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Identifying Hazardous Waste

Characteristic Hazardous Waste Identification Guidance Memos from the EPA from 1980 to the 1998

10/01/1998PROHIBITION ON THE USE OF HAZARDOUS WASTE AS DUST SUPPRESSANTQuestion & Answer Description: characteristic waste that has been decharacterized and meets land disposal restriction (LDR) treatment standards (including universal treatment standards for underlying hazardous constituents) may be used as dust suppressant; use of decharacterized waste as dust suppressant is allowable assuming the resulting product is being legitamately recycled; use of used oil or listed hazardous waste as dust suppresant is prohibited

07/27/1998REGULATORY ACTION BASED ON AIR CHARACTERISTIC STUDYMemo Description: study entitled Potential Inhalation Risks due to Air Emissions from Certain Waste Management Units (Air Characteristic Study) completed May 1998; EPA has decided not to pursue initiation of proposal for air characteristic under RCRA to address risks from inhalation

07/15/1998SPENT METHYL BROMIDE ACTIVATED CARBON IS NOT U029Memo Description: spent activated carbon used to capture methyl bromide that has been used for its intended purpose is not a listed U029 hazardous waste; the P and U lists apply to unused commercial chemical products; the spent carbon may still exhibit a characteristic of hazardous waste

04/21/1998WITHDRAWAL OF CYANIDE AND SULFIDE GUIDANCEMemo Description: cyanide and sulfide reactivity guidance withdrawn (See RPC# 7/12/85-02); critical errors were made in developing the original guidance; a Federal Register notice announcing the withdrawal of the guidance from SW-846 will be prepared soon; the Agency expects that generators should continue to classify their high concentration sulfide- and cyanide-bearing wastes as hazardous based on the narrative standard

02/26/1998RULEMAKING PETITION FOR TRIVALENT CHROMIUM EXCLUSIONMemo Description: three part criteria for excluding a chromium waste; rulemaking petition to take advantage of trivalent chromium exclusion must be submitted to implementing agency (EPA or state) for review and approval; filter cake from treatment of chrome-bearing wastewater is newly generated waste

02/11/1998CHARACTERIZATION OF NITROCELLULOSE FILTER FABRIC WASTEMemo Description: 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; no reactivity characteristic test procedures for nitrocellulose filter fabric; 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

11/20/1997REGULATORY STATUS OF ETHYLENE GLYCOLMemo Description: pure, unused ethylene glycol and unused antifreeze containing ethylene glycol are not hazardous wastes until a decision is made to discard these products; since they are not listed hazardous wastes, they would be hazardous only if they exhibited one of the hazardous waste characteristics; ethylene glycol is included on the list of chemicals subject to reporting requirements under Section 313 of the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA)

08/15/1997TREATMENT PROCESS FOR SPENT ABRASIVE WASTESMemo Description: vacuum system that mixes characteristic spent abrasive wastes and additives does not appear to resemble either tank or container; unit that treat wastes between point of collection and point of accumulation could be regulated treatment unit subject to miscellaneous treatment standards; determination of unit's status is made on site-specific basis; treated waste that passes TCLP when initially tested but later found to exhibit characteristic becomes regulated hazardous waste; CERCLA liability is independent of any hazardous waste determination

08/14/1997REGULATORY STATUS OF USED NICKEL CATALYSTMemo Description: 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; hazardous waste determination is generator’s responsibility; determination made by evaluating the waste using a required test or by comparing the properties of the waste with the narrative standard; 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

08/12/1997SOLIDIFICATION OF K044 WITH POZZOLANIC MATERIALMemo Description: solidification of K044 with pozzolanic material satisfies land disposal restrictions (LDR) treatment standard; solidified material can no longer exhibit potential to form reactive residues and must not exhibit any hazardous waste characteristic

07/25/1997INCORPORATION OF PRETOX 2000 INTO LEADED PAINT STRIPPERMemo Description: leaded paint scrapings and blasted paint typically fail the toxicity characteristic for lead; use of additives in paint strippers or blasting grit to mask leaching of hazardous constituents is not illegal under current regulations, but masking may only be temporary; use of such materials does not relieve generator of CERCLA liability

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 states or regional offices make such determinations on 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 ignitability of rags, consider type and amount of solvent used, type and number of rags used, and how rags are stored; solvent contaminated rags without free liquids are still capable of exhibiting ignitability characteristic (D001); rags placed in container can force free liquid into the bottom of the container through force of gravity; rags placed in environment with oxygen may meet criteria in 261.21(a)(2)

05/19/1997CLARIFICATION OF REACTIVITY CHARACTERISTIC AS IT PERTAINS TO AEROSOL CANSMemo Description: EPA is unable to make a categorical determination as to whether various types of cans that may have contained a wide range of products exhibit the characteristic of reactivity; the generator is responsible for making this determination; steel aerosol cans that have been punctured and drained would meet the definition of scrap metal; scrap metal that will be recycled is exempt from RCRA, thus generators would not need to make a hazardous waste determination

05/19/1997RULES FOR DISPOSAL OF DISCARDED CONCRETEMemo Description: concrete has not been identified by EPA as listed hazardous waste; common concrete is not likely to exhibit any of the characteristics of hazardous waste; authorized states can establish more stringent requirements and may have their own rules regarding nonhazardous waste or debris

04/11/1997PAINT RECYCLINGMemo Description: paint or coating remixed and used for its intended purpose is not a solid waste; if paint is discarded, generator must make a hazardous waste determination; discarded paints generally are not listed wastes, but they may exhibit characteristics such as ignitability or toxicity; paint generated by a CESQG is not subject to federal regulation provided the waste is discarded at a facility meeting 261.5(f) or (g); paint collected from households is exempt from regulation, even if the paint is subsequently discarded; household hazardous waste (HHW) mixed with regulated hazardous waste in collection program is regulated; paint cans emptied under the empty container provisions are not subject to regulation because they do not hold regulated residues

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; placement of waste in container or tank is not considered macroencapsulation; owner/operator may use alternative treatment method if demonstrated to be an equivalent technology

03/17/1997REGULATORY STATUS OF LEAD SHOTMemo Description: mixture of spent lead shot and gunpowder may be ignitable; regulatory status of lead shot; discharge of ammunition or lead shot is in the normal and expected use pattern of the product and does not constitute hazardous waste disposal; ammunition, rounds, expended cartridges, and unexploded bullets that fall to the ground are not discarded (SEE ALSO: 62 FR 6622; 2/12/97); lead shot may be considered scrap metal, not spent material, and exempt from regulation when recycled; exemption extends only to the lead shot portion of the waste

03/12/1997RCRA APPLICABILITY TO PAINT REMOVAL WASTESMemo Description: paint removal process not subject to regulation in some circumstances; waste determination under 262.11 made once combination of paint and surface preparation product is removed from surface of structure; each product user responsible for waste determination; nonhazardous waste which subsequently becomes hazardous is subject to regulation; generators potentially liable under CERCLA for damage caused by release; lead-based paint abatement contractor and building owner are both generators (cogenerators)

02/07/1997MANAGEMNET OF SPENT FLUORESCENT LAMPSMemo Description: EPA is currently completing analysis of estimated mercury emissions associated with managing spent fluorescent lamps; EPA will use analysis in conjunction with comments on proposed lamp rule (59 FR 38288; July 24, 1994) to determine how to proceed with final regulatory decision on lamps (SEE ALSO: 64 FR 36466; 7/6/99)

11/07/1996REGULATORY STATUS OF CHOPLINE RESIDUEMemo Description: chopline residues are spent material and therefore solid waste when reclaimed or recycled; considered spent because it can no longer be used for original purpose without reprocessing or reclamation; hazardous waste management requirements apply up to the point of resale as product; residue generated from recycling process may be hazardous if characteristic

09/01/1996PCB WASTES AS HAZARDOUS WASTESQuestion & Answer Description: PCBs are not listed RCRA hazardous waste; it is possible that PCBs will be present as incidental contaminants in listed hazardous waste (e.g., solvent used to remove PCBs from transformers); typically PCBs do not exhibit characteristic; wastes that are hazardous for TC waste codes D018-43 and contain PCBs are exempt under RCRA if regulated under TSCA; waste containing PCBs and not qualifying for 261.8 exemption is fully subject to RCRA; land disposal restrictions has special standards for PCB wastes (California List) per 3004(d)(2)(D) and 3004(d)(2)(E) (SUPERSEDED: California list removed, see 62 FR 25997; 5/12/97)

07/12/1996MANAGEMENT AND DISPOSAL OF WASTE VINYL MINI BLINDSMemo Description: toxicity characteristic (D008) lead-containing mini blinds not solid waste if returned to manufacturer for resale in reverse distribution system; blinds from homes, apartments, hotels are exempt household hazardous waste (HHW); waste from hospitals, offices, day care centers, non-residential buildings at military bases are not HHW; HHW and non-HHW must be segregated; generator can test waste or apply knowledge; most conservative approach assumes blinds are hazardous waste (HW); generator vulnerable for enforcement for incorrect determination if subsequent EPA testing reveals waste is HW

03/25/1996EPA'S ASSESSMENT OF WHETHER AN UNUSED CHEMICAL AND THE RESULTING SPENT MATERIAL ARE HAZARDOUS WASTE AND/OR MIXED WASTEMemo Description: potassium hexacyanocobalt (II) - ferrate (II) that is used as ion exchange medium to remove cesium from wastestream is not a listed hazardous waste before or after use; media are unlikely to exhibit characteristic before use; if media exhibit characteristic after use they would be radioactive mixed wastes

03/07/1996INDUSTRIAL WIPERS AND THE HAZARDOUS WASTE IDENTIFICATION RULEMemo Description: discussion of possible factors to consider in future rulemaking on disposable and reusable rags and wipers contaminated with solvents (SEE ALSO: RPC# 10/27/94-01 and RPC# 2/14/94-01)

02/15/1996EPA'S NON-OBJECTION TO IMPORTS OF COBALT OXIDE-MOLYBDIC OXIDE SPENT CATALYSTS INTO THE U.S. FOR RECOVERYMemo Description: cobalt oxide-molybdic oxide spent catalysts are usually nonhazardous, but can exhibit the toxicity characteristic for benzene and arsenic; EPA does not have the authority to object to imports of nonhazardous waste; in order for Basel parties to export covered waste to non-Basel parties, the two parties must have a bilateral agreement in place; list of countries that are parties to Basel as of January 10, 1996

01/26/1996LAND DISPOSAL RESTRICTIONS; PHASE IV SUPPLEMENTAL PROPOSAL ON MINERAL PROCESSING WASTESMemo Description: Phase IV Bevill proposal (61 FR 2338; 1/25/96) would clarify distinction between in-process materials and wastes in Bevill exemption for mining and mineral processing wastes; notice proposes retaining TCLP and classification of several wastes, including five smelting wastes previously lifted, iron chloride waste acid, and wastes from lightweight aggregate production; notice proposes to exclude processed scrap metal and shredded circuit boards destined for metal recovery and managed in containers; proposes to significantly reduce land disposal restrictions (LDR) paperwork requirements that apply to hazardous waste generally (SEE ALSO: Phase IV Final Rule, 63 FR 28556; 5/26/98)

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 ignitability characteristic; 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: manifest discrepancy regulations do not apply to waste which loses corrosivity characteristic during transit (transportation); manifest discrepancy regulation intended for situations where quantity of waste is unaccounted for; manifest not certification that shipped waste is indeed hazardous; generator can apply knowledge conservatively, rather than incur costs of testing each waste batch or stream

09/13/1995IS THE CHEMICAL POTASSIUM HEXACYANOCOBALT (II)-FERRATE (II), USED AT A DOE NUCLEAR PLANT, CONSIDERED A ""MIXED WASTE"" UNDER RCRA?Memo Description: potassium hexacyanocobalt (II) - ferrate (II) that is used as ion exchange media to remove cesium from wastestream is not listed waste; unlikely to exhibit ignitability (D001) or corrosivity (D002); if characteristic, may be radioactive mixed waste

08/24/1995THE DIFFERENCE BETWEEN THE DEFINITION FOR THE CHARACTERISTIC OF IGNITABILITY AS IT PERTAINS TO SOLIDS VS. LIQUIDSMemo Description: no official method for testing ignitability of solids or sludges; method 1010, Pensky-Martens, has some use for liquids wastes with non-filterable, suspended solids; flash point testing only appropriate for liquids; OSW developed and proposed SW-846 test method 1030 based on DOT burn rate test in 173.124 and Appendix E (SUPERSEDED: SW-846 method 1030 finalized in 6/13/97; 62 FR 32451); if using DOT method, separate solid/liquid phases and test separately; supplement tests with generator knowledge

08/16/1995CLARIFICATION AS TO WHETHER USED FIXER IS A ""BY-PRODUCT"" AND NOT SUBJECT TO THE DEFINITION OF SOLID WASTE WHEN BEING RECLAIMEDMemo Description: used photographic fixer is spent material and not a by-product; EPA considering removing silver from the TC

08/10/1995GENERATOR STATUS OF CONTRACTORS WHO REMOVE LEAD-BASED PAINTMemo Description: during typical lead-based paint abatement, both property owner and contractor may qualify as generators responsible for compliance; cogenerator policy applies to cases other than those specified in the 10/30/80 Federal Register (45 FR 72024), where waste is generated by more than one party

