repair) to a central accumulation point must generally be accompanied by a manifest. The central accumulation point must be a transfer facility or a TSDF to accept manifested hazardous waste. Generators conducting lead-based paint (LBP) abatement must test the wastes using TCLP unless they can apply knowledge to determine characteristics (SEE ALSO: 63 FR 70233, 70241; 12/18/98). If an LBP waste first tests nonhazardous in TCLP due to the masking effect of an iron abrasive but exhibits the characteristic prior to disposal, all hazardous waste regulations apply. LBP abatement wastes that are characteristic for lead may be stabilized on site during accumulation in tanks or containers without a permit.
 
07/02/1991DISPOSAL OF USED SYRINGESMemo
 Description: Addresses the treatment methods for used syringes. There is no federal regulation of medical waste for states not participating in the demonstration program (SUPERSEDED: see 60 FR 33912; 6/29/95).
 
06/21/1991POSITION PAPER ON SPENT ABSORBENT MATERIALSMemo
 Description: CESQGs may dispose of hazardous waste in a sanitary or municipal solid waste landfill as long as the landfill is permitted, licensed, or registered by the state to manage municipal or industrial solid waste (SEE ALSO: 261.5(g)(3)). An absorbent and waste mixture containing a free liquid phase with a flash point less than 140 F is D001. A sorbent and waste mixture with no free liquid is D001 only if it qualifies as an ignitable solid. DOT hazard classes do not correspond directly to RCRA characteristics. The deliberate mixing of hazardous waste and absorbents to render waste nonhazardous may be treatment subject to permitting (SEE ALSO: 264.1(g)(10)) and 268.3). If an absorbent is mixed with waste that is listed solely for exhibiting a characteristic, the mixture is not hazardous waste if it does not exhibit the characteristic (SEE ALSO: 66 FR 27266; 5/16/01). A mixture of absorbent and used oil is subject to Part 266, Subpart E (SUPERSEDED: See Part 279) if destined for energy recovery.
 
06/21/1991SPENT ANTIFREEZE AND THE TOXICITY CHARACTERISTICMemo
 Description: Discusses the use of TCLP to determine if spent antifreeze exhibits the characteristic for lead. The extraction procedure (EP) and TCLP are functionally equivalent for liquid wastes, since both lead to a direct analysis of the liquid. Extraction procedure toxic wastes are a subset of all hazardous waste. Generators may apply their knowledge instead of testing.
 
06/19/1991SURROGATE RECOVERYMemo
 Description: Testing surrogate recovery is used to demonstrate correct sample preparation and absence of matrix effects in test method. The omission of surrogates in analysis in which they are called for is a deviation. The absence of surrogate data does not in itself invalidate an analysis.
 
06/13/1991TCLP EXTRACTIONS AS THEY APPLY TO OILY WASTEMemo
 Description: The Agency does not recommend applying the TCLP test to oily waste. If oily waste is used oil, characterization is unnecessary if going for recycling (SEE ALSO: Part 279). If the TCLP is inconclusive on oily wastes, the generators may use knowledge.
 
05/29/1991PARTICLE SIZE REDUCTION PROCEDURE FOR TCLP SAMPLES OF DRY CELL BATTERIESMemo
 Description: The Agency is unable to determine if sample freezing with liquid nitrogen to facilitate grinding and crushing would alter accuracy of TCLP.
 
05/21/1991APPLICABILITY OF THE TCLP TO WASTE MUNITIONSMemo
 Description: The mandatory hazardous waste determination should be based on knowledge when the application of TCLP to discarded munitions would result in an inherently unsafe situation due to the particle reduction step. The exemption from TCLP is unwarranted because generators can apply their knowledge.
 
05/09/1991METHODS 8240 AND 8260 DIFFERENTIATION AND EQUIVALENCYMemo
 Description: Method 8240 uses packed columns, and Method 8260 uses open tubular capillary columns. Discussion of the substitution of capillary columns for packed columns if acceptable accuracy and precision by Method 8000 Section 8.6 is demonstrated.
 
05/02/1991CLOSURE STANDARDS FOR HAZARDOUS WASTE LAND TREATMENT UNITSMemo
 Description: Soil sampling is usually required during land treatment unit closure and post-closure as part of the unsaturated zone monitoring. If the treatment unit is removed as a part of clean-closure, the soil-core monitoring may be suspended at the completion of the closure period. Discusses guidance on intervals for, and duration of, soil sampling during closure and post-closure. There is no EPA-approved methods for determining degradation rates. Closure of a land treatment unit may take up to 360 days. Discussion of closure and post-closure standards for a land treatment units when migration of hazardous constituents has occurred. Discussion of closure standards when groundwater is contaminated at levels below alternate concentration levels specified in a facility permit. The post-closure period for a land treatment unit cannot be terminated until owner or operator has successfully demonstrates that all groundwater at the site is safe for all potential receptors. Discuses addressing migration of constituents of concern outside of the treatment zone during closure versus under corrective action. There are no regulatory provisions requiring corrective action when migratory constituent concentrations exceed regulatory levels of concern in groundwater at an interim status land treatment facility (3008(h)). Discussion of when closure is considered complete.
 
05/01/1991TCLP PARTICLE SIZE REDUCTION EXEMPTION FOR MUNITIONSMemo
 Description: Particle reduction in TCLP is unsafe for military munitions. Facilities may apply knowledge to determine characteristic.
 
03/27/1991DEFINING IGNITABLE LIQUIDS METHODMemo
 Description: Using one of the two test methods approved for determining ignitability is sufficient. The choice of method will depend on the nature of the waste to be tested (e.g., one method might be more appropriate given the viscosity of the waste).
 
03/25/1991DILUTION OF TEST SAMPLINGMemo
 Description: TCLP is difficult to use on wastes such as oils and neat solvents because dilution step shifts detection limits are above the toxicity characteristic levels. A generator should apply knowledge in such cases. If no information is available, it would be prudent to handle it as hazardous waste (SEE ALSO: RPC# 8/14/90-01). There is no need to run TCLP on used oil that will be recycled.
 
03/19/1991MATRIX SPIKE IN TCLP PROCEDUREMemo
 Description: A matrix spike may be used in the TCLP when the contaminant concentration is completely unknown to monitor method performance and to estimate the extent of bias or interference (SEE ALSO: 57 FR 26986; November 24, 1992). A matrix spike is a predetermined quantity of certain analytes added to a sample matrix before sample extraction/preparation.
 
02/22/1991ANALYSIS OF FLUFF MATERIALSMemo
 Description: Discusses tha analysis of fluff using TCLP v. extraction procedure (EP) and the use of different extraction fluids for TCLP.
 
02/12/1991TC APPLICABILITY TO MIXED WASTEMemo
 Description: Discusses the definition of mixed radioactive waste. Mixed waste was first subject to RCRA regulation in 1986. The toxicity characteristic does not apply to mixed waste in states with only RCRA base program authorization until the State revises its program and receives authorization for mixed waste. Discusses the status of mixed waste that fails the TCLP.
 
02/05/1991GENERATOR HAZARDOUS WASTE DETERMINATION AND THE TCLPMemo
 Description: Clarifies a letter (RPC# 11/8/90-04). A generator may always apply knowledge in determining if a waste is hazardous waste. If no information is available except for inconclusive TCLP data, it is prudent for the generator to assume that the waste is hazardous. There is no need to perform TCLP on used oil that is destined for recycling.
 
01/08/1991LEADED PAINT SANDBLASTING WASTE TESTING USING TCLPMemo
 Description: The land disposal restrictions (LDR) regulations continue to allow the use of either the extraction procedure (EP) or the TCLP to demonstrate compliance with the treatment standards for certain lead and arsenic wastes (SUPERSEDED: see 63 FR 28556; May 26, 1998). The TCLP is only test usable for characterization and identification of toxicity characteristic hazardous waste.
 
11/19/1990SELECTION OF NON-USEPA APPROVED METHODS FOR SUBPART X PERMITSMemo
 Description: The draeger tubes and supercritical fluid chromatography is an inappropriate test method for air emissions of 11 constituents from open burning/open detonation (OB/OD). The appropriate methods is found in SW-846, Ambient Air Test Methods Compendium, OAQPS, manufacturers, and NIOSH.
 
11/15/1990Test Method 9096: Liquid Release Test (LRT) ProcedurePublication
 Description: Provides information designed to determine whether or not liquids will be released from sorbents when subjected to overburden pressures in landfill.
 
11/09/1990PETROLEUM-CONTAMINATED MEDIA AND DEBRIS DEFERRAL FROM THE TOXICITY CHARACTERISTICMemo
 Description: The petroleum contaminated media deferral does not apply to D001-D017. There is no need to run TCLP to determine if wastes are D018 - D043, provided the wastes are generated as part of UST corrective action.
 
11/08/1990APPLICABILITY OF THE TCLPMemo
 Description: TCLP is inappropriate for certain matrices, like oils and neat solvents. Dilution step shifts detection limits are above regulatory levels. If that is the case, the generator must assume that the waste is hazardous (SEE ALSO: RPC# 3/25/91-01). TCLP must be used to obtain the extract.
 
