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Document DateDocument TitleDocument Type
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).
 
12/31/1986ENFORCEMENT POLICY ON WASTE BURNING FOR ENERGY RECOVERYMemo
 Description: Waste with a heating value below 5000 Btu/lb is not a bona fide fuel and is considered to be incinerated when burned in a BIF. The 5000 Btu/lb criterion of the sham recycling policy does not apply to each individual chemical or constituent of the waste, but applies to the aggregate waste as generated before mixing (SUPERSEDED: see RPC# 11/8/94-01).
 
12/31/1986SPECIAL MATERIALS DISPOSED OF IN LANDFILLS: BATTERIES, CAPACITORS, LAB PACKSMemo
 Description: Batteries and capacitors are exempt from the landfill containerized liquid requirements. They do not need to be 90% full, crushed, or shredded before disposal (SEE ALSO: Part 273).
 
12/30/1999FEES FOR COLLECTION AND RECYCLING OF USED MOTOR OILMemo
 Description: Used oil management standards do not include provisions for the assessment of fees for collection and recycling of used motor oil.
 
12/30/1992APPLICATION OF THE BIF RULE TO HERITAGE ENVIRONMENTAL SERVICES, INC., LEMONT, ILLINOISMemo
 Description: Unused propellant mixture (butane and propane) from aerosol cans is not a solid waste when it is burned for energy recovery because butane and propane are normally used as fuels. Material remaining in a partially used can is off-specification product that is being burned for its intended use. The burning of the mixture is not subject to the BIF regulations under Part 266, Subpart H.
 
12/30/1991PETITION TO DELIST XENIUM FIBERGLASS CORPORATION WASTEMemo
 Description: The delisting process generally takes two years. Addresses minimum delisting petition requirements. A delisting petition is not necessary for waste which is no longer hazardous via the 261.3(a)(2)(iii) exemption for mixtures of solid waste and hazardous waste listed solely for a characteristic that are no longer characteristic (SEE ALSO: 268.3; 66 FR 27266; 5/16/01). The generator is responsible for demonstrating that an exempt mixture remains nonhazardous and for classification as legitimately used, reused, recycled, or reclaimed.
 
12/30/1986DRAINS AND TRENCHES ASSOCIATED WITH TANK SYSTEMSMemo
 Description: In-building floor drains and outside-building trenches that are used to transfer hazardous waste to inground storage tanks comprise a tank system that requires secondary containment. Drains and trenches are ancillary equipment. Trenches may also be sumps that require secondary containment.
 
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).
 
12/30/1986TECHNICAL SUPPORT DOCUMENT FOR BDATMemo
 Description: The treatment standards for spent solvents do not require the use of a particular technology. The best demonstrated available technology (BDAT) background document for F001-F005 spent solvents provides information on the applicable technologies used to meet land disposal restrictions (LDR) standards and serves as a basis for decisions of treatment variances.
 
12/30/1986CONTAINERIZED AND BULK HAZARDOUS LIQUIDS IN RCRA LANDFILLSMemo
 Description: Any absorbent, biodegradable or non-biodegradable, may be used for the treatment and disposal of free liquids in a landfill (SUPERSEDED: see 57 FR 54452; 11/18/92, and RPC# 11/17/93-02).
 
12/30/1985INTEGRAL DESIGN STANDARD IN BOILER DEFINITION (LUBRIZOL)Memo
 Description: A rotary bed furnace with secondary combustion and an attached waste heat boiler does not meet the integral design standard of boiler definition nor the fluidized bed or process heater exemption. The unit is an incinerator. The boiler variance is not appropriate for furnaces ducted to heat recovery boilers.
 
12/30/1980AEROSOL CANS, RCRA REGULATON OFMemo
 Description: Puncturing, crushing, or shredding of non-empty aerosol cans is not treatment since the materials inside, not the cans, are hazardous. The residues inside are regulated if they are listed or characteristic. The cans themselves are not regulated unless they are mixed with waste (SUPERSEDED: see RPC# 10/7/93-05).
 
12/29/1986ELECTRIC ARC FURNACE DUST AFTER ENCAPSULATION TREATMENT PROCESSMemo
 Description: Bodner Metal and Iron’s electric arc furnace dust is K061 until it is delisted. Any waste for which delisting is sought must be evaluated for the originally listed constituents of concern and any Appendix VIII constituents reasonably expected to be present, as well as hazardous waste characteristics.
 
12/29/1986SURFACE IMPOUNDMENTS VIS-A-VIS NPDES-PERMITTED DISCHARGE POINTSMemo
 Description: A surface impoundment managing hazardous waste and that was not created by impounding water from “water of the US” is subject to RCRA. An impoundment located downgradient of an NPDES discharge point is regulated under CWA. Permit conditions are established by an EPA officer, not by the TSDF owner or operator.
 
12/29/1982LAND DISPOSAL PERMIT STRATEGYMemo
 Description: Discusses the historical priorities for permitting of land disposal units (surface impoundments, waste piles, land treatment units, and landfills).
 
12/28/2000USE OF RECYCLED GUARDRAILS AND GUARDRAIL POSTSMemo
 Description: The Comprehensive Procurement Guidelines (CPG) program (RCRA 6002) and Executive Order 13101, Greening the Government Through Waste Prevention, Recycling, and Federal Acquisition, require government agencies to purchase recycled-content and other environmentally-preferable products. EPA has not designated guardrails in CPG.
 