07/13/1995REGULATORY STATUS OF SPENT ANTIFREEZEMemo Description: spent antifreeze from radiator flushes may be characteristic; studies indicate spent antifreeze may be hazardous, primarily due to lead; EPA has not determined point of generation for like wastes of similar composition when commingled after being produced; status of commingling hazardous and nonhazardous antifreeze; if commingled mixture no longer hazardous and meets treatment standards, generator must comply with 268.9 notification requirement; residues, still bottoms from antifreeze recycling newly generated waste; metal-bearing, high-BTU still bottoms could be burned in BIF under dilution prohibition

06/22/1995DETERMINATION ON WHETHER A GENERATOR'S FLUORESCENT TUBES ARE NONHAZARDOUSMemo Description: generator responsible for determining if waste exhibits characteristic; testing one spent fluorescent mercury lamp tube to determine if all waste lamps exhibit characteristic is not representative sampling; selection of randomly chosen bulbs is more appropriate (see Chapter 9, SW-846); States authorized for universal waste (UW) rule may add lamps to state UW list and set management standards (SEE ALSO: 64 FR 36466; 7/6/99); UW rule streamlines regulations for hazardous waste batteries (battery), pesticides, mercury thermostats

06/14/1995INTERPRETATION OF THE PHRASE ""WHICH CAN BE REASONABLY EXPECTED TO BE PRESENT"" FOR SOIL THAT EXHIBITS THE TOXICITY CHARACTERISTICMemo Description: when preparing land disposal restrictions (LDR) notification for D001, D002, D012-43 soils, constituents “reasonably expected to be present” would include all constituents above universal treatment standards (UTS) levels; in remediation, point of generation is point contaminated soil is picked up (SEE ALSO: 63 FR 28556; 5/26/98)

06/08/1995GUIDANCE ON WHETHER GENERATORS MUST POST ""NO SMOKING"" SIGNS WHEN A FACILITY HAS A ""TOBACCO-FREE"" POLICYMemo Description: EPA interpretation of enforceability of comments and notes in the regulations; comments and notes are not legal requirements; generators meeting the requirements of 262.34 need not comply with 265.17(a); generators may be required to post “no smoking” sign in accordance with 265.31; TSDFs must, at a minimum, post “no smoking” signs wherever there is a hazard from ignitable or reactive waste, even if facility has a tobacco-free environment

06/05/1995GUIDANCE FROM THE U.S. EPA ON THE CRUSHING OF MERCURY-CONTAINING LAMPSMemo Description: crushing mercury lamps can be part of exempt legitimate recycling process; recycling exemption can apply even if portions of recycling performed at different sites; crusher carries burden to ensure bulbs actually recycled (SUPERSEDED: lamp crushing by universal waste handlers prohibited; see 64 FR 36466, 36477-36478; 7/6/99); EPA still weighing options proposed in 7/27/94 Federal Register (59 FR 38288) for streamlining fluorescent lamp regulation; universal waste rule streamlines regulations for hazardous waste batteries (battery), pesticides, mercury thermostats; States may add additional wastes (e.g., fluorescent lamps) to state universal waste list and establish management standards

02/24/1995REGULATORY ISSUES PERTAINING TO WASTES CONTAMINATED WITH EXPLOSIVE RESIDUESMemo Description: 261.23(a)(8) should not be used because it references DOT regs which have been changed; debris/media mixed with explosives are reactive if they continue to exhibit characteristic; Bureau of Alcohol, Tobacco, and Firearms (BATF) methods may be used to determine reactivity for 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 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 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 hazardous waste; if contains listed hazardous waste via the contained-in policy or is mixed with listed hazardous waste (SEE ALSO: 2/14/94-01); final regulatory determination for wipers should be made by State or Regional office; no test method has been promulgated for spontaneous combustion; generator is responsible for comparing properties of his/her waste with narrative definition; Paint Filter Liquids test is current test to determine whether material contains a liquid for the characteristic of ignitability (D001)

12/16/1994BUBBLER CANISTERS CONTAINING PHOSPHOROUS OXYCHLORIDE ARE NOT WASTE WHEN RETURNED TO THE UNITED STATES FROM JAPAN FOR REGENERATIONMemo Description: bubbler containing unused phosphorous oxychloride is commercial chemical product (CCP) when reclaimed and not solid waste; partially empty bubbler which is recharged by adding new phosphorous oxychloride to residual phosphorous oxychloride left in bubbler is continued use of product, not waste; bubbler is not subject to OECD provisions when imported into U.S. for reclamation, because bubbler is not subject to U.S. laws and regulations; phosphorous oxychloride is highly corrosive and reacts violently with water, and therefore could be reactive or corrosive characteristic hazardous waste if solid waste; inappropriate to discharge untreated phosphorous oxychloride to wastewater treatment system or land dispose; phosphorous oxychloride is hazardous reactive (D003) and possibly corrosive (D002) when discarded; phosphorous oxychloride can be destroyed through addition of sodium hydroxide solution

12/01/1994ELEMENTARY NEUTRALIZATION UNITS GENERATING AND STORING NON-CORROSIVE HAZARDOUS WASTESQuestion & Answer Description: tank in which corrosive-only (D002) electroplating wastewaters are treated meets the definition of elementary neutralization unit (ENU), even if treatment process produces F006 sludge; F006 is subject to regulation once removed from the tank

11/03/1994CLARIFICATION OF DISCARDED AMMUNITION OF 0.50 CALIBERMemo Description: small arms ball ammunition up to and including .50 caliber are not reactive (D003) but may be hazardous for another characteristic; popping furnaces are Incineration; popping furnaces treating small arms ball ammunition that exhibit a characteristic are subject to RCRA as Incineration

10/27/1994REGULATORY STATUS OF INDUSTRIAL WIPERS UNDER RCRAMemo Description: EPA Headquarters deferral on determination of regulatory status of rags and wipers to appropriate Region or State implementing agency (SEE ALSO: RPC# 2/14/94-01)

10/07/1994PROCESSING LEAD ABATEMENT DEBRIS TO MEET HAZARDOUS WASTE RECYCLER'S SPECIFICATIONS IS NOT ""TREATMENT"" AS DEFINED IN 40 CFR 260.10Memo Description: processing (cutting, chopping, shredding, or grinding) of lead-based paint (LBP) waste is treatment, but is not subject to regulation if it is part of legitimate recycling; storage of hazardous waste lead-based paint before or after exempt processing is regulated; recycling is exempt form of hazardous waste treatment

10/04/1994REGULATORY REQUIREMENTS APPLICABLE TO TWO WASTE STREAMS THAT WOULD BE BILAYERED THROUGH PHASE SEPARATION AT A LICENSED TSDFMemo Description: aqueous phase separated from bilayered ignitable (D001) high total organic carbon (TOC) waste is different waste and need not be combusted; may be sent to wastewater treatment; phase separation; change in treatability group

09/28/1994CLARIFICATION ON: MANIFEST DOCUMENT NUMBER; F003, F005, D001; WASTE DESTINED FOR RECYCLING; AND TREATMENT STANDARDS FOR CFCMemo Description: F003 and F005 exhibiting ignitability must carry notification for and meet D001 treatment standard (TS), since F003/F005 does not operate in lieu of D001 (SEE ALSO: 55 FR 22520, 22530; 6/1/90) (USE WITH CAUTION: see RPC# 3/1/94-02); TS for chlorinated fluorocarbons (CFC); CFC waste may be subject to California list prohibition for halogenated organic compounds (HOC) (SUPERSEDED: California list removed, see 62 FR 25997; 5/12/97) (SEE ALSO: RPC# 5/16/91-01); materials that are not solid waste (SW) when recycled are exempt even if shipped to recycler via TSDF; scrap metal is both SW and hazardous, but is exempt if recycled; legitimacy of recycling must be documented; use of manifest continuation sheets

07/15/1994APPLICABILITY OF HAZARDOUS WASTE CODES TO A CHEMICAL POLISHING SYSTEMMemo Description: discarded chemical polishing bath containing the oxidizer hydrogen peroxide may be ignitable (D001) because it is capable of severely exacerbating a fire by yielding oxygen to stimulate combustion; acid baths may be corrosive (D002) due to sulfuric acid content; chemical polishing process does not generate listed waste if no electroplating or cyanides are used; discarded baths from this process are hazardous waste only if characteristic; wastes that exhibit characteristic at point of generation may be subject to Part 268 requirements even if they do not exhibit a characteristic at point of disposal (261.3(d)(1))

07/14/1994MANAGEMENT OPTIONS FOR MERCURY-CONTAINING LAMPSMemo Description: fluorescent and high-intensity discharge lamps generally exhibit the toxicity characteristic for mercury; summary of two regulatory options for spent mercury-containing lamps as proposed in the 7/24/94 Federal Register (59 FR 38288) (SEE ALSO: 64 FR 36466; 7/6/99)

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 levels

07/08/1994EXPORT FROM JAPAN OF PHOSPHORUS OXYCHLORIDE CONTAINING BUBBLERSMemo Description: waste bubblers containing phosphorous oxychloride may exhibit the characteristics of corrosivity (D002) and reactivity (D003); importer of waste is responsible for hazardous waste determination and generator duties; importer could be waste broker, transporter, or destination TSDF (SUPERSEDED: RPC# 9/14/94-02)

06/03/1994DEFINITION OF RCRA WASTE K050Memo Description: sludge from double-pipe heat exchange units is not K050; inside tube of double-pipe unit is not a bundle; sludge may exhibit toxicity characteristic for benzene and other heavy organics

05/24/1994STATUS OF WASTES GENERATED FROM ABATEMENT OF LEAD-BASED PAINTMemo Description: lead-based paint (LBP) abatement wastes are not household hazardous waste (HHW) if generated in construction, demolition, or renovation, but are exempt HHW if generated in routine residential maintenance (SUPERSEDED: See 63 FR 70233, 70241; 12/18/98); EPA does not distinguish between wastes generated by homeowners and contractors (SEE ALSO: RPC# 3/7/95-01); unless it is HHW, LBP abatement waste exhibiting toxicity characteristic for lead (D008) is currently regulated under Subtitle C; EPA may amend RCRA Subtitle C rules to remove disincentives to abate LBP

04/15/1994REGULATORY STATUS OF NATURAL GAS PIPELINE CONDENSATEMemo Description: although ignitable off-specification fuels such as natural gas condensate are usually not solid wastes when burned for energy recovery, sale or use of low energy value condensate as motor fuel or fuel additive may constitute sham burning for energy recovery; use of unadulterated natural gas pipeline condensate with high Btu/lb value can constitute legitimate burning for energy recovery; factors besides energy value apply to sham recycling determination

03/22/1994CLARIFICATION OF THE ""CONTAINED-IN"" POLICYMemo Description: soil containing F003 (listed solely for ignitability) may be deemed to contain hazardous waste due to the presence of hazardous constituents (such as metals) even if the soil does not exhibit a characteristic under contained-in policy; consistent with the process for delisting wastes listed solely for a characteristic, States may consider constituents other than those for which the waste was listed when deciding if the soil still contains hazardous waste

03/01/1994CLARIFICATION OF LAND DISPOSAL RESTRICTIONS (LDR) REQUIREMENTSMemo Description: if a waste is ignitable (D001, high total organic carbon (TOC)) and exhibits toxicity characteristic for lead (D008), blending and combustion as a hazardous waste fuel not impermissible dilution, since treatment standard for high TOC D001 requires burning; fuel substitution alone not sufficient; ash from burning such metal-bearing wastes must meet treatment standards for metals; waste must meet treatment standards for all applicable waste codes before land disposal (SEE ALSO: 268.9(b)); F001-F005 treatment standards apply only to constituents used for solvent properties and which triggered the listing; solvent constituents picked up through use not subject to F001-F005 treatment standards; F005 treatment standard addresses the characteristic of ignitability and so operates in lieu of D001 treatment standard (USE WITH CAUTION: see RPC# 9/28/94 -04); alternative debris treatment standards may be used even if debris is contaminated with waste code whose treatment standard is a specified technology

01/26/1994RESPONSE TO PROPOSED PROCEDURE TO DECOMMISSION ALUMINUM CHAFF ROVING BUNDLESMemo Description: aluminum chaff roving bundles could exhibit reactivity characteristic (D003) for propensity to release flammable hydrogen gas when exposed to moisture; Part 268 land disposal restrictions (LDR) treatment standard for these wastes is deactivation, which is best achieved by washing with an acidic solution (SUPERSEDED: treatment standard is deactivation and meet 268.48 standards, see 268.40); compliance is evaluated based on removal of characteristic, not based on following a specified method of deactivation

01/21/1994REGULATORY STATUS OF SPENT ANTIFREEZEMemo Description: spent antifreeze is a hazardous waste only if it exhibits a characteristic

01/04/1994REGULATORY STATUS OF WASTE AEROSOL CANSMemo Description: no categorical determination is possible as to the reactivity of various types of aerosol cans; hazardous waste determination is responsibility of generator; steel aerosol cans that do not contain a significant amount of liquid (e.g., can has been punctured and drained) meet the definition of scrap metal; aerosol cans that are recycled as scrap metal are exempt, and generator need not make a hazardous waste determination (SEE ALSO: 261.4(a)(13) exclusion for processed scrap metal)