11/08/1990BIAS CORRECTION APPLIED TO THE TCLPMemo
 Description: Whenever the TCLP is used, all the requirements in the procedure must be met. All results should be corrected for bias, even if below standard. Spike matrix recovery is a bias correction tool (SEE ALSO: 57 FR 26986; November 24, 1992). Data collected before September 25, 1990 need not be corrected for bias per toxicity characteristic rule. The owner/operation may be held liable for the proper disposal of improperly characterized waste.
 
11/01/1990QC REVIEW OF PERMIT DATAMemo
 Description: A matrix spike assists in ascertaining and correcting co-extracted artifacts (analytical bias) and tests laboratory conditions. Discusses performance of matrix spike recovery for TCLP analytes (SEE ALSO: 57 FR 26986; November 24, 1992).
 
10/30/1990USED OIL FILTERS - REGULATION; USED OIL FILTERS, REGULATORY DETERMINATIONMemo
 Description: Crushing a filter to remove used oil (UO) is exempt if the removed UO is recycled (SUPERSEDED: see 261.6(a)(4) and 279.10(c)). Generally, used auto oil filters are not containers because they are not storing oil. Filters are not empty containers. A filter with UO removed is exempt scrap metal if it is recycled. Undrained, uncrushed filters have too much oil for the scrap metal exemption (SEE ALSO: 261.4(b)(13)). TCLP is performed on UO filters by crushing, cutting, or grinding filters and their contents until the pieces are smaller than one cm in the narrowest dimension. A characteristic UO filter that is sent for disposal is subject to regulation (SUPERSEDED: see 261.4(b)(13)).
 
08/24/1990LEAD AND ARSENIC WASTES TREATMENT STANDARDSMemo
 Description: Either the TCLP or extraction procedure (EP) can be used to demonstrate compliance with land disposal restrictions (LDR) treatment standards for lead and arsenic (SUPERSEDED: see 63 FR 28556; May 26, 1998). EP is no longer used for purposes of hazardous waste identification.
 
08/24/1990SPENT ANTI-FREEZE COOLANT REGULATORY STATUSMemo
 Description: Waste antifreeze coolant (ethylene glycol) is not a listed hazardous waste (HW) but is a solid waste if intended for discard. The generator must determine if it is characteristic, by testing the waste or applying knowledge. Anecdotal evidence indicates that used antifreeze may exhibit the toxicity characteristic for lead, as determined using the EP (extraction procedure).
 
08/23/1990TREATMENT STANDARDS AND THE BEVILLE EXCLUSIONMemo
 Description: Waste with technology land disposal restrictions (LDR) treatment standard must be treated to that standard. If the method is incineration (INCIN), the waste must be treated in an incinerator subject to Part 264 Subpart O or Part 265 Subpart O. Restricted wastes sent to a Bevill device or a BIF is still subject to LDR notification. Discusses a proposal to determine if resides from the co-processing of Bevill raw materials and hazardous waste remain excluded (SUPERSEDED: see Section 266.100).
 
08/17/1990USED OIL FILTERS CLASSIFICATIONMemo
 Description: If the extract from the TCLP-tested used oil filter equals or exceeds the regulatory levels for any hazardous constituent the filter is a hazardous waste. Filters that have been drained are less likely to be hazardous (SEE ALSO: Section 261.4(b)(13)).
 
08/14/1990TCLP APPLICABILITYMemo
 Description: The use of TCLP to evaluate solid waste prior to the effective date of TCLP is valid. Addresses the use of matrix spike recovery. TCLP is difficult to apply to oily or solvent matrices. In the absence of usable data, it is safest to assume the material is a hazardous waste (SEE ALSO: RPC# 3/25/91-01).
 
07/31/1990MULTI-SOURCE LEACHATE AND TREATMENT STANDARDS OF LAND DISPOSAL RESTRICTIONSMemo
 Description: Waste codes not required on the manifest. A TSDF may rely on waste analysis data from the generator, but the TSDF must periodically test representative samples. A lab may certify for land disposal restrictions (LDR) as representative of the waste handler. Waste analysis parameters. Stabilization of cyanide to reduce leachability is an inappropriate treatment and generally impermissible dilution. No dilution of toxicity characteristic wastes if land disposed. Generators must determine characteristics. If a listed treatment standard addresses the characteristic, it operates in lieu of characteristic (even if less stringent). Prohibited waste only placed in a minimum technological requirement (MTR) surface impoundment if meets treatment standards, variance or extension, or 268.4. Notice and certification for de-characterized waste is sent to the implementing agency. F039 HSWA. Permitted TSDFs with F039 submit Class 1 modification by 8/8/90. Lab packs must be burned in Subpart O incinerator, not cement kilns.
 
07/30/1990SUBMARINE REACTOR COMPARTMENTS - LAND DISPOSAL RESTRICTIONSMemo
 Description: Lead reactor compartments may meet the land disposal restrictions (LDR) treatment standard of macroencapsulation for D008, radioactive lead solids as generated. Compliance with the technology-based standard does not require that waste undergo TCLP analysis.
 
06/29/1990AGITATE SAMPLES EVALUATED USING METHOD 1110Memo
 Description: No quantitative guidance on when and to what extent waste should be agitated to ensure homogeneity during the steel coupon test for corrosivity. Non-homogeneous liquids should be agitated by mechanical means. For homogeneous liquids of low viscosity, thermal currents may be sufficient.
 
06/25/1990LEAD-BEARING WASTES TREATMENT STANDARDSMemo
 Description: The TC (toxicity characteristic) is effective 9/25/90. There are different TC compliance dates for LQG (9/25/90) and SQG (3/29/91). D008 (lead) wastes that fail TCLP but pass EP (extraction procedure) are considered in compliance with D008 treatment standard and can be land disposed (SUPERSEDED: see 63 FR 28556; 5/26/98).
 
06/24/1990NO TECHNICAL STANDARDS FOR SHARPS CONTAINERSMemo
 Description: Discussion of OSHA jurisdiction over medical waste management within facilities versus EPA jurisdiction over disposal. EPA has established performance standards for leak- and puncture-resistant containers, rather than test methods (SEE ALSO: 60 FR 33912; 6/29/95).
 
06/14/1990ADOPTION OF TCLP FOR DELISTING DEMONSTRATIONSMemo
 Description: Notification to petitioners that, after finalization of toxicity characteristic rule, TCLP data will be required in all delisting petitions instead of extraction procedure (EP) data (SEE ALSO: 261.24).
 
04/20/1990CLASSIFYING MERCURY-CONTAINING PAINTS AS HAZARDOUS WASTESMemo
 Description: Mercury-containing paint discarded by homeowners is exempt household HW. Mercury-containing latex paint usually exhibits the toxicity characteristic when properly tested. The statement that paint will not exhibit mercury characteristic unless concentration exceeds 540 ppm is incorrect.
 
04/12/1990CADMIUM WASTES FROM MILITARY COATING MATERIALSMemo
 Description: Cadmium wastes from coating materials and spent sacrificial anodes generated by military operations may be F-listed electroplating, heat treating, or aluminum conversion coating wastes (F006, F019, F007, F008, F009, F010, F011, F012) or may exhibit EP (extraction procedure) Toxicity for cadmium (SUPERSEDED: see Section 261.24).
 
02/16/1990IGNITABILITY OR CORROSIVITY TESTING-LIQUID AND AQUEOUS DEFINITIONMemo
 Description: No mandatory test for determining liquid and aqueous for ignitability (D001) and corrosivity (D002) characteristic testing. Paint filter liquid test (PFLT) Method 9095 may be used. Method 9095 is not appropriate for toxicity characteristic.
 
02/02/1990APPLICABILITY OF EXCLUSION FOR REGULATED MEDICAL WASTE THAT HAS BEEN TREATED AND DESTROYEDMemo
 Description: Breaking the needle from a syringe, removing the nipple from a syringe barrel, and separating the plunger from the syringe barrel are not adequate destruction methods for medical waste (SUPERSEDED: see 60 FR 33912; 6/29/95).
 
02/01/1990EXCULTION FOR REGULATED MEDICAL WASTE RESIDUES THAT HAVE BEEN TREATED AND DESTROYEDMemo
 Description: Autoclaving is legitimate treatment but not a legitimate destruction method;. Generators who treat and destroy on-site must comply with the Part 259 storage requirements before treatment/destruction. A QA/QC performed on test kits may generate regulated medical waste. Discussion of microorganisms (SUPERSEDED: see 60 FR 33912; 6/29/95).
 
01/30/1990IGNITABILITY CHARACTERISTIC TESTING FOR SOLIDSMemo
 Description: There is no test method for ignitable solids (D001), only narrative definition (SEE ALSO: SW-846 method 1030 finalized in the June 13, 1997 Federal Register (62 FR 32451)).
 
12/13/1989DIGESTION OF EP AND TCLP EXTRACTS PRIOR TO METAL ANALYSISMemo
 Description: For Method 1310 (extraction procedure) (EP) and Method 1311 (TCLP) the extracts should be digested prior to metal analysis if waste contains phases or if the waste precipitates during cold storage.
 
11/03/1989BLAST SLAG TESTING PROCEDURESMemo
 Description: Discusses representative sampling for blast slag generated at lead recycling facilities for purposes of extraction procedure (EP) (SUPERSEDED: see Section 261.24).
 