12/28/2000DISPOSAL OF VIDEO MONITORS IN LANDFILLSMemo
 Description: EPA is exploring ways of encouraging greater recycling of cathode ray tubes (CRTs) and electronic devices. EPA is developing regulation under RCRA that would promote recycling of CRTs and reuse and recycling of CRT glass.
 
12/28/1987F006 LISTING FOR PICKLING AND ETCHING WASTES AND DELISTING ISSUESMemo
 Description: Wastewater treatment sludges from aluminum etching are exempt from the F006 listing. Sludges are hazardous if they are mixed with spent pickle liquor (K062) or with other listed wastes.
 
12/28/1987REGULATORY STATUS OF LIME-STABILIZED WASTE PICKLE LIQUOR SLUDGEMemo
 Description: By narrowing the K062 listing, EPA narrowed the derived-from rule exemption for lime-stabilized waste pickle liquor sludge (LSWPLS). The exemption does not apply if K062 is treated with other listed wastes. If the spent pickle liquor is treated with other nonhazardous or characteristic wastes, the sludge is hazardous only if it is characteristic.
 
12/28/1987PROPOSED RULES IMPACT ON PERMIT DEADLINESMemo
 Description: When a draft rule contains a requirement that is applicable to a permit that the permit writer is drafting, and the requirement is necessary to protect human health and/or the environment, the permit writer can use 3005(c)(3) omnibus provision to add the requirement to the draft permit.
 
12/28/1985PART B PERMIT APPLICATION REQUIREMENTS FOR SQG TREATMENT FACILITIESMemo
 Description: A Part B permit application is required for small- and large-scale hazardous waste treaters.
 
12/27/2000APPLICABILITY OF RCRA SECTION 3020 TO IN-SITU TREATMENT OF GROUND WATERMemo
 Description: NO SIGNED PAPER COPY AVAILABLE - Reinjection of treated groundwater to promote in-situ treatment is allowed under RCRA 3020(b) as long as certain conditions are met: groundwater must be treated prior to reinjection; treatment must be intended to substantially reduce hazardous constituents in groundwater either before or after reinjection; cleanup must be protective of human health and environment; and injection must be part of RCRA corrective action or response action under CERCLA 104 or 106 (SEE ALSO: OSWER Directive 9234.1-06; December 27, 1989).
 
12/27/1993REGULATORY DETERMINATION ON THE STATUS OF PRECIOUS METAL RECOVERY FURNACESMemo
 Description: Addesses the criteria for legitimate precious metal recovery. Furnaces legitimately recovering precious metals fall within the Part 266, Subpart F exemption, and are not subject to the Subpart O incinerator regulations and most BIF rules, except for one-time notification and certification, sampling, and analysis. A precious metal recycler must be able to demonstrate that he is engaged in legitimate recycling.
 
12/27/1990TREATMENT STANDARDS FOR CERTAIN MIXED RADIOACTIVE WASTESMemo
 Description: Merely placing waste in a tank or a container is not macroencapsulation (MACRO). A plastic or steel coating that provides reduction in surface exposure to leaching media, and jackets of inorganic materials are MACRO. Macroencapsulation does not comply with existing land disposal restrictions (LDR) standards for metals. Waste could be macroencapsulated and disposed of via a variance from a treatment standard, no-migration petition, or national capacity variance.
 
12/27/1984STATE CAPABILITY ASSESSMENT GUIDANCEMemo
 Description: When applying for final authorization, a State must prove it is capable to implement a RCRA program. Memorandum of Agreement requirements are outlined. A State must submit information on funding for the state hazardous waste program and implementation accomplishments and activities.
 
12/26/2000COMPOSTING AND LANDFILLING OF YARD WASTESMemo
 Description: EPA does not have authority under RCRA to require recycling or to impose waste disposal bans. Management of municipal solid waste is regulated by state and local governments. EPA promotes alternative management methods such as composting.
 
12/26/1989INTERPRETATIONS OF THE EPA MEDICAL WASTE REGULATIONS (NUMBERS 24-39)Memo
 Description: Medical waste Qs and As, fourth set (numbers 24-35: syringes in integral sheaths; compaction; stocks of infectious agents; preprinted tracking forms; no storage time limit; hazardous waste-medical waste mixture; regulated medical waste containing radioactive waste subject to Nuclear Regulatory Commission and Part 259) (SUPERSEDED: see 60 FR 33912; 6/29/95).
 
12/26/1984REQUEST FOR GUIDANCE/CLARIFICATION OF WASTEWATER TREATMENT UNIT DEFINITIONMemo
 Description: The wastewater treatment unit (WWTU) definition does not require tanks at a facility to be connected. Wastewater can be piped, trucked, otherwise conveyed between components of WWTU’s.
 
12/26/1984CONTAMINATED GROUNDWATER, RCRA REGULATORY STATUSMemo
 Description: Generators do not use Appendix VIII in hazardous waste (HW) determination. Wastes containing Appendix VIII constituents are not HW unless they are listed or characteristic. Collected groundwater contaminated with listed or characteristic waste is regulated as HW. Discussion of the contained-in policy.
 
12/24/1996CLASSIFICATION OF SOLVENTS ADDEDMemo
 Description: Solvent used as reactants or ingredients in a product are not F-listed spent solvents. The policy also applies to discarded unused product containing solvent. The policy applies to solvents which are added by the end user to adjust viscosity. Statements to the contrary in the Solvent Study (EPA530-R-96-017) (August 1996) and Listing Determination Background Document for the 8/14/96 solvent listing proposal (61 FR 42318) are incorrect.
 

 

 
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