01/03/1994REGULATORY STATUS OF METAL CASINGS CONTAINING SPENT POWDERED METALLIC OXIDE CATALYSTMemo Description: metal casting containing spent powdered metallic oxide catalyst (i.e., manganese dioxide and copper oxide) is not a listed waste, but could exhibit a characteristic, most likely ignitability (D001) or reactivity (D003); manganese dioxide is a strong oxidizer and poses a human health hazard through inhalation

01/01/1994USE OF TOTAL WASTE ANALYSIS IN TOXICITY CHARACTERISTIC DETERMINATIONSQuestion & Answer Description: maximum theoretical leachate concentration limits for TCLP can be calculated from results of total waste analysis using specific formula; use of total waste analysis for liquid wastes, solid wastes, and dual-phase wastes; maximum theoretical extract concentration (MTEC)

12/22/1993REGULATORY STATUS OF BATTERIESMemo Description: lithium-sulfur dioxide batteries (battery) that have been fully discharged to zero volts do not exhibit the characteristic of reactivity (D003); other lithium batteries may exhibit the toxicity characteristic for constituents such as lead (lead-acid batteries), cadmium (nickel-cadmium rechargeable batteries), and mercury (mercuric oxide, and some alkaline batteries), or may be hazardous due to other characteristic properties

12/07/1993INAPPROPRIATE USE OF METHOD 1311 (TCLP) AS AN ALTERNATIVE EXTRACTION PROCEDUREMemo Description: Method 1311 (TCLP) is leaching procedure, not extraction procedure (EP); TCLP is not appropriate sample preparation procedure for extractable total petroleum hydrocarbons (TPH) or for volatile TPH fractions (e.g., gasoline); suggested methods for preparation of extractable TPH in soil

11/22/1993RCRA HAZARDOUS WASTE DETERMINATION OF SPENT NUCLEAR REACTOR FUELSMemo Description: Naval Nuclear Propulsion Program’s (NNPP) spent reactor fuel does not exhibit any characteristics of hazardous waste; application of 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: reactive (D003) if releasable sulfide level is 500 mg/kg of above(SUPERSEDED: see RPC# 4/21/98-01); contrasting releasable sulfide methods

10/20/1993RESPONSE TO SPECIFIC QUESTIONS REGARDING HAZARDOUS WASTE IDENTIFICATION AND GENERATOR REGULATIONSMemo Description: absence of free liquids precludes applicability of the ignitability characteristic (D001) as defined in 261.21(a)(1); proposed rule change (58 FR 46052; 8/31/93) suggests using pressure filtration step from TCLP (Method 1311) as definitive demonstration for absence of free liquids for D001 and D002

10/13/1993LAND DISPOSAL RESTRICTION INTERIM FINAL RULEMemo Description: applicability of interim final rule (58 FR 29884; 5/24/93) to wastes that have one or more numerical treatment standards as well as a deactivation requirement; F001 waste that is also corrosive (D002) must be treated to meet standards for both waste codes (including treatment for underlying hazardous constituents); waste mixtures with common constituents of concern must meet most stringent standard that applies; ignitable (D001) and corrosive wastes (subject to treatment for underlying hazardous constituents) may be aggregated with other compatible wastes to facilitate treatment; aggregating wastes for other purposes may be impermissible dilution

10/07/1993REGULATORY STATUS OF USED RESIDENTIAL AND COMMERCIAL/INDUSTRIAL AEROSOL CANSMemo Description: EPA is unable to determine if aerosol cans exhibit characteristic of reactivity (D003); emptying steel aerosol can by puncturing and draining may be exempt as step in recycling can as scrap metal; steel aerosol can qualifies as scrap metal if it does not contain significant liquids (i.e., is fully drained) and is therefore exempt from regulation when sent for recycling; aerosol cans may be rendered empty in accordance with 261.7; liquid or gas removed from can is hazardous waste if listed or characteristic; no need to determine if steel aerosol can is empty once it qualifies as scrap metal (i.e., once it no longer contains significant liquids) that is destined for recycling; aerosol cans generated by households qualify for household hazardous waste exclusion; exclusion attaches at point of generation and continues to apply throughout waste management cycle

10/07/1993REGULATORY STATUS OF USED RESIDENTIAL AND COMMERCIAL/INDUSTRIAL AEROSOL CANSMemo Description: aerosol cans generated by households qualify for household hazardous waste exclusion; exclusion attaches at point of generation and continues throughout waste management cycle; steel aerosol cans are scrap metal when recycled if they do not contain significant liquids; no need to determine if steel aerosol can is empty once it qualifies as scrap metal; emptying aerosol can by puncturing and draining may be exempt as step in recycling of can as scrap metal; EPA is unable to determine if aerosol cans exhibit characteristic of reactivity (D003); liquid or gas removed from can is hazardous waste if listed or characteristic; aerosol cans may be emptied in accordance with 261.7

09/24/1993CLARIFICATION OF THE USED OIL REGULATIONS APPLICABLE TO MIXTURES OF USED OIL AND CHARACTERISTIC WASTEMemo Description: mixtures of used oil and ignitable-only characteristic wastes (D001) are regulated as used oil if no longer D001; mixtures of used oil and other characteristic wastes are hazardous wastes if they characteristic, used oil if not; mixtures of used oil and wastes listed solely for ignitability are regulated as used oil if no longer ignitable; mixtures of used oil and wastes listed for corrosivity, reactivity, or characteristic of toxicity are hazardous wastes if they exhibit a characteristic, used oil if they do not

09/23/1993LEAD CONTAMINATION RESULTING FROM SKEET SHOOTINGMemo Description: EPA encourages use of substitute materials for lead in ammunition on firing ranges; U.S. Court of Appeals for Second District affirmed that lead ammunition deposited in Long Island Sound is “hazardous solid waste,” citizen may bring 7002 lawsuit for imminent and substantial endangerment (SEE ALSO: 62 FR 6622; 2/12/97)

09/14/1993PROPOSAL TO APPLY DEBRIS TREATMENT STANDARDS TO DEBRIS CONTAMINATED WITH PHASE II WASTESMemo Description: clarification to Phase II proposed rule (58 FR 48092; 9/14/93): EPA intends Phase I alternative debris treatment standards to apply to waste codes addressed in Phase II rule (D018-43, K149-K151, K141-K145, K147, K148)

09/14/1993REGULATORY STATUS OF BRASS PARTICLES GENERATED IN THE BELTING AND BUFFING OF BRASS CASTINGSMemo Description: scrap metal that fails toxicity characteristic for lead is excluded from RCRA Subtitle C regulation when recycled; determination of whether brass particles from belting/buffing of brass castings are scrap metal is made by state or Regional office (SEE ALSO: 261.4(a)(13) exclusion for processed scrap metal)

09/14/1993REGULATORY STATUS OF LITHIUM SULFUR DIOXIDE BATTERIESMemo Description: regulatory determination made in letter, Williams to Berger, (RPC# 3/18/87-01) regarding potential reactivity of lithium sulfur dioxide (LiSO2) batteries (battery) is still in effect

09/01/1993HAZARDOUS WASTE RECYCLING REGULATIONS TO A PROPOSED INK RECYCLING PROCESSMemo Description: waste ink is a spent material; spent materials are solid wastes when reclaimed; process recycling waste ink is not regulated under RCRA Subtitle C; storage of waste ink prior to recycling is subject to permit standards; whether temporary holding area is subject to permitting is decided on case-by-case basis; lithographic printers may qualify as CESQGs (SEE ALSO: RPC# 9/20/93-03); waste ink may be characteristic or listed, depending on type of solvent used to clean ink machine; hazardous waste recyclers must notify EPA under RCRA 3010 and obtain EPA ID numbers; residues from recycling process may no longer be solid wastes if they are legitimate products; discussion of regulatory status of reclaimed materials and legitimacy determinations

07/14/1993RESPONSE TO REQUEST FOR OPINION ON SECTION 21 PETITION ON BATTERY DEPOSITSMemo Description: toxicity characteristic TC is designed to identify wastes which may pose a risk to human health and environment under reasonable worst-case mismanagement scenario; some spent batteries (battery) would fail toxicity characteristic for lead (D008), cadmium (D006), and mercury (D009); batteries may be eligible for universal waste regulations; batteries generated by households and conditionally exempt small quantity generators (CESQGs) are generally exempt from Subtitle C regulation

06/03/1993USE OF ON-SITE PRECIPITATION PROCESS AS AN ACCEPTABLE PRETREATMENT STEP ADJUNCT TO MERCURY RETORTINGMemo Description: mercury precipitation treatment cannot be used as substitute for required retorting treatment (RMERC) for D009 high mercury subcategory; precipitation process may be used as pretreatment step; generators can treat waste on-site without obtaining a permit, provided generator accumulation provisions are met; generators subject to land disposal restrictions (LDR) analysis plan notification

06/01/1993SAMPLE HOLDING TIMES AND VALIDITY OF ANALYTICAL RESULTSQuestion & Answer Description: use of 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; 5/26/98); zinc-carbon batteries are not subject to cadmium battery recycling standard; applicable D006 treatment standard is based on stabilization (SEE ALSO: Part 273)

04/23/1993INTERPRETATION OF ""AQUEOUS"" AS APPLIED TO THE CORROSIVITY CHARACTERISTICMemo Description: aqueous means amenable to pH measurement; corrosivity characteristic (D002) references Method 9040; 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: paint filter liquids test (Method 9095) was developed to determine free liquids in a waste; test not intended for use in determining if waste contains any bound or absorbed liquid or if liquid is aqueous; aqueous phase must be present to evaluate waste for pH (SEE ALSO: RPC# 2/16/90-01)

04/02/1993REVISIONS TO THE TCLPMemo Description: use of the method of standard additions (MSA) in metallic contaminants in TCLP wastes

03/05/1993U.S. WASTE MANAGEMENT PRACTICES FOR AUTOMOBILES AND AUTO SHREDDER RESIDUEMemo Description: automobile shredder residue (ASR or fluff) and shredded appliances have potential to exhibit characteristics, may also contain PCBs above levels of regulatory concern; generator's responsibility to determine whether ASR is hazardous waste before disposal; estimated ASR yearly generation; most shredder residue managed in solid waste (SW) landfills; some States ban disposal of white goods (appliances) and autos from landfills or impose consumer surcharge

03/03/1993AVAILABILITY OF CRITERIA USED TO EVALUATE THE CHARACTERISTIC OF REACTIVITYMemo Description: EPA has test procedures to determine reactivity of wastes that release hydrogen cyanide or hydrogen sulfide gas when mixed with weak acid; no EPA test for waste that releases hydrogen gas when mixed with water; many reactive properties, such as water reactivity, are difficult to quantify (SUPERSEDED: test procedures have ben withdrawn, see RPC# 4/21/98-01)

02/01/1993MIXTURES OF USED OIL AND CHARACTERISTIC HAZARDOUS WASTEQuestion & Answer Description: mixture of used oil and ignitable-only hazardous waste (D001) regulated as used oil if mixture so long as mixture is not ignitable; mixture of used oil and waste characteristic for reason other than ignitability is regulated as hazardous waste if exhibits any characteristic after mixing

01/18/1993HAZARDOUS WASTE TESTING ISSUESMemo Description: EPA has no data that trivalent chromium oxidizes to hexavalent chromium in a landfill; TCLP based on co-disposal scenario; methods 9010 and 9012 suggested for concentration of total cyanide and cyanide amenable to chlorination

01/12/1993NOTES ON RCRA METHODS AND QA ACTIVITIESMemo Description: method and formula for using totals analysis to determine theoretical maximum concentration of contaminants that could leach from waste when using TCLP; 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 waste is heterogeneous (i.e., contains hot spots)

01/07/1993APPLICABILITY OF CORROSIVITY PH AND STEEL CORROSION TESTSMemo Description: nonaqueous liquids need only be tested using the steel corrosion test, whereas aqueous nonliquids (e.g., gels) need only be evaluated for pH; aqueous liquids are subject to pH measurement and steel corrosion test; aqueous waste is defined as a waste that is amenable to pH measurement

12/24/1992CLARIFICATION ON WHAT CONSTITUTES DIOXIN RELATED MATERIALSMemo Description: list of waste codes that contain dioxin (F020, F022, F023, F026, F027, F028, F032, D017, D041, D042); F-listed dioxin waste codes do not apply if waste contains dioxin but does not meet listing description; waste exhibits toxicity characteristic only if level of constituent exceeds regulatory level; F039, K043, and K099 have land disposal restrictions (LDR) for certain dioxins and furans; if waste meets listing description, waste code applies even if no Appendix VIII constituents are present; for purposes of F021, pentachlorophenol derivative includes any substance which is related structurally and can be made from pentachlorophenol (PCP), including sodium pentachlorophenate, octachlorodibenzodioxin, octachlorodiphenyl ether, and potassium pentachlorophenate; derivatives from tri- and tetrachlorophenol include tri- and tetra-chlorophenoxy derivatives of carboxylic acids; F020 -F023, F026-F028 must be incinerated in unit meeting 99.9999 DRE or burned in thermal treatment unit meeting same DRE; waste that contains Appendix VII constituents but cannot be traced to original process that would generate waste meeting listing description is exempt from regulation unless characteristic