10/05/1989DEFINITION OF A LIQUID AS IT APPLIES TO IGNITABLE AND CORROSIVE WASTES; LIQUID AS IT APPLIES TO IGNITABLE OR CORROSIVE WASTESMemo
 Description: The definition of liquid depends on the specific regulatory application for ignitable (D001), corrosive (D002), and extraction procedure (EP) (SUPERSEDED: see 261.24). For toxic wastes, liquid is defined as the material expressed from the waste in Step 2 of Method 1310. Liquids produced from paint filter test are generally also liquids under Method 1310 (SEE ALSO: 60 FR 3092; January 13, 1995). Only wastes containing a liquid component are subject to the flash point test (ignitability (D001)) and the pH test (corrosivity (D002)). Method 9095 is used to determine if a waste is prohibited from disposal in a landfill for containing free liquids. Method 9096 is a draft procedure for determining if adsorbents contain releasable liquids. Adsorbents containing releasable liquids are prohibited from disposal in a landfill by HSWA.
 
08/28/1989RECORDKEEPING FOR ON-SITE INCINERATORS OF MEDICAL WASTEMemo
 Description: Using the weight-averaging method to estimate the quantity of a regulated medical waste incinerated is acceptable for incinerator recordkeeping. Records should indicate incinerated quantity, by weight (SUPERSEDED: see 60 FR 33912; 6/29/95).
 
08/17/1989SCRAP DENTAL AMALGAMMemo
 Description: Dental silver amalgam is not specifically listed as a hazardous waste. The American Dental Association (ADA) research suggests amalgam does not exhibit extraction procedure (EP) toxicity (SUPERSEDED: See 261.24), but the burden of determination is ultimately the generator's. ADA data could be the basis of a determination by knowledge. CERCLA 107 liability is independent of the material’s regulatory status under RCRA.
 
07/20/1989LIQUID, FREE LIQUID, RELEASABLE LIQUID DEFINITIONSMemo
 Description: Liquid for purposes of corrosivity (D002) determined by Method 1310 (extraction procedure (EP)). The definition of free liquid applies to the prohibition of liquids in landfills. Definition of releasable liquid applies to absorbent materials that might release liquids (SEE ALSO: current Sections 264.314(e), and 265.314(f)).
 
05/17/1989SCRAP AMALGAM FILLINGS FROM DENTISTS, DISPOSAL OFMemo
 Description: Dental amalgam is hazardous if it exhibits extraction procedure (EP) toxicity for lead or silver (SUPERSEDED: See 261.24). Most dentists are probably classified as CESQGs.
 
05/12/1989PROCEDURE FOR APPLYING EP TOXICITY TEST TO BLAST SLAG AT SECONDARY LEAD SMELTERSMemo
 Description: Discussion of the proper procedure for testing blast slag at secondary lead smelter according to extraction procedure (EP) toxicity test (SUPERSEDED: See 261.24). Reconciliation of particle reduction step with structural integrity requirement.
 
05/05/1989PLACEMENT OF STABILIZED WASTES THAT DO NOT MEET LAND RESTRICTION REQUIREMENTSMemo
 Description: Waste must meet treatment standards before it is placed in a land disposal unit. A land disposal restrictions (LDR) equivalent method variance may be granted if the technology is equivalent or better than best demonstrated available technology (BDAT). A no-migration variance must be based on the period that the waste is hazardous. Bulk or non-containerized liquid hazardous waste must pass the paint filter liquids test prior to placement in a landfill.
 
04/20/1989ANALYTES TO LOOK FOR WHEN PERFORMING RCRA ANALYSISMemo
 Description: Target analytes for RCRA analyses will depend upon the purpose of the analysis. A list of analytes needed to be tested for is generally specified in the waste analysis plan. SW-846 is a compilation of test methods for complying with all aspects of RCRA.
 
04/20/1989EP TOXICITY LEVEL FOR BARIUM IN DRINKING WATERMemo
 Description: The regulatory levels for extraction procedure (EP) toxicity depend on both MCLs and a fate and transport factor of 100 (EP toxicity levels are equal to 100 times the MCLs). Therefore, a change to the MCL for barium would not automatically merit a change to the extraction procedure regulatory level (SUPERSEDED: See 261.24).
 
03/14/1989SUMMARY OF ASSISTANCE BRANCH PERMITTING COMMENTSMemo
 Description: Discusses an automatic waste feed shut-off design for munitions deactivation (popping) furnaces and fugitive emissions control from popping furnaces. Pits used for dewatering and open burning are surface impoundments, not miscellaneous units. EPA can use omnibus provisions to impose additional controls on open burning in surface impoundments. Waste explosives that do not have the potential to detonate cannot be destroyed in open burning/open detonation (OB/OD) units. Solvents contaminated with explosives that have the potential to detonate can be open burned. Because open burning/open detonation (OB/OD) of waste explosives is treatment, not disposal, the land disposal restrictions (LDR) do not apply. Treatment residues may be subject to LDR. Clarifies when the disposal of explosives requires a permit and when unused explosives become wastes (SEE ALSO: 62 FR 6622; 2/12/97). Burning commercial fuel in fire training exercises is not regulated under RCRA. Discusses methods of determining soil background levels for the clean closure of surface impoundments and waste piles, circumstances in which the unit type can be redesignated during interim status, cleanup standards for corrective action, compliance points for soil and groundwater cleanup, timing of corrective action cleanup activities and site monitoring, termination of groundwater corrective action, the use of institutional controls, the use of trial burn data from one facility at other incinerators, the evaluation of trial burn plans for popping furnaces, and the use of in-place hydraulic conductivity testing during liner installation for surface impoundments and landfills. A landfill’s clay layer component of the final cover must be completely below the average frost depth. Addresses the use of natural material (calcium carbonate) and cement kiln dust in waste stabilization, the use of the RCRA corrective action plan (CAP) in HSWA permit preparation, the use of the 261.4(f)(2) authority to implement Subpart X standards in RCRA authorized states, and the permitting deadlines for Subpart X facilities.
 
02/22/1989REGULATORY STATUS OF SOLVENT, “ULTIMA-GOLD”Memo
 Description: Unused solvent is only subject to regulation as a discarded material when abandoned (i.e., disposed or incinerated) or recycled by being burned for energy. A CCP that is abandoned is a solid waste, while a CCP being reclaimed is not a solid waste. The transportation and sale of unused solvent, Ultima-Gold, is not subject to Subtitle C because it is a product rather than a discarded material. The material safety data sheet for solvent product "Ultima-Gold" indicates potential to be corrosive (D002) and reactive (D003). The product "Ultima-Gold" does not exhibit ignitability (D001) or extraction procedure (EP) toxicity (SUPERSEDED: See 261.24). A product solvent only meets P-listing or U-listing if the chemical on the P-list or U-list serves as the product's sole active ingredient.
 
01/27/1989TOTAL CONCENTRATION USED TO DEMONSTRATE A WASTE DOES NOT EXHIBIT THE CHARACTERISTIC OF EP TOXICITYMemo
 Description: The maximum theoretical leachate concentration limits for TCLP can be calculated from the results of a total waste analysis of liquid wastes, solid wastes, and dual-phase wastes using a specific formula. Discusses the maximum theoretical extract concentration (MTEC) (SEE ALSO: RPC# 1/1/94-01).
 
01/25/1989FLUFF ANALYSIS/SAMPLESMemo
 Description: The extraction procedure (EP) (SUPERSEDED: see 261.24) analyses of fluff should be conducted after samples have undergone the appropriate size reduction. The extraction procedure does not require the size reduction of materials whose ratio of surface area to weight is greater than 3.1 cm2/g (e.g., pieces of fabric or wire).
 
11/21/1988FLUFF RESIDUALS FROM FERROUS METALS RECYCLING (AUTOMOBILE SHREDDING)Memo
 Description: Fluff residual from automobile shredding may commonly exhibit extraction procedure (EP) toxicity (SUPERSEDED: See 261.24) for lead. Other metals of concern include cadmium and chromium. PCB contamination may subject the fluff to additional regulation under TSCA. Hazardous waste fluff is subject to California list if it equals or exceeds halogenated organic compound (HOC) prohibition levels (SUPERSEDED: California list removed, see 62 FR 25997; 5/12/97).
 
10/19/1988MULTIPLE EXTRACTION PROCEDURE, METHOD 1320Memo
 Description: For the multiple extraction procedure (Method 1320), the weight of the wet material remaining after each extraction procedure (EP), not the original dry weight, is used to calculate the 20:1 liquid to solid ratio. Method 1320 is trying to predict the effect on the waste in a landfill that is subject to rain for a long period of time.
 
09/09/1988IGNITABILITY CHARACTERISTIC, DEFINITION OF UNDER STANDARD TEMPERATURE AND PRESSUREMemo
 Description: A waste need not be evaluated for a flash point if it is not a liquid at standard temperature (20°C/68°F) and pressure (1 atmosphere). Polystyrene production distillation still bottom tar is not a liquid at standard temperature and pressure and, for purposes of ignitability characteristic, need be evaluated only against 261.21(a)(2) criterion.
 