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

11/25/1992QUESTIONS ON FINAL USED OIL RULEMemo Description: toxicity characteristic rule is federally enforceable in every state until it is adopted by the State and EPA approves authorization; used oil filter exclusion applies in Arizona on 6/19/92; applicability of used oil regulations in authorized states

11/05/1992CLARIFICATION OF NEWLY LISTED WASTES AND HAZARDOUS DEBRISMemo Description: characteristic debris treated to meet the land disposal restrictions (LDR) performance standard and contaminant restrictions and no longer exhibits characteristic, is not hazardous waste; if a mixture of material is comprised primarily of debris, by volume, based on visual inspection, 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 constituent leachability before and after treatment using TCLP

11/05/1992REGULATIONS GOVERNING THE MIXING OF HAZARDOUS WASTE SOLVENTS AND USED OILMemo Description: mixture of used oil and characteristic hazardous waste is managed as hazardous waste if mixture is characteristic; mixture of used oil and ignitable only hazardous waste (D001) such as mineral spirits is regulated as used oil if mixture is not ignitable; tank in which used oil and D001 hazardous waste are mixed is subject to Part 279 and 262.34; tank must be labeled with words “used oil;” mixing may be treatment

11/04/1992CLASSIFICATION OF F003 WASTESMemo Description: xylene and acetone used to remove paint is F003, even if waste is not ignitable; 261.3(a)(2)(iii) mixture rule exemption does not apply to nonignitable F003 that has not yet been mixed with solid waste, and does not apply to mixture of soil and F003 that does not exhibit a characteristic; land disposal restrictions (LDR) treatment requirements still apply to F003 waste that has been rendered nonignitable and/or nonhazardous under 261.3(a)(2)(iii); if F003 is spilled into soil, soil must be managed as listed waste until State or Region determines it no longer contains hazardous waste

11/03/1992TRANSPORTATION AND DISPOSAL OF SHOCK SENSITIVE OR EXPLOSIVE MATERIALSMemo Description: picric acid and ethyl ether may be hazardous due to reactivity; removal, transportation of old lab chemicals to eliminate imminent and substantial danger qualifies for 270.1(c)(3) permit exemption; emergency permit regulations can also be used; RCRA permit is necessary if safety official determines no immediate safety threat exists

09/21/1992CALCULATION OF TCLP CONCENTRATIONS FROM TOTAL CONCENTRATIONSMemo Description: generator may use total analysis in lieu of TCLP analysis to determine if analyte could possibly be above regulatory level by dividing total concentration by 20 and comparing result with regulatory limit; 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; revision of the toxicity characteristic level for lead may occur as part of Hazardous Waste Identification Rule; EPA considered extending 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); bulbs subject to LDR because they exhibit EP toxicity characteristic and toxicity characteristic (TC) 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 rate of steel corrosion to determine corrosivity; for D002, aqueous defined as waste for which pH is measurable; aqueous nonliquids subject to pH test only; examples of aqueous nonliquids

08/26/1992ASTM D4982-89 (METHOD B) AS AN EQUIVALENT METHOD OF TESTING FOR IGNITABILITYMemo Description: no promulgated test method for ignitable solids (D001) (SEE ALSO: SW-846 method 1030 finalized in 6/13/97; 62 FR 32451); ASTM D4982-89 (Method A) may be used as interim method for ignition, but not for vigorous burning determination; five circumstances where CFR requires SW-846 method use

07/21/1992REGULATIONS FOR DISPOSAL OF CERAMIC MATERIALSMemo Description: disposal of ceramic tiles regulated only if they meet the definition of hazardous waste; if tiles are hazardous, they may be subject to the land disposal restrictions (LDR); appropriate treatment could consist of chemical stabilization or vitrification, depending on the metals in the waste

07/01/1992ALCOHOL-CONTENT EXCLUSION FOR THE IGNITABILITY CHARACTERISTICQuestion & Answer Description: non-alcoholic component does not cause aqueous solution with less than 24% alcohol to lose eligibility for alcohol exclusion for ignitable (D001) wastes; alcohol defined as any alcohol or combination of alcohols; for D001, aqueous means at least 50% water by weight

06/16/1992DESIGNATION OF AMERICIUM BERYLLIUM SOURCES UNDER RCRAMemo Description: 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 combination testing/ mass balance approach; theoretical TCLP concentration can be based on solder composition or testing

03/31/1992MANAGEMENT OF MIXED WASTEMemo Description: low-level radioactive mixed waste typically consists of organic liquids, oil mixtures, heavy metal-contaminated wastes, and corrosive liquids; generators, TSDFs must include mixed waste information in biennial report; mixed waste permitting authority discussion; mixed waste is subset of low level waste

03/09/1992CORROSIVITY CHARACTERISTIC AS IT APPLIES TO SOLIDSMemo Description: corrosive solids (lye, solid acids) are not covered under corrosivity characteristic (D002); aqueous not defined (SUPERSEDED: see RPC# 1/7/93-02; RPC# 4/23/93-01); test method for corrosive solids proposed

02/04/1992CLASSIFICATION OF INFILTRATION GALLERIES UNDER THE UIC AND RCRA PROGRAMSMemo Description: distinction between, and definition of, infiltration galleries (IGs) and SDWA underground injection control (UIC) wells for purposes of 4/2/91 (56 FR 13406) rule extending toxicity characteristic (TC) effective date for reinjection of groundwater pursuant to hydrocarbon recovery operations at petroleum refineries and transportation facilities; IGs can be UIC wells; IGs are often trenches; remediation activities using reinjection may be subject to state groundwater protection statutes, SDWA, RCRA, and/or CERCLA authorities

12/19/1991USED AUTOMOBILE ANTIFREEZE DISPOSALMemo Description: used antifreeze from households is exempt; used antifreeze from business is hazardous waste only if characteristic; small business may be able to enjoy reduced CESQG regulation; industry data indicate used antifreeze may fail TCLP

12/01/1991SW-846 TEST METHODSQuestion & Answer Description: test methods found in SW-846 are generally not required, but are intended as guidance for both hazardous waste identification and compliance with land disposal restrictions (LDR) treatment standards; in certain instances, such as delisting and characteristic testing, EPA requires use of SW-846 methods

11/12/1991APPLICABILITY OF SPECIAL COLLECTION SYSTEM PROPOSAL TO BATTERIESMemo Description: hazardous waste batteries (battery) generated by households are not subject to regulations; batteries generated by CESQG subject to limited controls; until EPA develops special management standards for recycling hazardous waste batteries, generators must still determine whether used nickel-cadmium batteries exhibit toxicity characteristic (SEE ALSO: Part 273)

11/01/1991REMOVAL OF TOXICITY CHARACTERISTIC WASTES FROM A SURFACE IMPOUNDMENTQuestion & Answer Description: one-time removal of toxicity characteristic (TC) waste from a surface impoundment on or after TC rule’s (55 FR 11798; 3/29/90) effective date does not subject unit to regulation; unit can then be used to manage nonhazardous waste; surface impoundment holding toxicity characteristic (TC) waste that is left in place and not actively managed (active management) after the toxicity characteristic effective date is not subject to regulation

10/29/1991TCLP EXTRACTIONS APPLIED TO LIQUID WASTES, OILS AND SOLVENT-BASED PRODUCTSMemo Description: suggested analytical steps when inconclusive results are obtained from application of 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

10/11/1991MATERIALS USED IN FERTILIZER PRODUCTION MANAGEMENTMemo Description: characteristic sludge used to make fertilizer is solid waste, even if it is first sent to facility for lead reclamation; solid waste determination for recycled material is made at point of generation and must account for entire recycling process; D008 baghouse dust used in fertilizer production is solid waste used in a manner constituting disposal; fertilizer produced for the general public's use that meets land disposal restrictions (LDR) treatment standards is no longer subject to regulation

10/11/1991MATERIALS USED IN FERTILIZER PRODUCTION MANAGEMENTMemo Description: characteristic sludge (D008) used to make fertilizer is solid waste, even if first sent to facility for lead reclamation; fertilizer produced for general public's use that meets land disposal restrictions (LDR) treatment standards is no longer subject to regulation under use in manner constituting disposal exemption; history of used constituting disposal regulations; solid waste determination for recycled material made at point of generation and must account for entire recycling process, not only first step; elements of legitimate recycling

10/09/1991EXEMPTION FROM PARTICLE SIZE REDUCTION STEP IN TCLPMemo Description: generator knowledge may include previous testing data on similar waste; generator must test or apply knowledge for characteristic; TCLP particle size reduction method up to lab’s best professional judgment

10/01/1991ANALYTICAL METHODS FOR CONDUCTING TESTING UNDER THE TC RULEMemo Description: up until 6/21/90 analytical methods for toxicity characteristic arsenic, selenium, and mercury were 7060, 7061,7740, 7470, and 7471; on 6/21/90, Agency promulgated method 6010

09/26/1991APPLICABILITY OF THE TOXICITY CHARACTERISTIC TO USED OIL FILTERSMemo Description: no hazardous waste determination necessary for oil filters destined for scrap metal recycling (SEE ALSO: 261.4(b)(13)); crushed and hot drained oil filters are unlikely to exhibit toxicity characteristic

09/25/1991TC RULE DELAY OF IMPOSITION ON OIL FILTERSMemo Description: data suggest that crushed oil filters may not exhibit the toxicity characteristic; no toxicity characteristic determination is necessary for oil filters destined for recycling (SEE ALSO: 261.4(b)(13))

09/11/1991USE OF ASTM METHOD D-56 IN IGNITABILITY DETERMINATIONSMemo Description: possible use of ASTM method D-56 to test flash point of potentially ignitable (D001) liquid as an alternative to the two methods specified in 261.21

09/06/1991DETERMINATION OF THE IGNITABILITY CHARACTERISTICMemo Description: no test method for ignitable solids (D001), generator should apply knowledge (SEE ALSO: SW-846 method 1030 finalized in 6/13/97; 62 FR 32451); analyses of solids may help determine if any detectable compounds are known to be ignitable; meeting any (not all) of ignitability properties renders waste hazardous; no specific definition of “liquid” for purposes of Pensky-Martens closed tester (SEE ALSO: RPC# 10/20/93-01) (SEE ALSO: 60 FR 3092; 1/13/95)

08/30/1991LEAD PAINT REMOVAL DEBRIS AND THE TCLP PROCEDUREMemo Description: adding iron or other material to lead-based paint (LBP) removal waste (or to removal abrasive) to mask lead (D008) characteristic is not legitimate and may subject generator to additional liability; whether masking agent is added to paint removal abrasive prior to abatement process or added to waste following generation is immaterial (SEE ALSO: RPC# 7/3/91-02)

08/30/1991UNDERGROUND INJECTION WELLS USED IN HYDROCARBON RECOVERYMemo Description: groundwater reinjected through injection wells following hydrocarbon recovery at certain types of facilities is not subject to the toxicity characteristic rule until 1/25/93; rationale for extending compliance date; OSW and Office of Water should agree on terms of implementation

08/27/1991POTENTIALLY CONFLICTING REGULATION OF INFILTRATION GALLERIES BY THE OGWDW AND OSWMemo Description: injection wells and infiltration galleries are not mutually exclusive; units that are both infiltration galleries and injection wells were included in 4/2/91 extension of TC compliance date for certain injection wells (56 FR 13406; units that are infiltration galleries (e.g., leaking surface impoundments) but not injection wells were not included in the extension

08/05/1991APPLICABILITY OF THE TOXICITY CHARACTERISTIC RULE TO UNREGULATED HEAVY METALSMemo Description: certain heavy metals (e.g. vanadium, copper, zinc, nickel, tin, antimony) are not regulated constituents under the toxicity characteristic because they have not yet been assigned MCLs and EPA's fate and transport model does not fully account for behavior of metals

07/31/1991TC RULE HAZARDOUS WASTE DETERMINATIONMemo Description: pulp and paper mill wastes should be sampled at outlet from bleach plant (point of generation), prior to commingling (mixing) with other wastestreams, to determine whether they exhibit the toxicity characteristic for chloroform (D022); 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); definition of aggressive biological treatment (ABT) units for purposes of F037 and F038 listings does not apply to exemption for biological treatment units from surface impoundment minimum technical requirements

07/12/1991RCRA APPLICABILITY TO POTASSIUM PERMANGANATE AND MANGANESE DISPOSALMemo Description: wastewater treatment sludges from POTWs or other facilities discharging pursuant to CWA are subject to all applicable Subtitle C regulations when treated, stored, or disposed; generally, sludges from POTWs are hazardous waste only if characteristic; POTW sludges unlikely to exhibit characteristics; spent potassium permanganate and manganese from the garment industry are unlikely to be ignitable (D001) oxidizers

07/09/1991METHODOLOGIES EMPLOYED IN USED OIL SAMPLINGMemo Description: 1989-1990 used oil sampling data, gathered to support used oil characterization effort; used oil was analyzed for compositional characteristics and analyzed via TCLP; 7 types of used oils were analyzed; results do not reflect regional variations as all samples, where possible, were taken from Washington, D.C. area; role of TCLP and other methods in determination (SEE ALSO: 57 FR 41566; 9/10/92)

07/03/1991DRAFT REGION VIII POLICY ON “AGGRESSIVE BIOLOGICAL TREATMENT”Memo Description: sludges formed in aggressive biological treatment (ABT) units are not F037 or F038; only secondary or tertiary treatment units qualify as ABT; ABT units receiving or generating toxicity characteristic hazardous waste are subject to all applicable rules; F037/F038 sludges can be formed in ABT units not operating properly

07/03/1991TCLP AND LEAD PAINT REMOVAL DEBRISMemo Description: general guidance for representative sampling of lead-based paint abatement wastes (debris and abrasives) from drums, roll off boxes, and other containers; shipments of LBP abatement waste from field site (bridge repair) to central accumulation point must generally be accompanied by manifest; central accumulation point must be a transfer facility or TSDF to accept manifested hazardous waste; generators conducting lead-based paint (LBP) abatement must test wastes using TCLP unless they can apply knowledge to determine characteristics (SEE ALSO: 63 FR 70233, 70241; 12/18/98); if LBP waste first tests nonhazardous in TCLP due to masking effect of iron abrasive, but exhibits 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 permit

06/28/1991CCA TREATED WOOD WHEN DISPOSEDMemo Description: treated wood exemption applies to wood failing toxicity characteristic for D004-D017, not just arsenic (SEE ALSO: 57 FR 30657; 7/10/92)

06/21/1991POSITION PAPER ON SPENT ABSORBENT MATERIALSMemo Description: CESQGs may dispose of hazardous waste in sanitary or municipal solid waste landfill as long as landfill is permitted, licensed, or registered by State to manage municipal or industrial solid waste (SEE ALSO: 261.5(g)(3)); absorbent and waste mixture containing free liquid phase with flash point <140 F is D001; 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; 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 absorbent is mixed with waste listed solely for characteristic, mixture is not hazardous waste if it does not exhibit characteristics; 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: use of TCLP to determine if spent anti-freeze exhibits characteristic for lead; extraction procedure (EP) and TCLP are functionally equivalent for liquid wastes, since both lead to direct analysis of the liquid; extraction procedure toxic wastes are a subset of all hazardous waste; generators may apply their knowledge instead of testing

06/13/1991TCLP EXTRACTIONS AS THEY APPLY TO OILY WASTEMemo Description: Agency does not recommend applying TCLP test to oily waste; if oily waste is used oil, characterization unnecessary if going for recycling (SEE ALSO: Part 279); if TCLP inconclusive on oily wastes, generators may use knowledge

05/29/1991ELECTROPLATING WASTESMemo Description: anode bags are spent materials when removed from electroplating bath for reclamation; spent anode bags are both reactive (D003) and F007; bags can be washed in accumulation tank/container without permit under 262.34; filter media, residue from apparatus used to filter cyanide plating bath are D003 (reactive) and F008, but not F007; cleaning bath that does not contain cyanides is not F009

05/29/1991PARTICLE SIZE REDUCTION PROCEDURE FOR TCLP SAMPLES OF DRY CELL BATTERIESMemo Description: Agency 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: mandatory hazardous waste determination should be based on knowledge when application of TCLP to discarded munitions would result in inherently unsafe situation due to particle reduction step; exemption from TCLP is unwarranted because generators can apply their knowledge

05/09/1991SHELL OIL FACILITY - TC COMPLIANCEMemo Description: infiltration galleries not exempted by 261.4(b)(11) groundwater injection exclusion; treatment wastewaters from extracted petroleum-bearing groundwater are considered sludges and are not eligible for extended toxicity characteristic compliance date (exclusion expired 1/25/93)

05/01/1991TCLP PARTICLE SIZE REDUCTION EXEMPTION FOR MUNITIONSMemo Description: particle reduction in TCLP unsafe for military munitions; facilities may apply knowledge to determine characteristic

04/16/1991TC RULE RELATIONSHIP TO USED OIL FILTER DISPOSALMemo Description: in spite of toxicity characteristic rule, generators may still apply their knowledge to make hazardous waste determination; they must, however, be correct in their determination; used oil filters are subject to hazardous waste determination (SEE ALSO: 261.4(b)(13))

03/27/1991DEFINING IGNITABLE LIQUIDS METHODMemo Description: using one of the two test methods approved for determining ignitability is sufficient; choice of method will depend on nature of waste to be tested (e.g., one method might be more appropriate given viscosity of waste)

03/26/1991SUBSURFACE FATE AND TRANSPORT MODELMemo Description: EPA Composite Model for Landfills (EPACML) is subsurface fate and transport model developed for national regulatory purposes, not site-specific use; EPA is proposing to use EPACML in delisting petitions; EPA discourages application of model to site-specific corrective actions

03/25/1991DILUTION OF TEST SAMPLINGMemo Description: TCLP difficult to use on wastes such as oils and neat solvents, because dilution step shifts detection limit above toxicity characteristic levels; generator should apply knowledge in such cases; if no information is available, it would be prudent to handle as hazardous waste (SEE ALSO: RPC# 8/14/90-01); no need to run TCLP on used oil that will be recycled

03/19/1991MATRIX SPIKE IN TCLP PROCEDUREMemo Description: matrix spike may be used in TCLP when contaminant concentration is completely unknown to monitor method performance and estimate extent of bias or interference (SEE ALSO: 57 FR 26986; 11/24/92); matrix spike is predetermined quantity of certain analytes added to sample matrix before sample extraction/preparation

03/08/1991SLUDGES WITHIN SURFACE IMPOUNDMENTS, NEWLY REGULATED DUE TO TC RULEMemo Description: toxicity characteristic sludges generated in surface impoundments are solid waste (discarded by being abandoned); sludges are solid waste subject to regulation not only when surface impoundment is cleaned or closed, but when sludge is generated (sludges are generated at moment of deposition at bottom of unit)

02/27/1991MOBILE TREATMENT UNITS QUALIFIED FOR INTERIM STATUSMemo Description: explanation of three criteria necessary for facility to qualify for interim status under the toxicity characteristic (TC) rule; mobile treatment unit may qualify for interim status at more than one location; routine movement of mobile treatment unit from site-to-site does not require a change in interim status; addition of waste codes to Part A at interim status facility regulated by EPA due to TC rule in an authorized state that has not adopted TC rule

02/22/1991ANALYSIS OF FLUFF MATERIALSMemo Description: analysis of fluff using TCLP versus extraction procedure (EP); use of different extraction fluids for TCLP

02/12/1991TC APPLICABILITY TO MIXED WASTEMemo Description: definition of mixed radioactive waste; mixed waste first subject to RCRA regulation in 1986; toxicity characteristic does not apply to mixed waste in states with only RCRA base program authorization until State revises its program and receives authorization for mixed waste; status of mixed waste that fails the TCLP

02/05/1991GENERATOR HAZARDOUS WASTE DETERMINATION AND THE TCLPMemo Description: clarification of letter (RPC# 11/8/90-04); generator may always apply knowledge in determining if waste is hazardous waste; if no information is available except inconclusive TCLP data, prudent for generator to assume waste is hazardous; no need to perform TCLP on used oil destined for recycling

01/23/1991REGULATORY STATUS OF SOLVENT-CONTAMINATED RAGS AND WIPERSMemo Description: until EPA has resources to respond to petition to exempt solvent-contaminated rags, wipers, and shop towels from mixture rule, EPA believes waste determination should be made by State or Region on a case-by-case basis since they are in best position to make evaluation

01/08/1991LEADED PAINT SANDBLASTING WASTE TESTING USING TCLPMemo Description: land disposal restrictions (LDR) regulations continue to allow the use of either the extraction procedure (EP) or the TCLP to demonstrate compliance with treatment standards for certain lead and arsenic wastes (SUPERSEDED: see 63 FR 28556; 5/26/98); TCLP is only test usable for characterization and identification of toxicity characteristic hazardous waste

11/09/1990PETROLEUM-CONTAMINATED MEDIA AND DEBRIS DEFERRAL FROM THE TOXICITY CHARACTERISTICMemo Description: petroleum contaminated media deferral does not apply to D001-D017; no need to run TCLP to determine if wastes D018 - D043, provided wastes generated as part of UST corrective action

11/08/1990APPLICABILITY OF THE TCLPMemo Description: TCLP inappropriate for certain matrices, like oils and neat solvents; dilution step shifts detection limit above regulatory levels; if case, generator must assume waste hazardous (SEE ALSO: RPC# 3/25/91-01); TCLP must be used to obtain extract

11/08/1990BIAS CORRECTION APPLIED TO THE TCLPMemo Description: whenever TCLP used, all requirements in procedure must be met; all results should be corrected for bias, even if below standard; spike matrix recovery is bias correction tool (SEE ALSO: 57 FR; 11/24/92); data collected before 9/25/90 need not be corrected for bias per toxicity characteristic rule; owner/operation may be held liable for proper disposal of improperly characterized waste

11/01/1990QC REVIEW OF PERMIT DATAMemo Description: matrix spike assists in ascertaining and correcting co-extracted artifacts (analytical bias) and tests laboratory conditions; performance of matrix spike recovery for TCLP analytes (SEE ALSO: 57 FR; 11/24/92)

10/30/1990USED OIL FILTERS - REGULATION; USED OIL FILTERS, REGULATORY DETERMINATIONMemo Description: crushing filter to remove used oil (UO) exempt if removed UO recycled (SUPERSEDED: see 261.6(a)(4) and 279.10(c)); generally, used auto oil filters not containers because not storing oil; filters not empty containers; filter with UO removed exempt scrap metal if recycled; undrained uncrushed filters have too much oil for scrap metal exemption (SEE ALSO: 261.4(b)(13)); TCLP on UO filters: crushing, cutting, or grinding filter and contents until pieces smaller than one cm in narrowest dimension; characteristic UO filter for disposal subject to regulation (SUPERSEDED: see 261.4(b)(13))

10/01/1990REGULATORY STATUS OF PETROLEUM CONTAMINATED MEDIA AND DEBRIS UNDER THE TOXICITY CHARACTERISTIC UST TEMPORARY DEFERRALQuestion & Answer Description: 261.4(b)(10) exclusion applies to media and debris from UST corrective action; exclusion does not apply to sludge removed from UST during remediation; exclusion does not apply to media and debris that exhibit the toxicity characteristic for D003-D017

10/01/1990TC RULE - IMPLEMENTATIONMemo Description: potential impact of toxicity characteristic final rule on reinjection of petroleum-contaminated groundwater, solvent-contaminated chlorofluorocarbons (CFCs), automobile and appliance fluff, oil-contaminated media, and off-site crude oil reclaimers

09/20/1990SQG COMPLIANCE WITH TC RULEMemo Description: fuel oil leak from household tank is exempt household hazardous waste (HHW); EPA does not determine if particular waste is characteristic; hazardous waste determination is generator responsibility; SQGs newly subject due to toxicity characteristic (TC) rule had until 11/2/90 to notify Region; SQG granted additional three months to comply with TC Rule; spilled petroleum products reclaimed from contaminated soil and used to produce fuels are not solid waste

09/01/1990PRETREATMENT OF CHARACTERISTIC WASTES SUBJECT TO LAND DISPOSAL RESTRICTIONSQuestion & Answer Description: if ignitable characteristic waste (D001) is pretreated by dividing it into solid and liquid phases, solid phase is no longer regulated if not characteristic; phase separation is new point of generation; notification/certification requirements do not apply to solid phase; separation may be acceptable pretreatment if liquid phase is treated to treatment standards

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; 5/26/98); EP no longer used for purposes of hazardous waste identification

08/24/1990SPENT ANTI-FREEZE COOLANT REGULATORY STATUSMemo Description: waste antifreeze coolant (ethylene glycol) not listed hazardous waste (HW), but is solid waste if intended for discard; generator must determine if characteristic, by testing or applying knowledge; anecdotal evidence indicates used antifreeze may exhibit toxicity characteristic for lead, as determined using EP (extraction procedure)

08/17/1990USED OIL FILTERS CLASSIFICATIONMemo Description: if extract from TCLP-tested used oil filter equals or exceeds regulatory levels for any hazardous constituent, filter is a hazardous waste; filters that have been drained are less likely to be hazardous (SEE ALSO: 261.4(b)(13))

08/14/1990TCLP APPLICABILITYMemo Description: use of TCLP to evaluate solid waste prior to effective date of TCLP valid; matrix spike recovery use; TCLP difficult on oily or solvent matrices; in absence of usable data, safest to assume material hazardous waste (SEE ALSO: RPC# 3/25/91-01)

08/13/1990USED OIL AS A DUST SUPPRESSANTMemo Description: restrictions on use of used oil (UO) as dust suppressant (SUPERSEDED: see 279.12(b)); toxicity characteristic used oil must not be used as a dust suppressant (SEE ALSO: 279.82)

08/01/1990POINT OF GENERATIONQuestion & Answer Description: co-mingled corrosive wastes (D002) which neutralize each other subsequent to point of generation are individually subject to land disposal restrictions (LDR) (SUPERSEDED: wastes discharged under CWA are not subject to land disposal restrictions; SEE ALSO: 61 FR 15660; 61 FR 33681)