09/02/1988SUMMARY OF ASSISTANCE BRANCH PERMITTING COMMENTSMemo
 Description: Aboveground bolted flange joints that are inspected daily do not need secondary containment. Joints where waste may contact the thread must meet the secondary containment requirement for tank ancillary equipment. A trench below tank waste lines may qualify as secondary containment if it is sized to contain a release and if the trench is dry so that leaks can be detected. Discusses the status of new tank systems at facilities permitted between 7/14/86 and 1/12/87. To meet the definition of a boiler, the combustion chamber and energy recovery section must be of integral design. A unit with a “post-combustion” chamber between the combustion and energy recovery sections is not a boiler. A unit with a combustion section connected to an energy recovery unit by a duct and a control system is not a boiler. A unit with innovative insulation installation does not qualify as boiler under a variance petition if the insulation does not provide significantly better performance. The determination of boiler efficiency should be conducted under controlled conditions following a method specified by the American Society of Mechanical Engineers. Thermal relief vents can be used in the design of a new incinerator, but a permit should require backup systems to minimize their use. Addresses the application of the minimum technology requirements (3004(o)) to the vertical and lateral expansions of surface impoundments and landfills. The minimum technology waiver petition was granted due to alternate design and operational factors. The 3004(o)(2) waiver petition that would prevent the migration of contaminated groundwater beyond the waste management area (e.g. surface impoundment) is inadequate because it does not prevent all groundwater contamination. Incinerators may be eligible for research, development, and demonstration (RDD) permits. Provides guidance on the duration of Research, Development, and Demonstration (RDD) permits beyond a calendar year and criteria for renewing RDD permits. Discusses the applicability of the new tank system regulations in authorized v. unauthorized states. Includes guidance on the selection of principal organic hazardous constituent (POHCs) and the use of surrogate v. actual wastes during the incinerator trial burn. The actual waste can be spiked during the trial burn to raise principal organic hazardous constituent levels. Addresses the sampling frequency during a trial burn. The mass feed rate of a principal organic hazardous constituent (POHC) input used for destruction and removal efficiency (DRE) calculations must equal mass feed rate in the wastestream only. When sampling for particulates and semi-volatile POHCs during an incinerator trial burn, two separate Modified Method 5 (MM5) trains should be used. Only one confirmatory sampling event is necessary to trigger compliance monitoring. Discusses the disposal of purged water generated during groundwater sampling and analysis. An owner of a landfill or surface impoundment submitting a no migration waiver petition must use a worst-case soil permeability factor in groundwater modeling. The constituent concentration, retardation factors, and constituent half-life must be evaluated when developing a model for a no migration waiver petition for a surface impoundment or a landfill (3004(o)(2)). The owner of a site with a complex hydrogeology should use a 2 or 3-dimensional model to support a no migration demonstration. Provides criteria for evaluating landfill composite bottom liner equivalency. Addresses the evaluation of a final cover slope using a soil loss equation. EPA recommends the use of glass vessels when performing compatibility testing on a high-density polyethylene (HDPE) liner. Scarifying and remolding do not meet the minimum technological requirements for a landfill secondary soil liner. A contingency plan must designate a sufficient number of emergency coordinators to provide 24-hour and vacation coverage. The federal regulations require a compressive strength test for stabilized wastes (going to a landfill) that pass the paint filter test only if true chemical stabilization has not occurred.
 
07/30/1988RCRA TEST METHODS & QA ACTIVITIESMemo
 Description: Provides clarification of an error in Method 3500. The SOXTEC extraction procedure is suitable for determining PCBs in soil. Discusses suitable techniques for determining total halogens in used oil. Contract Lab Program (CLP) participation does not constitute EPA certification.
 
06/09/1988SUBSTITUTION OF EXTRACTION SOLVENTS FOR METHYLENE CHLORIDEMemo
 Description: Methylene chloride is the only solvent able to satisfactorily extract semivolatile organic compounds for Method 3510.
 
05/31/1988SOXTEC EXTRACTION SYSTEM VS. SOXHLET EXTRACTION SYSTEM FOR PREPARATION OF PCB SAMPLESMemo
 Description: The petition of equivalency for the SOXTEC extraction system in place of the Soxhlet system for the preparation of samples for method 8080 for PCBs is granted.
 
05/18/1988COLORED GLAZE SOLIDS COLLECTED IN POTTERY MANUFACTURING OPERATIONSMemo
 Description: Extraction procedure (EP) (SUPERSEDED: See 261.24) toxic glazes incorporated into pottery are not solid wastes because they are used as an ingredient in an industrial process to make a product.
 
05/02/1988CALIFORNIA AUTHORIZATION - EVALUATION OF THE WASTE EVALUATION TESTMemo
 Description: California’s waste extraction test (WET) is equivalent to the extraction procedure (EP) for the toxicity characteristic. WET may be broader in scope (cover more waste) rather than more stringent (tighter control over covered waste) and thus affect EPA enforcement and authorization of California’s RCRA program.
 
03/30/1988SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTSMemo
 Description: Samples taken from turbid groundwater may not be valid. Proper well development requires that wells be clay and silt free. Discusses the use of polyvinyl chloride (PVC) in well construction, the calculation of purge volume, and Part 264, Appendix IX. An accelerated groundwater monitoring schedule can be used to bring a facility into compliance. The maintenance of a groundwater monitoring network may include the redevelopment of a well. Well maintenance should be included as a permit condition. Replacement units (e.g. landfills and surface impoundments) must be retrofitted to meet the minimum technological requirements. If a proposed alternative to a double liner does not meet the requirements of 264.221(c), the location characteristics or operating practices must compensate for the deficiency. A redundant flexible membrane bottom liner may be equivalent to the 3004(o)(5)(B) interim statutory design, thus meeting the 3004(o)(1) minimum technological requirements. Addresses the use of the Hydrologic Evaluation of Landfill Performance (HELP) model v. Moore’s Equation for calculating leachate volume when designing a collection system, the proposed modifications to the cap design to reduce erosion potential, and the use of a test plot to support alternative landfill design cover. A high-density polyethylene liner must be supported by a stable base. An owner of a petroleum refinery undertaking a land treatment demonstration must fully characterize the waste, including addressing the Skinner List constituents in the waste analysis plan. A properly conducted land treatment demonstration should include an evaluation of the waste degradation, transformation, and immobilization, as well as a toxicity study. A land treatment unit cannot accept sludges containing high concentrations of water if the soil moisture conditions cause saturation of the unit. Discusses the selection of principal hazardous constituents for a land treatment unit. An owner of a land treatment unit who has not demonstrated satisfactory treatment of hazardous constituents may need to close the unit. Addresses the presence of a high water table at a land treatment unit and the possible responses. An owner of an existing interim status land treatment unit may be eligible for an immediate full-scale permit if the land treatment demonstration addresses all of the necessary requirements. In states that are authorized for the RCRA base program but not for the HSWA provisions, construction cannot begin at a new facility until both the state and EPA permits are issued. The land disposal restrictions (LDR) program is a self-implementing portion of HSWA, superseding the permit as a shield provision. Permit content should be edited for applicability, importance, clarity, and precision prior to issuance. A minimum detection limit (MDL) can be used to establish background as a groundwater protection standard. Any component required in a RCRA facility investigation (RFI), such as monitoring releases not requiring immediate response, should be included as a permit condition. Monitoring wells installed as part of a HSWA corrective action may be designated as point of compliance wells. Permits containing corrective action conditions for groundwater treatment programs must specify methods of handling groundwater containing hazardous waste and must include pumping and removal requirements. Air stripping may not be an appropriate treatment method for groundwater contaminated with methyl isobutyl ketone. A permit or 3008(h) order should address the air emissions from treatment units such as an air stripper. Includes criteria for the referral of facilities to the Agency for Toxic Substances aND DISEASE REGISTRY (ATSDR) UNDER 3019. Emerging technologies, such as in-situ bio-reclamation, should be demonstrated as effective in pilot-scale field studies prior to approval. 264 Subpart F compliance monitoring standards should be applied to the verification monitoring at solid waste management units (SWMUs) during corrective action. A HSWA corrective action pe
rmit may include a technical feasibility clause discontinuing the program once contaminant levels can no longer be reduced. EPA discourages the approval of a waiver allowing the disposal of nonhazardous waste in a landfill that has lost interim status.
 
03/24/1988REGULATORY STATUS OF ECOSCINT A AND ECOSCINT OMemo
 Description: Liquid scintillation cocktails Ecoscint A and O are not listed, EP (extraction procedure) toxic (SUPERSEDED: See 261.24) or ignitable (D001), but data provided are not sufficient to make corrosivity (D002) or reactivity (D003) determination (SEE ALSO: RPC# 3/1/89-04). The generator is responsible for the hazardous waste determination.
 
02/03/1988PCB-CONTAMINATED WASTES, STABILIZATION OFMemo
 Description: Bulk liquid waste treated with absorbents or adsorbents must be tested with the paint filter liquids test (PFT) (3004(c)(1)) (SEE ALSO: 1RPC# 1/17/93-02). When a waste passes the PFT, it may be disposed in a landfill. When a waste fails the PFT, further chemical stabilization is required. Provides guidance on the level of adequacy for chemical treatment.
 