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 land disposal restrictions (LDR) treatment standard of macroencapsulation for D008 radioactive lead solids as generated; compliance with technology-based standard does not require that waste undergo TCLP analysis

07/19/1990ELECTRIC UTILITY POLESMemo Description: utility poles may exhibit the toxicity characteristic (TC) for organic constituents and trigger hazardous waste regulation; generator of used utility poles removed from ground must determine if poles exhibit a characteristic of hazardous waste

07/11/1990LOSS OF INTERIM STATUS FROM NEWLY IDENTIFIED TC WASTESMemo Description: loss of interim status (LOIS) dates for TSDFs subject to toxicity characteristic (TC) rule (55 FR 11798; 3/29/90); facility that obtained interim status for new TC waste is subject to federal requirements until State is authorized for TC; federal v. state regulation of TSDFs in authorized states that have not adopted TC rule; 3010 notification not required for facility that commenced treatment, storage or disposal after 6/27/90 but before 9/25/90

07/11/1990NEWLY IDENTIFIED WASTE STREAMS AS A RESULT OF NEW TCMemo Description: loss of interim status (LOIS) dates for TSDFs subject to toxicity characteristic (TC) rule (55 FR 11798; 3/29/90); facility that obtained interim status for new TC waste is subject to federal requirements until State is authorized for TC; federal v. state regulation of TSDFs in authorized states that have not adopted TC rule; 3010 notification not required for facility that commenced treatment, storage or disposal after 6/27/90 but before 9/25/90

07/03/1990CREOSOTE TREATED CROSS-TIES DISPOSALMemo Description: creosote-treated railroad cross ties are solid waste when intended for discard; not covered by any listing; although cresols and phenolic compounds in toxicity characteristic, commenters suggest creosote-treated cross ties unlikely to exhibit any characteristic

07/01/1990TOXICITY CHARACTERISTIC WASTE PART B PERMIT APPLICATION DEADLINESQuestion & Answer Description: Part A and Part B permit application deadlines for newly regulated land disposal facility and other types of facilities after promulgation of toxicity characteristic (TC) rule; definition of land disposal facility

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 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

06/27/1990SECONDARY MATERIALS RECYCLED IN PHOSPHORIC ACID RECIRCULATING SYSTEMSMemo Description: corrosive (D002), low-volume secondary materials (e.g., precipitates and spilled materials) that are recycled in phosphoric acid plant’s recirculating water systems may cause entire system to be regulated if there is continued circulation of corrosive secondary materials

06/25/1990LEAD-BEARING WASTES TREATMENT STANDARDSMemo Description: TC (toxicity characteristic) effective 9/25/90; 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)

06/20/1990CLARIFICATION OF SPENT SOLVENT LISTINGSMemo Description: if total of all F001, F002, F004, or F005 solvents before use is 10% or more by volume, waste from using solvent is listed and carries all applicable codes; F001-F005 codes can apply even if each F001-F005 constituent is under 10%; trichloromethane (chloroform) is U044 or D022, not F-listed

06/14/1990ADOPTION 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)

06/14/1990PERSONAL PROTECTIVE GEAR DISPOSALMemo Description: lead-contaminated personal protective equipment (PPE) or gear subject to land disposal restrictions (LDR); hazardous waste eligible for national capacity variance may be disposed without treatment in a minimum technological requirement (MTR) landfill or surface impoundment if waste is below California list prohibition levels (SUPERSEDED: California list removed, see 62 FR 25997; 5/12/97)

05/08/1990Environmental Fact Sheet: Final Rule for Third Third Scheduled Wastes Completes Statutory Requirements for Land Disposal RestrictionsPublication Description: Explains fifth in series of five Land Disposal Restrictions (LDR) rulemakings. Establishes treatment standards and effective dates for Third Third wastes; including characteristic wastes and soft hammer wastes from First and Second Third lists. Treatment standards apply to hazardous wastes that are land disposed; including those injected into deep wells.

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 toxicity characteristic when properly tested; 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 261.24)

04/05/1990DIMETHYL BENZENE-LISTING CLARIFICATIONMemo Description: benzene dimethyl (U239, CAS No. 1330-20-7), a synonym for xylene, listed for ignitability only (typographical error in CFR); 4/22/88 Federal Register (53 FR 13382) added CAS numbers and chemical synonyms to P- and U-lists

03/01/1990USED OIL USED FOR DUST SUPPRESSION OR ROAD TREATMENTQuestion & Answer Description: used oil that exhibits the toxicity characteristic is prohibited from placement on the land for dust suppression or road treatment; use for dust suppression or road treatment is use in manner constituting disposal (SEE ALSO: 279.82)

03/01/1990USED OIL USED FOR DUST SUPPRESSION OR ROAD TREATMENTQuestion & Answer Description: used oil that exhibits the toxicity characteristic is prohibited from placement on the land for dust suppression or road treatment; use for dust suppression or road treatment is use in manner constituting disposal (SEE ALSO: 279.82)

02/22/1990D001 CHARACTERISTIC WASTES - LAND DISPOSAL RESTRICTIONSMemo Description: waste cannot be disposed unless treated to land disposal restrictions (LDR) treatment standard, disposed in no-migration unit, or subject to exemption or variance from treatment standard; D001 ignitable waste must be treated to treatment standard before disposal; special requirements for ignitable wastes placed in surface impoundment, landfill, waste pile, and land treatment unit

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 not appropriate for toxicity characteristic

02/14/1990END-USERS OF CHLORDIMEFORM EXEMPTIONMemo Description: chlordimeform not listed; may be ignitable (D001); not subject if returned to manufacturer for resale or reclamation; if valid market, continued use as product not solid waste (SW); burden of proof on party making claim; canceled pesticides SW if discarded (abandoned), intended for discard, or fuel

01/30/1990IGNITABILITY CHARACTERISTIC TESTING FOR SOLIDSMemo Description: for ignitable solids (D001), there is no test method, only narrative definition (SEE ALSO: SW-846 method 1030 finalized in 6/13/97; 62 FR 32451)

01/15/1990Environmental Fact Sheet: Final Rule to Identify the Status of Twenty Mineral Processing Wastes Conditionally Retained within the Bevill AmendmentPublication Description: Identifies the 5 wastes removed from exclusion and the 15 wastes remaining within exclusion. Wastes no longer covered by Bevill exclusion will be evaluated for hazardous characteristics. Wastes exhibiting one or more characteristics of hazardous waste must be managed according to RCRA Subtitle C requirements.

12/13/1989DIGESTION OF EP AND TCLP EXTRACTS PRIOR TO METAL ANALYSISMemo Description: method 1310 (extraction procedure) (EP) and 1311 (TCLP) extracts should be digested prior to metal analysis if waste contains phases or if waste precipitates during cold storage

11/17/1989NITRIC ACID WASTE CHARACTERIZATIONMemo Description: while Federal regulations do not require waste codes on the manifest, nitric acid waste that is both ignitable (D001) (i.e., an oxidizer) and corrosive (D002) must be managed in compliance with all special requirements for D001 (e.g., 264.17) and D002 wastes; waste exhibiting two characteristics carries two waste codes

11/03/1989BLAST SLAG TESTING PROCEDURESMemo Description: representative sampling for blast slag generated at lead recycling facilities for purposes of extraction procedure (EP) (SUPERSEDED: see 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: definition of liquid depends on the specific regulatory application; for ignitable (D001), corrosive (D002), and extraction procedure (EP) (SUPERSEDED: see 261.24); 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; 1/13/95); only wastes containing a liquid component are subject to flash point test (ignitability (D001)) and 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 (the Liquid Release Test) is draft procedure for determining if adsorbents contain releasable liquids; adsorbents containing releasable liquids are prohibited from disposal in a landfill by HSWA

10/03/1989PETITION TO WITHDRAW K090 AND K091 LISTINGSMemo Description: K090 and K091 cover waste generated by air pollution control devices from ferrochromium or ferrochromium silicon production furnaces; K090 and K091 are listed for total chromium (Cr); as of 1989, no plan to remove listings since new data show trivalent Cr may be a carcinogen; EPA is considering removing 261.4(b)(6) exclusion for wastes containing trivalent chromium; EPA will not remove listed waste from regulation based solely on whether or not waste exhibits toxicity characteristic; in making delisting decisions, EPA considers whether waste meets any of the criteria for which it was originally listed, as well as additional constituents and factors

09/28/1989OFF-SPEC COMMERCIAL CHEMICAL PRODUCTS AT BOTTLING FACILITYMemo Description: product solvent that is discarded because it was contaminated with another product while being containerized is an off-specification CCP and is a P-listed or U-listed waste if solvent is listed in 261.33; RCRA waste codes and regulations applicable to wastes do not necessarily correspond to DOT hazardous material descriptions; wastes are defined as hazardous under RCRA, in part, based on characteristics, such as ignitability (D001) and corrosivity (D002)

08/25/1989CLARIFICATION ON THE SCOPE OF K088Memo Description: K088 only applies to carbon portion of the aluminum potliner inside electrolytic reduction cell; other portions of the pot containing

08/17/1989SCRAP DENTAL AMALGAMMemo Description: Dental silver amalgam is not specifically listed as a hazardous waste. 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 basis of determination by knowledge. CERCLA 107 liability is independent of material’s regulatory status under RCRA.

08/02/1989CHLOROFLUOROCARBONS (CFCS) AS REFRIGERANTS, RECYCLING OF SPENTMemo Description: used CFC refrigerants are not hazardous waste F001 or F002 because they were not used as solvents, and are not U121 because they have been used; such wastes are only hazardous if characteristic (SEE ALSO: 261.4(b)(12))

08/01/1989WASTE IDENTIFICATION OF DISCARDED THERMOMETERSQuestion & Answer Description: Unused mercury thermometer is not U151 when discarded. Thermometer is considered manufactured article, not CCP. EPA did not intend for P and U-lists to apply to manufactured articles containing chemicals listed in 261.33. Thermometers are hazardous waste if they fail toxicity characteristic for mercury.

07/20/1989LIQUID, FREE LIQUID, RELEASABLE LIQUID DEFINITIONSMemo Description: liquid for purposes of corrosivity (D002) determined by Method 1310 (extraction procedure) (EP); definition of free liquid applies to liquids in landfills prohibition; definition of releasable liquid applies to absorbent materials that might release liquids (SEE ALSO: current 264.314(e), 265.314(f))

06/30/1989DENTAL AMALGAM DISPOSALMemo Description: dental amalgam is not specifically listed, so generator is responsible for determining applicability of hazardous waste characteristics; silver and mercury are of particular concern; EPA has no plan to develop specific rules regarding recycling of dental amalgam

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

04/20/1989EP TOXICITY LEVEL FOR BARIUM IN DRINKING WATERMemo Description: 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 change to extraction procedure regulatory level (SUPERSEDED: See 261.24)

04/14/1989REGULATORY STATUS OF SPENT IGNITION TUBES AFTER SENT FOR RECLAMATIONMemo Description: used ignitron tubes sent off-site for mercury reclamation are spent materials and solid wastes, not commercial chemical products (CCPs); purity of the mercury within the tube is not a consideration when determining whether the ignitron tube itself meets the definition of spent material (the tube is what becomes spent); if mercury is removed from the tube on-site and only mercury is sent for direct reuse or further refining, mercury is product and not solid waste

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; transportation and sale of unused solvent, Ultima-Gold, is not subject to Subtitle C because it is a product rather than a discarded material; material safety data sheet for solvent product

01/27/1989TOTAL CONCENTRATION USED TO DEMONSTRATE A WASTE DOES NOT EXHIBIT THE CHARACTERISTIC OF EP TOXICITYMemo Description: maximum theoretical leachate concentration limits for TCLP can be calculated from results of total waste analysis of liquid wastes, solid wastes, and dual-phase wastes using specific formula; maximum theoretical extract concentration (MTEC) (SEE ALSO: RPC# 1/1/94-01)

01/25/1989FLUFF ANALYSIS/SAMPLESMemo Description: extraction procedure (EP) (SUPERSEDED: see 261.24) analyses of fluff should be conducted after samples have undergone appropriate size reduction; extraction procedure does not require 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)

12/01/1988CLOSED LOOP RECYCLINGQuestion & Answer Description: closed-loop exemption for secondary materials when reclaimed and returned to original process in which generated; portion of the secondary material that is returned to the original process is exempted from definition of solid waste; portion of secondary material which is discarded is solid waste; mixture of ignitable gases and liquids being reclaimed

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 subject to California list if equals or exceeds halogenated organic compound (HOC) prohibition levels (SUPERSEDED: California list removed, see 62 FR 25997; 5/12/97)

11/04/1988GENERATION AND TREATMENT OF K044 WASTEMemo Description: K044 (listed solely for exhibiting a characteristic) that no longer exhibits reactivity characteristic after being treated in facility’s wastewater treatment system is no longer K044, but must be designated as a hazardous waste if it exhibits another characteristic (SEE ALSO: 268.3)

10/19/1988MULTIPLE EXTRACTION PROCEDURE, METHOD 1320Memo Description: for multiple extraction procedure (Method 1320), weight of wet material remaining after each extraction procedure (EP), not original dry weight, is used calculate the 20:1 liquid to solid ratio; Method 1320 is trying to predict effect on waste in landfill subject to rain for a long period of time