01/13/1988GUIDANCE IN DESIGNATING POHC'SMemo
 Description: The incinerability ranking used to designate principal organic hazardous constituents (POHCs) at incinerators can be based on many methods, including the heat of combustion or on the thermal stability index. Additional factors can be applied to POHC designation. Discusses surrogate compound availability. Includes an incinerability ranking.
 
12/31/1987TOTAL CONSTITUENT ANALYSIS TO DETERMINE HAZARDOUS CHARACTERISTICS OF WASTE SAMPLEMemo
 Description: Discusses the applications of totals analysis in lieu of TCLP. If guidance levels of the compound are not exceeded assuming 100% leachability, no further analysis is required. Provides the 100% leachability formula. Addresses the maximum theoretical extract concentration (MTEC) (SEE ALSO: RPC# 1/1/94-01).
 
12/21/1987ASTM STANDARDS IN THE RCRA PROGRAMMemo
 Description: Discusses ASTM standards that have been approved for use in the RCRA program (D445-86; D446-85a; D2015-77; D1888-78 Method A; D1888-78 Method B; D93-80; D3828-81).
 
12/04/1987ALLOWABLE HOLDING TIMES WHEN TESTING RCRA SAMPLESMemo
 Description: Discusses the holding time determination for RCRA samples. The holding time begins when the sample is generated. Addresses the holding times for the extraction procedure (EP) analysis, for volatile organics in groundwater using Method 8010, and semi-volatile organics in groundwater using Methods 3510 and 8270.
 
12/03/1987PAINT FILTER LIQUIDS TEST USED TO DETERMINE COMPLIANCE WITH THE CALIFORNIA LIST RESTRICTIONSMemo
 Description: EPA is considering the use of the paint filter liquids test, the extraction procedure, and the Toxicity Characteristic Leaching Procedure to determine compliance with the statutory California List land disposal restrictions (LDR) prohibition levels (SUPERSEDED: California list removed, see 62 FR 25997; 5/12/97).
 
11/20/1987LEAD-BASED PAINT RESIDUES AND CONTAMINATED SOILSMemo
 Description: Paint wastes are exempt household hazardous wastes (HHW) if they are generated by homeowners and not by contractors (SUPERSEDED: RPC# 3/1/90-06). HHW from federal agencies is not HHW. Certain material and soil contaminated with weathering lead based paint is characteristic for lead. If characteristic soil is actively managed, it is a hazardous waste. Discusses lead paint remediation methods (SEE ALSO: RPC# 3/7/95-01). A property owner is normally not required to characterize soil left on site. Addresses factors in determining if soil removal is required. On-site soil treatment needs a permit unless the generator is exempt (SEE ALSO: 61 FR 18779; 4/29/96).
 
11/18/1987TCLP IN THE LAND DISPOSAL RESTRICTIONS PROGRAM AND HAZARDOUS WASTE IDENTIFICATION PROGRAMMemo
 Description: TCLP was created for the land disposal restrictions (LDR) program for testing for solvents and dioxins, and for the toxicity characteristic.
 
11/17/1987COMPRESSIVE STRENGTH OF TREATED WASTES - USE OF SW-846 METHODS, WASTE IDENTIFICATIONMemo
 Description: EPA does not recommend that a specific compressive strength be incorporated into permits for wastes subject to the liquid absorption/adsorption treatment. The compressive strength should increase over time. Permit writers may require facilities to use SW-846 methods.
 
11/12/1987PULVERIZING / CRUSHING WASTE PRIOR TO EP TESTMemo
 Description: Metal rings and lids that are part of an ash wastestream should not be removed when testing a representative sample for the toxicity characteristic. Although pulverizing is inappropriate for metal objects, the particle reduction requirement in the extraction procedure (EP) (SUPERSEDED: see 261.24) is still in effect.
 
11/05/1987LEACHING TESTS FOR EVALUATING SOILS CONTAMINATED WITH LEADMemo
 Description: Method 1310 extraction procedure (EP) is used to determine if contaminated soils exhibit the toxicity characteristic (SUPERSEDED: see 261.24). Method 1312 for in-place soil and debris is under development. It may be appropriate for facility investigations and clean closure determinations. 1311 (TCLP) may not be appropriate for groundwater contamination of soil and debris.
 
10/20/1987RCRA TESTING TECHNIQUESMemo
 Description: Addresses the gas chromatograph/mass spectrometer suitability testing of RCRA Appendix VIII and Michigan List Analytes. Includes notes on laboratory safety and noxious fumes from nitric acid digestion. Discusses the standardization of method 8610, microwave oven safety, the 1988 Solid Waste Testing and Quality Assurance Symposium, the TCLP video, and the application of the structural integrity procedure when performing extraction procedure analyses.
 
10/08/1987ENVIRONMENTAL HAZARDS ASSOCIATED WITH BURNING HAZARDOUS WASTE IN CEMENT KILNSMemo
 Description: Cement kiln dust (CKD) generated during the use of hazardous waste fuel contains elevated lead levels but tends not to leach enough lead to fail the extraction procedure (EP) toxicity test (SUPERSEDED: see 261.24). EPA considers cement kiln dust to be nonhazardous under the Bevill exemption and does not plan on issuing specific guidance (SEE ALSO: 60 FR 7366; 2/7/95).
 
10/02/1987DELISTING POLICY ALLOWS EXCLUSION OF SEPARATE WASTE TREATMENT UNITS AT MULTI-UNIT FACILITIESMemo
 Description: Delistings allow the exclusion of separate waste treatment units at a multi-unit facility. Discusses the Oily Waste Extraction Procedure (OWEP) for oil and grease exceeding 1% (SEE ALSO: 261.24). Addresses the 6 month deadline for the submission of information before a petition dismissal. A withdrawal prevents a denial notice in the Federal Register.
 
09/16/1987SW-846 METHODS MANUALMemo
 Description: The use of SW-846 methods is generally not required except for quality assurance/quality control procedures and determining if the waste is characteristic. Discusses sampling, analysis for delisting petitions, incinerator trial burns, and determining if bulk or containerized waste contains free liquids prior to disposal in a landfill.
 
09/01/1987SW-846 TEST METHOD 3060Question & Answer
 Description: Test method 3060 (used to determine total concentration of hexavalent chromium) was dropped from the Third Edition of SW-846 because it yielded inconsistent results from sample to sample. The method may still be used if spike recoveries demonstrate that it works. There is no replacement method.
 
09/01/1987TREATMENT OF INFECTIOUS WASTEQuestion & Answer
 Description: Provides an overview of the treatment methods for infectious wastes. While RCRA 1004 includes within the hazardous waste definition wastes with infectious characteristics, currently there are no federal regulations for infectious waste management (SEE ALSO: 60 FR 33912; 6/29/95).
 
08/11/1987METHODS 1310 AND 1330: EXTRACTION PROCEDURE AND EXTRACTION PROCEDURE FOR OILY WASTEMemo
 Description: Method 1310 extraction procedure (EP) is the only method to be used for determining the applicability of the toxicity characteristic, even for oily waste (SUPERSEDED: See 261.24). Method 1330 (EP for oily waste) may be used for delisting.
 
08/07/1987WASTES FROM ENVIRONMENTAL CHEMISTRY LABORATORYMemo
 Description: High temperature incineration is the recommended method of management for lab wastes that are not listed hazardous waste and that do not exhibit any characteristics, even though they are contaminated with dioxins.
 
07/01/1987CALIFORNIA LISTQuestion & Answer
 Description: The California List prohibition on nickel applies whether the nickel is contained chemically or physically in hazardous wastes. The ban is based on the total concentration of nickel in filtrate generated using the paint filter liquids test. A facility can precipitate nickel to a lower concentration in wastewater (SUPERSEDED: California list removed, see 62 FR 25997; 5/12/97).
 
07/01/1987ON-SITE TREATMENT BY GENERATORS UNDER 262.34Memo
 Description: Generators can treat in accumulation tanks or containers without a permit provided the treatment occurs in units complying with Subparts I or J of 265. Open burning in drums or tanks is not allowed under 262.34. Subparts I and J limit the type of treatment that can occur. Burning in open drums is not allowed because open burning (defined in 260.10) is a method of disposal. Open burning (thermal treatment) of waste, except for explosives, is prohibited under 265.382.
 
06/23/1987USE OF THE METHOD OF STANDARD EDITIONSMemo
 Description: SW-846 requires that the method of standard editions be used whenever the percent recovery of a matrix spike is outside the range of 75-125%. The method of standard additions is required, in all cases, when analyzing extraction procedure (EP) toxicity extracts (SEE ALSO: 57 FR 55115; 11/24/92).
 
06/08/1987F006 WASTES, VHS AND GROUNDWATER MONITORING DATA TO EVALUATE A DELISTING PETITION FORMemo
 Description: The vertical and horizontal spread (VHS) model is used in delistings. A delisting for wastes managed in on-site waste management units must have a groundwater monitoring system in place and 4 quarters of data. Oily Waste Extraction Procedure (OWEP) is used for wastes with 1% oil and grease (SEE ALSO: 261.24).
 
04/16/1987CHARACTERISTIC OF IGNITABILITYMemo
 Description: There are no test methods for ignitable (D001) soils or ignitable solids (SUPERSEDED: SW-846 method 1030 finalized in 6/13/97; 62 FR 32451). Only liquids that flash are ignitable. Liquids that boil at low temperatures cannot be evaluated for flash.
 
03/30/1987SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTSMemo
 Description: A native soil foundation does not constitute a liner for the purposes of the 3005(j)(2) waiver. A 264.282 compatibility demonstration applies to both hazardous and nonhazardous waste. Addresses HSWA waste minimization requirements (3002(b)) and the application of sludge to land treatment units. The identification of principal hazardous constituents for land treated wastes must include all constituents that may enter the waste stream. A land treatment unit performance evaluation must include the unit’s ability to treat and degrade organic constituents, as well as its ability to immobilize heavy metals. Provides guidance on the frequency of soil pore liquid sampling at land treatment units (unsaturated zone monitoring) and guidance on screening groundwater monitoring wells. QA/QC methodology at a land treatment unit should include verification of the organic constituent analysis by gas chromatography/mass spectroscopy (GC/MS). Includes guidance on the content of construction quality assurance plans. A person who conducts quality assurance measures for surface impoundments, waste piles, and landfills should be independent of the construction contractor. Discusses the use of Method 9090 for compatibility testing of liner materials with waste or leachate. All man-made materials that contact waste or leachate should be subjected to the immersion test portion of 9090. A sample of waste or leachate used in compatibility testing must be representative of the actual waste or leachate managed in the surface impoundment, waste pile, or landfill. A concrete pad cannot be equivalent protection. If the design slope of a final landfill cover exceeds 3-5%, the applicant must demonstrate that soil erosion will not be excessive and may need to perform a slope stability analysis. Waste and soil settlement must be included in calculations for the final landfill cover design to be substituted for a waste pile liner as equivalent protection under 3015(a). A flexible membrane liner should not be used in a final cover when the landfill is unusually deep and slopes are steep. Clean, not contaminated, soil should be used for the final cover. A leachate collection system design should be based on realistic infiltration rates. Geogrid and geotextile materials used in place of conventional drainage materials for a landfill must have an equivalent drainage capacity of a one-foot layer of compacted sand. Berms constructed of manufactured slag should not contain hazardous constituents. For landfills, the use of a composite primary liner below the primary synthetic liner is allowable. An owner of a land treatment unit who cannot establish vegetative cover may use an alternate closure procedure. A facility cannot extend closure in order to receive nonhazardous waste (SUPERSEDED: see current 264.113(d)). Addresses the role of the Agency for Toxic Substances and Disease Registry (ATSDR) in exposure information and evaluation. The review of Exposure Information Reports should be coordinated with ongoing RCRA Facility Assessments.
 
03/06/1987AUTOMOTIVE FLUIDS, REGULATION OFMemo
 Description: Automotive fluids are not listed hazardous waste, but they may be characteristic. Some brake and automatic transmission fluids are ignitable (D001). Used crankcase oil may be ignitable and may exhibit EP (extraction procedure) for lead (SUPERSEDED: see 261.24). Used oil (UO) that is recycled by burning is subject to 266 Subpart E; other UO recycling is exempt (SUPERSEDED: see Part 279). Brake fluid, power steering fluid, and automatic transmission fluid would all be considered UO. Antifreeze and windshield wiper fluid are not UO (SEE ALSO: 279.1).
 
03/06/1987AUTOMOTIVE FLUIDS, STATUS OFMemo
 Description: Automotive fluids are not listed hazardous waste, but they may be characteristic. Some brake and automatic transmission fluids are ignitable (D001). Used crankcase oil may be ignitable and may exhibit EP (extraction procedure) for lead (SUPERSEDED: see 261.24). Used oil (UO) that is recycled by burning is subject to 266 Subpart E; other UO recycling is exempt (SUPERSEDED: see Part 279). Brake fluid, power steering fluid, and automatic transmission fluid would all be considered UO. Antifreeze and windshield wiper fluid are not UO (SEE ALSO: 279.1).
 
12/30/1986SAMPLING PLAN FOR DELISTING PETITION ADDRESSING HSWA REQUIREMENTS FOR ANALYZING FOR APPENDIX VIII COMPOUNDSMemo
 Description: Addresses sampling parameters in delisting petitions. If the amount of oil and grease in sludge exceeds one percent, the Oily Waste Extraction Procedure (OWEP) should be used. OWEP uses a dual solvent extraction instead of a dilute acetic acid solution which is used in the extraction procedure (EP) (SEE ALSO: 261.24).
 
12/23/1986BURNING CHARACTERISTIC OFF-SPECIFICATION PETROLEUM PRODUCTS FOR ENERGY RECOVERYMemo
 Description: Listed or characteristic off-specification CCPs that are themselves fuels are not solid wastes when burned for energy recovery. Burning in an incinerator is burning for destruction, not energy recovery. Fuel mixed with used oil would be subject to regulation as off-specification used oil if the flash point is under 100 F (SEE ALSO: Part 266).
 
12/22/1986PROPOSAL OF UNREGULATED DIOXIN WASTESMemo
 Description: Incineration is an appropriate management method for nonhazardous dioxin wastes (wastes that are not characteristic and are not covered by F-listings).
 
10/30/1986HAZARDOUS WASTE CLASSIFICATION OF PAINTED CIRCUIT BOARDSMemo
 Description: Although printed circuit boards are not specifically listed, they commonly exhibit the extraction procedure (EP) toxicity characteristic (SUPERSEDED: See 261.24) for lead that leaches from the solder (SEE ALSO: 261.4(a)(14) exclusion for shredded circuit boards).
 
10/22/1986INCINERTION OF LABORATORY WASTES CONTAMINATED WITH TCDDMemo
 Description: Lab wastes such as paper towels, pipets, and laboratory gloves, that have come into contact with TCDD laboratory standards are not covered by the dioxin listings, F020-F023, F026-F028. Incineration may be a reasonable method of disposal for these wastes.
 
09/30/1986GLASS FIBER FILTERS FOR USE IN CONDUCTING THE TOXICITY CHARACTERISTIC LEACHING PROCEDURE (TCLP)Memo
 Description: The denial of a request to add glass fiber filters to the list of filters is deemed suitable for TCLP purposes.
 
09/26/1986GC/MC RATHER THAN GC FOR GROUNDWATER MONITORING PURPOSESMemo
 Description: States may require the use of a specified analytical methods for groundwater monitoring. Gas chromatography and mass spectrometry (gc/ms) that are used for organic analyses may not be consistent with the Federal program.
 
09/03/1986LABORATORY EQUIPMENT USED IN CONDUCTING THE TOXICITY CHARACTERISTIC LEACHING PROCEDURE (TCLP)Memo
 Description: A tentative EPA decision to list a zero-headspace extractor (ZHE) to the list of suitable extractors for conducting evaluations of volatiles in the TCLP.
 
06/19/1986RISK-BASED METHODOLOGIES ON LAND DISPOSAL RESTRICTIONSMemo
 Description: A risk-based approach to the development of the land disposal restrictions (LDR) regulations is not appropriate because the statute contains presumption against the land disposal of untreated waste. Risk-based methodologies are an effective tool in developing regulations to identify hazardous waste.
 
05/05/1986LABORATORY EQUIPMENT USED TO RUN THE TOXICITY CHARACTERISTIC LEACHING PROCEDURE (TCLP)Memo
 Description: A discussion of the steps necessary for the designation of a substitution TCLP zero-headspace extractor.
 
04/30/1986FLUORESCENT AND MERCURY VAPOR LAMPS AND CLASSIFICATION USING THE EP TOXICITY TESTMemo
 Description: Fluorescent and mercury vapor lamps may exhibit the toxicity characteristic (TC) for mercury as determined using the extraction procedure (EP) (SUPERSEDED: See 261.24) (SEE ALSO: RPC# 12/7/92-01). Some States regulate waste based on total mercury, not leachable mercury.
 
04/28/1986GENERATOR USE OF TOTAL CONSTITUENT ANALYSIS IN LIEU OF THE EP OR TCLP TESTSMemo
 Description: A generator may use knowledge to make a characteristic determination, including the total waste concentration. When using total waste analysis in lieu of the extraction procedure (EP) or TCLP tests, the generator must assume all the contaminant present in the waste will migrate or leach into a liquid extract. A discussion of the maximum theoretical extract concentration (MTEC) (SEE ALSO: RPC# 1/1/94-01).
 
04/07/1986ENVIRONMENTAL RELEASES FROM WOOD PRESERVING PLANTSMemo
 Description: A summary of EPA regulations applicable to releases from wood preserving facilities. The wood preserving process wastewater effluent is subject to the CWA (SEE ALSO: 261.4(a)(9)). The storage or mixing tanks, kraft bags can be empty containers under section 261.7. Discusses the applicability of the F020, F021, F026, F027 listings. Dioxin wastes are acutely hazardous and are subject to the 1 kg threshold. Wastewater treatment sludges from creosote and pentachlorophenol (PCP) are K001. An explanation of the closure of units used to treat these process wastewaters. The applicability of the EP (extraction procedure) toxicity characteristic (SUPERSEDED: see 261.24) to wood preserving wastes. A discussion of section 3004(u) and (v) corrective action at wood preserving facilities.
 