09/19/1988QUESTIONS AND ANSWERS REGARDING THE HANDLING OF EXPLOSIVES AND COMMERCIAL FUELSMemo Description: off-specification fuel (i.e., jet fuel, kerosene, gasoline) used to burn planes during fire training exercise is not subject to regulation; resulting soil contamination may later be subject to federal cleanup authorities; law enforcement agents (BATF) transporting and detonating bombs and other reactive wastes may be exempt from RCRA Subtitle C regulation if action is immediate response; if not immediate response, emergency permit may be required (SEE ALSO: 62 FR 6622; 2/12/97); dropping munitions on land and detonating bombs is not discard and is not regulated because it is normal pattern of use; unexploded ordnance or bullets removed from firing range and sent for destruction via open burning/open detonation (OB/OD) are wastes subject to regulation; open burning of hazardous waste (other than explosives) is prohibited (SEE ALSO: 62 FR 6622; 2/12/97)

09/13/1988REACTIVE WASTE - EXPLOSIVITYMemo Description: reactive characteristic hazardous wastes (D003) fall under DOD Hazard Classes 1.1, 1.2, and 1.3, not 1.4

09/09/1988IGNITABILITY CHARACTERISTIC, DEFINITION OF UNDER STANDARD TEMPERATURE AND PRESSUREMemo Description: waste need not be evaluated for flash point if it is not a liquid at standard temperature (20ÝC/68ÝF) 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

07/29/1988CEMENT KILN DUST WASTEMemo Description: cement kiln dust (CKD) is not a hazardous waste (SEE ALSO: 60 FR 7366; 2/7/95); mixture of exempt cement kiln dust with corrosive liquid (D002) will result in nonhazardous waste if mixture no longer exhibits any characteristic (SEE ALSO 261.3(d)(1)); mixing is considered treatment; no permit required for treatment performed in generator accumulation tanks subject to 262.34

07/21/1988CHLOROFLUOROCARBON RECYCLINGMemo Description: used refrigerants meet the definition of spent material; used CFC refrigerant is not F-listed spent solvent but may exhibit a characteristic; used refrigerant is not U121 or U075 because has been used; P-listings and U-listings do not apply to used chemicals; cylinders containing used refrigerants to be reclaimed are solid waste (SW); generators may use knowledge of similar operations at different facilities to characterize waste (SEE ALSO: 261.4(b)(12)); owner of refrigeration equipment and company or individual performing servicing may be generators of used refrigerant waste (i.e., cogenerators)

06/02/1988DISCARDED CLASS C EXPLOSIVESMemo Description: only class C explosives designated as off-specification small arms ball ammunition (Š.50 caliber) are not reactive (D003); any other class C explosives, including small arms non-ball ammunition, may be HW; generator responsible for characterization

05/27/1988SOIL BACKGROUND LEVELS AS CLEAN CLOSURE STANDARDS, USE OFMemo Description: clean closure levels for surface impoundments, waste piles, and land treatment units must be based on EPA-recommended exposure levels or factors that have undergone peer review by EPA; where no health-based levels exist, clean closure levels are based on background or exposure levels submitted by owner based on toxicity data; recommendations for clean closure levels for lead and cadmium; lead background levels should be established by taking soil samples at uncontaminated area of facility or by using published literature data on lead levels in similar soils (SUPERSEDED: see RPC# 5/7/90-01)

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

05/02/1988SPENT PICKLE LIQUOR CORROSIVITYMemo Description: spent pickle liquor generated by steel fabricator is not K062 since facility is not in SIC codes 331 or 332; nonlisted spent pickle liquor is corrosive if it corrodes 1020 steel at a rate of >0.25 inches/year; nonlisted sludge from pickling tank is D002 if pH of the sludge is < 2; 264.314 liquids in landfills ban does not apply to nonhazardous waste disposal facilities

04/29/1988ELEMENTARY NEUTRALIZATION EXEMPTIONMemo Description: sumps, as defined in 260.10, are tanks; neutralization sump and ancillary equipment handling corrosive-only wastewater qualify for elementary neutralization unit (ENU) exemption

04/14/1988APPLICABILITY OF SOLVENT AND ELECTROPLATING LISTINGSMemo Description: discarded paint, residues (scrubber water) with solvent ingredient not F-listed, may be characteristic; paint stripper is solvent use; sludge from metal cleaning wastewater associated with electroplating is F006; routine cleaning, stripping not normally associated with electroplating; purpose of cleaning, not location, determines if associated; metal stripping part of electroplating; stripped paint waste listed solely for characteristic (F003) mixed with solid waste hazardous only if characteristic; mixture rule wastewater exclusions (SEE: 261.3(a)(2)(iv); F007-F009 for cyanide electroplating solutions or where cyanides used in process; spent stripping bath itself might also be F001-F005; scale, size of aluminum chemical conversion coating operation not affect F019

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; use of polyvinyl chloride (PVC) in well construction; calculation of purge volume; Part 264, Appendix IX; accelerated groundwater monitoring schedule can be used to bring facility into compliance; maintenance of groundwater monitoring network may include redevelopment of well; well maintenance should be included as a permit condition; replacement units (e.g. landfills and surface impoundments) must be retrofitted to meet minimum technological requirements; if proposed alternative to double liner does not meet requirements of 264.221(c), location characteristics or operating practices must compensate for deficiency; redundant flexible membrane bottom liner may be equivalent to 3004(o)(5)(B) interim statutory design, thus meeting 3004(o)(1) minimum technological requirements; use of Hydrologic Evaluation of Landfill Performance (HELP) model v. Moore’s Equation for calculating leachate volume when designing collection system; proposed modifications to cap design to reduce erosion potential; use of a test plot to support alternative landfill design cover; high-density polyethylene liner must be supported by a stable base; owner of petroleum refinery undertaking land treatment demonstration must fully characterize waste, including addressing Skinner List constituents in waste analysis plan; properly conducted land treatment demonstration should include evaluation of waste degradation, transformation, and immobilization, as well as a toxicity study; land treatment unit cannot accept sludges containing high concentrations of water if soil moisture conditions cause saturation of unit; selection of principal hazardous constituents for land treatment unit; owners of land treatment units who have not demonstrated satisfactory treatment of hazardous constituents may need to close unit; presence of high water table at land treatment unit and possible responses; owner of existing interim status land treatment unit may be eligible for immediate full-scale permit if land treatment demonstration addresses all necessary requirements; in states authorized for RCRA base program but not HSWA provisions, construction cannot begin at new facility until both state and EPA permits are issued; land disposal restrictions (LDR) program is self-implementing portion of HSWA, superseding permit as shield provision; permit content should be edited for applicability, importance, clarity, and precision prior to issuance; minimum detection limit (MDL) can be used to establish background as groundwater protection standard; any component required in RCRA facility investigation (RFI), such as monitoring releases not requiring immediate response, should be included as permit condition; monitoring wells installed as part of 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, must include pumping and removal requirements; air stripping may not be appropriate treatment method for groundwater contaminated with methyl isobutyl ketone; permit or 3008(h) order should address air emissions from treatment units such as air stripper; criteria for 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 verification monitoring at solid waste management units (SWMUs) during corrective action; HSWA corrective action permit may include technical feasibility clause discontinuing program once contaminant levels can no longer be reduced; EPA discourages approval of waiver allowing disposal of nonhazardous waste in 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); generator is responsible for hazardous waste determination

03/09/1988PROPOSED BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BDAT) FOR K061 WASTEMemo Description: zinc oxide collected in baghouse that is sold as a product is no longer derived from K061; calcining residuals from K061 wastes may exhibit a characteristic; use of K061 treatment residual as roadbed and anti-skid material is use in a manner constituting disposal (SEE ALSO: 266.20(c), 59 FR 67256; 12/29/94); K061 treatment standards are performance standards based on a Best Demonstrated Available Technology (BDAT) of high temperature metals recovery (HTMR); EPA does not require or recommend the use of any specific class of high temperature metals

02/22/1988WASTES CONTAINING F001-F005 CONSTITUENTSMemo Description: mixture with hazardous waste (HW) listed solely for characteristic not HW if mixture not characteristic (SEE ALSO: 268.3); mixture of F001, D001 carries all applicable codes; listed solvent constituent in wastestream does not automatically render waste HW; HW only if meets F001-F005 descriptions; if HW, subject to land disposal restrictions (LDR); if transporter mixes wastes of different DOT shipping descriptions, becomes generator of new waste

02/10/1988RESIDUALS GENERATED BY PROCESS FOR SEWAGE SLUDGE TREATMENTMemo Description: generator of residuals from treating sewage sludge must determine if residuals are characteristic hazardous waste; determination can be made by testing or applying knowledge of materials and processes; EPA does not endorse or support specific processes

12/31/1987TOTAL CONSTITUENT ANALYSIS TO DETERMINE HAZARDOUS CHARACTERISTICS OF WASTE SAMPLEMemo Description: applications of totals analysis in lieu of TCLP; if guidance levels of compound not exceeded assuming 100% leachability, no further analysis required; 100% leachability formula provided; maximum theoretical extract concentration (MTEC) (SEE ALSO: RPC# 1/1/94-01)

12/07/1987HYDROGEN SULFIDE WASTE IN SURFACE IMPOUNDMENT - REACTIVITY CHARACTERISTICMemo Description: narrative definition for reactive sulfide waste; interim guidance that wastes releasing more than 500 mg H2S/Kg of waste should be considered hazardous for reactivity characteristic (D003) (SUPERSEDED: see RPC# 4/21/98-01)

12/04/1987ALLOWABLE HOLDING TIMES WHEN TESTING RCRA SAMPLESMemo Description: holding time determination for RCRA samples; holding time begins when sample is generated; holding times for 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 considering use of paint filter liquids test, the extraction procedure, and the Toxicity Characteristic Leaching Procedure to determine compliance with statutory California List land disposal restrictions (LDR) prohibition levels (SUPERSEDED: California list removed, see 62 FR 25997; 5/12/97)

11/30/1987DETONATING EXPLOSIVE WASTESMemo Description: detonation of seized explosives for disposal rather than use constitutes discarding, so explosives must be managed as solid waste (SW); if explosives are characteristic for reactivity (D003), Subtitle C regulations apply to these Bureau of Alcohol, Tobacco, and Firearms (BATF) activities; seized explosives must be managed as SW and potentially hazardous waste from moment decision is made to destroy the explosives; detonation of reactive waste is thermal treatment

11/20/1987LEAD-BASED PAINT RESIDUES AND CONTAMINATED SOILSMemo Description: paint wastes exempt household hazardous waste (HHW) if generated by homeowners, not contractors (SUPERSEDED: RPC# 3/1/90-06); HHW from Federal agencies not HHW; certain material and soil contaminated with weathering lead based paint characteristic for lead; if characteristic soil actively managed, is hazardous waste; lead paint remediation methods (SEE ALSO: RPC# 3/7/95-01); property owner normally not required to characterize soil left on-site; factors in determining if soil removal required; on-site soil treatment needs permit unless generator 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 created for land disposal restrictions (LDR) program for testing for solvents and dioxins, and for the toxicity characteristic

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 representative sample for 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 toxicity characteristic (SUPERSEDED: see 261.24); method 1312 for in-place soil and debris under development; may be appropriate for facility investigations and clean closure determinations; 1311 (TCLP) may not be appropriate for groundwater contamination of soil and debris

10/26/1987REACTOR VESSEL WASHOUT CONTAINING TRACE AMOUNTS OF SOLVENTMemo Description: reactor vessel washout containing residues of solvent (acetone, ethyl acetate, and xylene) and fragrance oils is not F003, but is process wastewater contaminated with solvent constituents; if wastewater is ignitable, it is regulated as D001 until no longer characteristic

10/26/1987SOLVENT-CONTAMINATED WASTEWATER FROM FRAGRANCE MANUFACTUREMemo Description: oil and trace solvents that remain in reactor vessel following washing with acetone, ethyl acetate, and xylene do not meet spent solvent definition; subsequent soap and water washout is process wastewater containing solvent constituents that can be ignitable (D001), but is not F003 via mixture rule; residues generated from treating a D001 ignitable waste remain hazardous as long as they exhibit a characteristic

10/20/1987RCRA TESTING TECHNIQUESMemo Description: gas chromatograph/mass spectrometer suitability testing of RCRA Appendix VIII and Michigan List Analytes; notes on laboratory safety - noxious fumes from nitric acid digestion; standardization of method 8610; microwave oven safety; 1988 Solid Waste Testing and Quality Assurance Symposium; TCLP video; application of 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 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 Bevill exemption and does not plan on issuing specific guidance (SEE ALSO: 60 FR 7366; 2/7/95)

09/23/1987F021 LISTING FOR SUBSTANCES CONTAINING CHLOROPHENOLIC COMPOUNDSMemo Description: wood chips, sawdust from wood treated with pentachlorophenol (PCP) formulation (Noxtane) not F-listed or K-listed; could be characteristic; discarded CCP Noxtane F027 due to the active ingredient PCP