04/07/1986WOOD PRESERVING AND SURFACE PROTECTION FACILITIES, CONTROLLING ENVIRONMENTAL RELEASES FROMMemo
 Description: A summary of EPA regulations applicable to releases from wood preserving facilities. The wood preserving process wastewater effluent is subject to the CWA (SEE ALSO: 261.4(a)(9)). The storage or mixing tanks, kraft bags can be empty containers under section 261.7. Discusses the applicability of the F020, F021, F026, F027 listings. Dioxin wastes are acutely hazardous and are subject to the 1 kg threshold. Wastewater treatment sludges from creosote and pentachlorophenol (PCP) are K001. An explanation of the closure of units used to treat these process wastewaters. The applicability of the EP (extraction procedure) toxicity characteristic (SUPERSEDED: see 261.24) to wood preserving wastes. A discussion of section 3004(u) and (v) corrective action at wood preserving facilities.
 
03/21/1986CHROMIUM WASTES: TRIVALENT AND HEXAVALENT, CHROMIUM IN TANNERY WASTESMemo
 Description: The extraction procedure (EP) toxicity based on the total chromium (hexavalent and trivalent) (SUPERSEDED: see 261.24). Trivalent chromium oxidizes to hexavalent when drinking water is treated with chlorine. Tannery wastes containing solely trivalent chromium are excluded. The extraction procedure thresholds are 100X the drinking water standard.
 
03/14/1986SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTSMemo
 Description: The owner of a landfill applying for the liner exemption must show that the unit prevents migration of hazardous constituents. The bulk treatment for hazardous liquids cannot include absorption. Bulk liquids that have been chemically stabilized must pass the paint filter liquids test. Guidance on filtering groundwater prior to analysis. Brass bailers should not be used when sampling groundwater for metals. Guidance on the use of mathematical models when aquifers have unique features. The definition of a solid waste management unit (SWMU) includes the areas with routine and systematic releases. The use of surface water limits as Alternate Concentration limits (ACLs). Guidance on determining the potential point of exposure for ACL applications. The use of modeling information in establishing ACLs. ACL guidance allows grouping of hazardous constituents. Activated carbon filtration may not be appropriate for pentachlorophenol (PCP)-contaminated groundwater. Corrective action programs for regulated land disposal units must be part of a facility’s permit. The owner of a facility who counterpumps contaminated groundwater during corrective action must handle the contaminated groundwater as a hazardous waste, the Part B application must include groundwater management procedures.
 
03/12/1986DETECTION LIMIT FOR EP-LEACHATE CONCENTRATION OF SELENIUMMemo
 Description: The detection limit for the extraction procedure (EP) leachate concentration of selenium is in petition.
 
02/04/1986REGULATORY STATUS OF PHOTOGRAPHIC FILMS AND PAPERS UNDER RCRA SUBTITLE CMemo
 Description: Photo film and paper are not listed hazardous waste (HW). They are HW if characteristic. Data suggest they are usually not toxic by the extraction procedure (EP) (SUPERSEDED: See 261.24). The generator must make the determination. Even if not contaminated, used photo film and paper removed from service to recycle are spent materials. Unless characteristic, spent material status irrelevant.
 
01/29/1986LABORATORY EVALUATION PROGRAMMemo
 Description: EPA has a voluntary self-auditing program designed to allow laboratories to evaluate their capability to analyze RCRA/CERCLA samples using SW-846 methods.
 
01/24/1986WASTE-DERIVED FUELS AT IRON AND STEEL MILLS AS PRODUCTS OR WASTE FUELS, INFORMATION REQUIREDMemo
 Description: The classification of waste-derived coke/coal tar as a product or waste-derived fuel turns on whether recycling significantly affects the composition, whether waste-derived coke has significantly higher levels of hazardous constituents. The list of constituents to be analyzed, with SW-846 methods (SEE ALSO: 261.4(a)(10)).
 
01/07/1986EXCLUSION FROM REGULATION FOR CHARACTERISTIC AND LISTED WASTES - LEACHATE LEVELS; DELISTING CRITERIA/LEACHATE LEVELSMemo
 Description: There is delisting criteria for variable constituent levels depending on waste volume. For delisting, EPA considers the original listing constituents and other factors. A mixture of solid waste (SW) and hazardous waste (HW) listed solely for a characteristic is not HW if not characteristic under the 261.3(a)(2)(iii) mixture rule exemption for wastes listed solely for exhibiting a characteristic (SEE ALSO: 268.3; 66 FR 27266; 5/16/01). The leachate test used depends on the nature of the waste. Discussion of the use of extraction procedure (EP) for Oily Waste (SUPERSEDED: See 261.24).
 
12/01/1985USED OIL AS DUST SUPPRESSANTQuestion & Answer
 Description: Used oil that exhibits a characteristic of extraction procedure (EP) toxicity (SUPERSEDED: See 261.24) can be used as a dust suppressant provided it has not been mixed with hazardous waste (SUPERSEDED: See RPC# 3/1/90-05 and 279.82).
 
10/21/1985EP TOXICITY TEST EXTRACTION MEDIUM, REQUESTED CHANGE INMemo
 Description: The extraction medium in the extraction procedure (EP) (SUPERSEDED: see 261.24) may not be appropriate for determining the hazardousness of oil shale. A listing process may be used if the data indicates a sufficient threat.
 
10/03/1985APPROPRIATENESS OF THE EP/TCLP SIMULATION OF CO-DISPOSAL SITUATION FOR MINING WASTES; CHARACTERISTIC TESTS FOR DETERMINING THE HAZARDOUS CHARACTERISTICS OF MINING WASTESMemo
 Description: There is no determination on the appropriate tests used to identify mining or Bevill exempt mining and mineral processing wastes to be regulated as hazardous waste. TCLP is designed to simulate the leachability of industrial waste that is co-disposed with sanitary waste. Although the disposal scenario may be incompatible with mining waste disposal, similar generation of acids warrants TCLP or stronger. Mining wastes generate acidic leachate upon exposure to air.
 
10/01/1985WASTE MINIMIZATIONQuestion & Answer
 Description: The 3002(b) waste minimization requirements are self implementing and leave the choice of a method to the generator. Waste exchanges, recycling of solvents, on-site reuse and off-site recycling are all legitimate waste minimization.
 
09/01/1985EP TOXICITY FOR OILY WASTESQuestion & Answer
 Description: Method 1330 “Oily Waste Extraction Procedure” should only be used when requested by EPA for delisting purposes. Method 1330 cannot be used in waste identification as a substitute for the extraction procedure (EP) (SUPERSEDED: See 261.24) when analyzing oily wastes.
 
09/01/1985NON-HAZARDOUS LIQUIDS BANQuestion & Answer
 Description: The ban on nonhazardous liquids in landfills applies to any waste that is liquid or contains free liquids as determined by the paint filter liquids test (Method 9095). Nonhazardous liquid solidified with absorbents can be land disposed if no free liquids (SUPERSEDED: See 264.314, 265.314).
 
08/07/1985LIQUID HAZARDOUS WASTES IN LANDFILLSMemo
 Description: The paint filter liquids test is used to verify no free-standing liquid. A definition of free-standing liquid vs. free liquid. Eliminate free-standing liquid before placement in landfill (3004(c)(1)). Stabilization of liquid on manifested solid is treatment requiring permit unless it meets addition of absorbent exemption.
 
07/16/1985SULFIDE REACTIVITY CHARACTERISTICMemo
 Description: There is no approved test method for the reactivity characteristic (D003). 500 mg/kg available sulfide is adopted as the interim action level (SUPERSEDED: see RPC# 4/21/98-01). A surface impoundment which is a neutralization pond receiving only corrosive waste (D002) is exempt from groundwater monitoring.
 
07/01/1985EP TOXICITY CHARACTERISTIC AMENDMENTSQuestion & Answer
 Description: A discussion of draft TCLP. TCLP will be suitable for determining the mobility of organic and inorganic compounds present in liquid, solid, and multiphase wastes.
 
06/30/1985RCRA METHODS AND QA ACTIVITIES (NOTES)Memo
 Description: A discussion of metal determination in groundwater (total recoverable, dissolved metals). Organic determinations are made only on groundwater samples that have not been filtered. An overview of dioxin method 8280. Discusses the performance audits on gas samplers (organic cylinder gases). An overview of Method 3540 validation. Discusses the reactivity test methods.
 
05/01/1985LIQUIDS AND FREE LIQUIDS, DEFINITION OFQuestion & Answer
 Description: The paint filter test (method 9095) is used to determine if a material is a liquid under section 3004(c)(3) (Liquids in Landfills). EPA believes that Congress intended the term “liquid” in section 3004(c)(3) to encompass free liquids as well as liquids.
 
05/01/1985WASTE ANALYSISQuestion & Answer
 Description: The EPA does not require the use of SW-846 for TSDF waste analysis under sections 264.13 and 265.13.
 
04/23/1985RCRA METHODS AND QA ACTIVITIES (NOTES)Memo
 Description: Delisting public meetings were held. SW-846 was updated. A discussion of the development of new methods, reevaluation of existing methods: 9022, 450.1, 8030, 8090, 8280. An overview of using gas chromatography/Fourier transform infrared protocol for semivolatile organics. Discusses the methods for compounds that do not use gas chromatograph. EPA is developing a sorbent pressure test method to determine if sorbents will release liquids under simulated landfill pressure.
 
02/26/1985AQUEOUS SOLUTION, IGNITABILITY DEFINEDMemo
 Description: The alcohol exclusion was created for beverages, but is broader as alcohol is defined by functional hydroxyl group [-OH]. Use the paint filter liquids test to extract free liquid (SEE ALSO: 59 FR 46052; 8/31/93 and 60 FR 3089; 1/13/95). Use standard lab techniques to identify aqueous solutions (50% water by weight).
 
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).
 
12/20/1984RCRA METHODS AND QUALITY ASSURANCE ACTIVITIES (NOTES)Memo
 Description: The RCRA Laboratory Evaluation Program is outlined. The rationale for the proposal of standard methods for testing groundwater at hazardous waste facilities is discussed (49 FR 38786; 10/1/84). The analytical report on Method 3030 - acid digestion of oils, greases, and waxes as well as the Waste Analysis Plans Guidance Manual, including “boundary conditions” and “tolerance limits,” are discussed. The U.S. Gap Test and U.S. Internal Ignition Test are under evaluation to determine if a solid waste is explosive.
 
12/18/1984DELISTING TESTING REQUIREMENTS, CYANIDE AND OTHER WASTES, STEEL INDUSTRYMemo
 Description: The EP (extraction procedure) toxicity test is not applicable to wastes with greater than 1 percent oil and grease. Delisting petitions must test photodegradable cyanide when total (complexed) cyanide exceeds 10 ppm (SEE ALSO: current 261.24).
 
12/11/1984ELECTROPLATING SLUDGE, EXCLUSION PETITIONMemo
 Description: For delistings of an electroplating sludge, total, free (amenable to chlorination), leachable, and photodegradable cyanides must be analyzed. Total and free cyanides are analyzed using Method 9010. Leachable cyanides are analyzed using the extraction procedure (EP) toxicity test (SUPERSEDED: See 261.24). Photodegradable cyanides are analyzed using Method 9011.
 
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).
 
11/13/1984F006 DELISTING PETITION INFORMATION REPORTMemo
 Description: Discussion of examples of data necessary for EPA to consider a F006 delisting petition. Required data include a description of raw material used, manufacturing process, disposal methods, personnel qualifications, sampling, and constituent analyses.
 
09/11/1984BLASTING CAPS AS REACTIVE WASTESMemo
 Description: Off-specification blasting caps are reactive (D003). Note 5 in 2.1.3 of SW-846 incorrectly states that blasting caps in quantities less than 1000 are not hazardous waste.
 
08/16/1984ENFORCING GROUNDWATER MONITORING REQUIREMENTS IN RCRA PART B PERMIT APPLICATIONSMemo
 Description: Regional enforcement personnel may assign low priority to certain technical violations of groundwater monitoring regulations, including the failure to monitor for constituents that are not detectable in groundwater and constituents for which there are no EPA test methods (SUPERSEDED: SEE 264.93(a) and (b)). Constituents for which accepted test procedures exist must be analyzed despite the expense of the procedure. Facilities must monitor for these constituents even if records imply they were never managed at the facility.
 
08/01/1984LANDFILLS WITH EP TOXIC LEACHATE, REGULATION OFQuestion & Answer
 Description: Once leachate is collected, subsequent management is regulated if the leachate is a hazardous waste. If extraction procedure (EP) (SUPERSEDED: see 261.24) toxic leachate collected from a sanitary landfill is pumped back into the landfill, the landfill is subject to TSDF requirements (SUPERSEDED: see 258.28(a)(2)).
 
07/01/1984EP TOXICITY TEST ON OILY WASTESQuestion & Answer
 Description: Conducting the extraction procedure (EP) toxicity test (SUPERSEDED: see 261.24) on oily wastes that do not pass through the filter is outlined.
 
07/01/1984HAZARDOUS WASTE INCINERATION/SW-846 METHODQuestion & Answer
 Description: “Sampling and Analysis Methods for Hazardous Waste Incineration” will not be issued as Appendix A to SW-846, but it will be incorporated throughout the document (SEE ALSO: Chapter 7 of SW-846).
 
07/01/1984WASTE AS LIQUID OR SOLID, DETERMINATION OFQuestion & Answer
 Description: The phase of a waste should be determined just prior to landfill disposal. If a waste liquefies during transportation, it is proper to allow a shipment of containers to stabilize or solidify before performing the free liquids test (SEE ALSO: 40 CFR 268.3).
 
05/25/1984ANALYTICAL METHODS FOR PETROLEUM REFINING RESIDUES AND WASTESMemo
 Description: Guidance is provided on the analytical methods for petroleum refinery wastes that are the subject of a land treatment permit application (cover letter for “Handbook for the Analysis of Petroleum Refinery Residues and Waste”). A land treatment permit application should include total metal concentrations, not extraction procedure (EP) results.
 
04/23/1984RCRA METHODS AND QUALITY ASSURANCE ACTIVITIES (NOTES)Memo
 Description: The spot-check program to collect samples to verify delisting petition data is discussed. A recommendation that audit cylinders containing organic compounds be used during all source measurement programs is provided. Problems with spike recovery for metals in Method 3030 - Acid Digestion of Oils, Greases, and Waxes and pH adjustment for the extraction procedure (EP) are outlined. Materials that do not pass through 0.45 um filter are solids and must be extracted. The pH of oil and grease is discussed. It is impossible to determine the pH of non-aqueous materials. Unless specifically stated in the method, results are to be reported “as received,” and a sample is not dried before analysis.
 
04/04/1984ANALYTICAL METHODS/EP TOXICITY TEST/REFERENCE STDS.Memo
 Description: The adjustment of pH during the extraction procedure (EP) toxicity test should be conducted with a pH meter, not pH paper (SUPERSEDED: see current 261.24). Extract digestion, testing manufactured articles that are structurally resistant to crushing, and methods evaluation are discussed. EPA is developing methods for ignitable (D001) solids (SEE ALSO: SW-846 method 1030 finalized in 6/13/97; 62 FR 32451), liquids with flash points less than 60 degrees C, and reactive gases - cyanide and sulfide. EPA is developing a “Waste Analysis Plans Guidance Manual.” The use of reference standards is discussed.
 
02/23/1984HAZARDOUS WASTE TREATMENT/STORAGE TANKS, PERMITTINGMemo
 Description: Permits must specify a minimum shell thickness for all treatment and storage tanks. Methods exist for determining the thickness for various tanks and are provided. Tanks must be inspected internally before the issuance of a draft permit and during their active life (SUPERSEDED: see 51 FR 25422; 7/14/86).
 
07/27/1983WASTE BATTERIES AND CELLSMemo
 Description: Waste batteries that are resistant to corrosion may be tested for the extraction procedure (EP) (SUPERSEDED: See 261.24) toxicity characteristic without particle reduction. Addresses the saltwater test to measure the corrosion resistance of a product (battery casing).
 
07/01/1983MANUFACTURED ARTICLES TEST FOR EP TOXICITYQuestion & Answer
 Description: Manufactured articles are tested using the extraction procedure (EP) (SUPERSEDED: see 261.24) by reducing the size of the representative sample to pieces which can pass through a 9.5 mm sieve, then performing the extraction step. Corrosion-resistant batteries (battery) do not have to be reduced in size prior to testing. Provides guidance on determining corrosion-resistance.
 
02/01/1983PH MEASUREMENT ON PARTIAL SOLIDSQuestion & Answer
 Description: Material that contains free liquids (using the paint filter liquids test) can be measured for pH to evaluate corrosivity (SEE ALSO: RPC# 4/23/93-01; RPC# 10/20/93-01).
 
06/28/1981LIQUID WASTE, DEFINITION OFMemo
 Description: Liquids are materials that pass through a .45 micron filter at a pressure differential of 75 psi. Different phases should be evaluated separately based on the definition of a liquid. Free liquids are a subset of liquids. Liquids are ignitable (D001) if they contain or consist of liquids with a flash point below 60° C (SEE ALSO: 261.21).
 
06/18/1981FLASH POINT TESTS AND THE IGNITABILITY CHARACTERISTICMemo
 Description: EPA recommends the Pensky-Martens or Setaflash Closed Cup Testers to determine the flash point of potentially ignitable solid waste (D001). The Tag Closed Cup Tester is not a suitable alternative for wastes which are very viscous, that skin over, or that tend to stratify or contain suspended solids.
 
06/17/1981EXTRACTION PROCEDURE TOXICITY TESTMemo
 Description: An acceptable extractor for the extraction procedure (EP) will impart sufficient agitation to the mixture to not only prevent stratification of the sample and extraction fluid, but also insure that all sample surfaces are continuously brought into contact with the well-mixed extraction fluid.
 
05/29/1981REGULATION OF DRYING BED SOLIDSMemo
 Description: Denial of petition to block applicability of extraction procedure (EP) (SUPERSEDED: See 261.24) to drying bed solids since these wastes could leach hazardous levels of cadmium and lead to groundwater if mismanaged.
 
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