09/16/1987SW-846 METHODS MANUALMemo Description: use of SW-846 methods generally not required except for quality assurance/quality control procedures and determining if waste is characteristic; sampling, analysis for delisting petitions; incinerator trial burns; determining if bulk or containerized waste contains free liquids prior to disposal in a landfill

09/15/1987DEFINITION OF AQUEOUS FOR CORROSIVITY CHARACTERISTICMemo Description: for corrosivity characteristic (D002), a waste is aqueous if it has a liquid phase containing more than 50% water (SUPERSEDED: see RPC# 1/7/93-02; RPC# 4/23/93-01; RPC# 9/1/92-02)

09/14/1987AQUEOUS AS USED IN THE CORROSIVITY CHARACTERISTICMemo Description: aqueous for corrosivity characteristic (D002) is defined as waste having a liquid phase containing more than 50% water (SUPERSEDED: See RPC# 4/23/93-01)

09/01/1987AEROSOL PAINT AND SOLVENT CANS DEMONSTRATION OF REACTIVITYQuestion & Answer Description: aerosol can emptied according to 261.7 is still hazardous waste if it exhibits the reactivity characteristic (D003) (SEE ALSO: RPC# 1/4/94-02)

08/18/1987CORROSIVE CHARACTERISTIC APPLIED TO LIQUID AND AQUEOUS WASTESMemo Description: corrosivity characteristic (D002) applies only to aqueous and liquid wastes; no definition of corrosive solid

08/12/1987WASTE CHARACTERIZATION: LITHIUM BATTERIESMemo Description: lithium sulfur dioxide batteries (battery) tend to exhibit reactivity characteristic (D003)

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 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 characteristic even though they are contaminated with dioxins

07/21/1987F003 10% RULE AND ASSOCIATED REGULATIONSMemo Description: discarded, used paint thinner 80% xylene, 9% toluene, and 11% glycol ethers before use ignitable (D001) not F003, F005; ignitable solvent rags not subject to land disposal restrictions (LDR) until third third (SEE ALSO: 55 FR 22520; 6/1/90 and RPC# 2/14/94-01)

06/26/1987TREATMENT AND DISPOSAL METHODS FOR LOW-LEVEL WASTES THAT CONTAIN UNCONTAMINATED OR RADIOACTIVE LEADMemo Description: activated lead may be stored to allow radioactive decay prior to disposal as hazardous waste; mixed waste storage requires a permit; surface- contaminated lead may be decontaminated; EPA may establish below regulatory concern (BRC) levels for radiation; container liners used as shielding in low-level waste disposal are not RCRA-regulated; encapsulation may be viable treatment for lead wastes if process results in product that will not degrade after disposal (SEE ALSO: 64 FR 63464; 11/19/99)

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%; method of standard additions is required, in all cases, when analyzing extraction procedure (EP) toxicity extracts (SEE ALSO: 57 FR 55115; 11/24/92)

06/19/1987REGULATORY STATUS OF VARIOUS TYPES OF PENTACHLOROPHENOL WASTESMemo Description: F021 for pentachlorophenol (PCP) manufacturing wastes, not wood-preserving waste like dip tank bottom sludge or discarded pentachlorophenol (PCP)-treated wood (SEE ALSO: F032); F027 is unused PCP wood preservative, not used formulations which come in contact with wood that remains in process vessel or dip tank after treatment or contained-in treated wood (posts, poles, railroad ties); K001 for treatment sludges from wastewater from PCP or creosote wood preserving, not dip tank bottom sludge from PCP wood preserving facilities (SEE ALSO: 261.24 and 261.31)

06/08/1987TOTAL CHROMIUM ANALYSISMemo Description: toxicity characteristic regulates chromium as total chromium

05/20/1987SOLVENT LISTINGS AND LAND DISPOSAL RESTRICTIONSMemo Description: determining if solvent contaminated rags or wipers listed hazardous waste (SUPERSEDED: RPC# 2/14/94-01); product paint with solvent ingredient not listed, even if solvent added as thinner after purchase; addition of product solvent by user not solvent use; listed solvents from ink formulation both K086 and appropriate F001-F005 when discarded; lab solvents used as solvents listed when spent; technical grade F003 solvent can be F003 when spent; solvent containing (before use) less than technical grade F003 and less than 10% F001, F002, F004, F005 not listed

04/16/1987CHARACTERISTIC OF IGNITABILITYMemo Description: 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 and cannot be evaluated for flash

04/08/1987MUNICIPAL WASTE COMBUSTION, DISPOSAL OF RESIDUAL ASHMemo Description: regulatory alternatives for management of characteristically hazardous municipal waste combustor (MWC) ash (SEE ALSO: RPC# 10/1/94-02; 59 FR 29372; 6/7/94; 60 FR 6666; 2/3/95; RPC# 3/22/95-01)

04/08/1987SOIL CONTAMINATED WITH USED AND UNUSED PESTICIDES; SOIL CONTAMINATED WITH PESTICIDEMemo Description: soil contaminated with discarded unused 2,4,5-T contains F027; soil contaminated with 2,4,5,-T used as pesticide does not contain listed waste, but is hazardous if excavated for discard and is characteristic; incinerators burning F-listed dioxin wastes must achieve 99.9999% destruction and removal efficiency

03/18/1987REACTIVE CHARACTERISTICS OF DISCHARGED LI/SO2 BATTERIESMemo Description: based on supplied data, EPA agrees Li/SO2 (lithium-sulfur dioxide) batteries (battery) are unlikely to exhibit reactivity characteristic when fully discharged to zero volts; fully charged and duty-cycle Li/SO2 batteries are reactive; generator is responsible for hazardous waste determination; placement of ignitable (D001) or reactive (D003) waste into landfill is prohibited unless treated, rendered, mixed before, or immediately after, placement in landfill so that it is no longer characteristic (SEE ALSO: Part 268)

03/16/1987K062 LISTING APPLIES ONLY TO FACILITIES WITHIN THE IRON AND STEEL INDUSTRYMemo Description: pickle liquor wastes from industries not in iron and steel industrial classifications are hazardous only if characteristic; because spent pickle liquor is generally corrosive (D002) and usually contains high concentrations of chromium and lead, it is probably characteristic

03/11/1987SCINTILLATION COUNTING COCKTAILMemo Description: liquid scintillation cocktail Bio-Safe II does not appear to be a hazardous waste provided it is not reactive (D003) or corrosive (D002), since it is not ignitable (D001) and does not exhibit the toxicity characteristic (D018-D043); neither scintillation cocktails, nor lab wastes in general, are listed (SEE ALSO: RPC# 3/1/89-04); hazardous waste identification is generator's responsibility

03/11/1987SOILS CONTAMINATED WITH CHLORDANE AND HEPTACHLOR DURING TREATMENT OF BUILDINGS FOR TERMITESMemo Description: soil contaminated from treatment of home for termites with chlordane and heptachlor not P-listed or U-listed, because contamination from normal pesticide use; soil may be hazardous if characteristic; contained-in policy

03/06/1987AUTOMOTIVE FLUIDS, REGULATION OFMemo Description: automotive fluids not listed hazardous waste, may be characteristic; some brake and automatic transmission fluids ignitable (D001); used crankcase oil may be ignitable and exhibit EP (extraction procedure) for lead (SUPERSEDED: See 261.24); used oil (UO) recycled by burning subject to 266 Subpart E, other UO recycling exempt (SUPERSEDED: See Part 279); brake fluid, power steering fluid, automatic transmission fluid considered UO; antifreeze and windshield wiper fluid not UO (SEE ALSO 279.1)

03/06/1987AUTOMOTIVE FLUIDS, STATUS OFMemo Description: automotive fluids not listed hazardous waste, but may be characteristic; some brake and automatic transmission fluids ignitable (D001); used crankcase oil may be ignitable and may exhibit EP (extraction procedure) for lead (SUPERSEDED: see 261.24); used oil (UO) recycled by burning subject to 266 Subpart E, other UO recycling exempt (SUPERSEDED: see Part 279); brake fluid, power steering fluid, and automatic transmission fluid would all be considered UO; antifreeze and windshield wiper fluid not UO (SEE ALSO: 279.1)

03/06/1987DRYCLEANING INDUSTRY WASTESMemo Description: perchloroethylene (PCE) condensed and recovered during fabric drying in dry cleaning machine is process waste, not F-listed solvent; hazardous only if characteristic; PCE condensate from distillation or spent filter cartridge steam stripping is hazardous because derived from F002

03/03/1987ASH RESIDUE GENERATED FROM INCINERATION OF K045Memo Description: mixture rule exclusion applies only to mixtures of solid waste (SW) and hazardous waste listed solely for characteristic, not residues from treating wastes listed for characteristic; K045 incineration residue K045 even if ash not reactive

02/19/1987PROCESS WASTES CONTAINING INKS, PAINTS, AND ADHESIVESMemo Description: waste paint, ink, adhesive not listed; hazardous only if characteristic; products with ingredient or added solvent not listed solvent; mixture of listed solvent and product destined for discard F-listed via mixture rule

02/05/1987APPLICABILITY OF LAND DISPOSAL RESTRICTIONS (LDR) TO PAINT SLUDGE WASTES Memo Description: paint sludge waste from water-wall paint spray booth is manufacturing process waste, not F-listed solvent

02/01/1987F006Question & Answer Description: sludge generated off-site from mixture of corrosive (D002) electroplating rinsewater and other acid wastes is F006

01/27/1987SOLVENTS USED AS COOLANTS AND APPLICABILITY OF SOLVENT LISTINGSMemo Description: spent coolant with 1,1,1,-trichloroethane (111-TCE) as an ingredient is not listed if it is not commingled with 111-TCE used in degreasing (F001); coolant is only a hazardous waste if characteristic; future changes to toxicity characteristic might address TCE (SEE ALSO 55 FR 11862; 3/29/90)

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)

10/21/1986REGULATORY STATUS OF USED WOOD PRESERVATION CONTAINING PENTACHLOROPHENOL (PCP)Memo Description: mixture of unused pentachlorophenol (PCP) formulation (F027) and used PCP formulation that is spilled, disposed, or intended for disposal, is F027 via mixture rule; as F027 does not include used PCP formulations, only hazardous waste if mixed with listed or characteristic waste

09/30/1986GLASS FIBER FILTERS FOR USE IN CONDUCTING THE TOXICITY CHARACTERISTIC LEACHING PROCEDURE (TCLP)Memo Description: denial of request to add glass fiber filters to list of filters deemed suitable for TCLP purposes

09/29/1986SOIL CONTAMINATED WITH CHLORDANE AS A RESULT OF PESTICIDE APPLICATIONMemo Description: while unused CCP chlordane is listed as U036 when it is discarded, land application of chlordane pesticide product does not make it a solid waste even though it is used in a manner constituting disposal, since placement on land is the pesticide’s intended purpose (261.2(c)(1)(ii)); soil contaminated with chlordane as a result of pesticide application is a hazardous waste only if excavated for disposal and characteristic

09/15/1986DEFINITION OF SOLID WASTEMemo Description: ignitable discarded paint with xylene D001 as xylene not spent F003, nor discarded unused CCP (U239); mixture of waste listed solely for characteristic with solid waste not hazardous waste if mixture not characteristic (SEE ALSO: 268.3); spent toluene F005, not F002; pyridine osmium tetroxide mixture not P- or U-listed because mixture not pure or technical grade of chemical or sole active ingredient

09/04/1986MERCURY DRY CELL BATTERIES AND APPLICABLE REGULATIONSMemo Description: mercury dry cell batteries (battery) that exhibit a characteristic are hazardous waste (HW) and must be managed by a HW management TSDF, unless household hazardous waste (HHW) or CESQG waste (SEE ALSO: Part 273)

09/03/1986LABORATORY EQUIPMENT USED IN CONDUCTING THE TOXICITY CHARACTERISTIC LEACHING PROCEDURE (TCLP)Memo Description: tentative EPA decision to list zero-headspace extractor (ZHE) to list of suitable extractors for conducting evaluations of volatiles in TCLP

08/22/1986HYDRAULIC DEVICES CONTAMINATED WITH OIL DURING QUALITY CONTROL TESTINGMemo Description: used oil from hydraulic equipment hazardous waste if characteristic or if proposed used oil listing finalized (SUPERSEDED: See 51 FR 41900; 11/19/86, 57 FR 41566; 9/10/92, and Part 279); hydraulic equipment contaminated with used oil during quality control testing conducted prior to sale and distribution not subject to mixture rule because equipment product, not solid waste

08/04/1986PRE-COAT WASTE CONTAINING 2-ETHOXYETHANOL (EXTRUDING PROCESS WASTE)Memo Description: using solvents as reactants or ingredients in products is not solvent use; wastes from processes where solvents were used as reactants are not F-listed; waste from process where 2-ethoxyethanol was used as ingredient in pre-coating cannot be F-listed solvent waste, although it may exhibit a characteristic

07/02/1986WASTES GENERATED IN A PROCESS USING METHYLENE CHLORIDE TO RECOVER ALKALOIDS FROM PLANT MATTER; WASTES GENERATED FROM EXTRACTION PROCESSMemo Description: filter cake from extraction process with listed methylene chloride not listed, hazardous if characteristic; wastewater stripped from solvent wastewater not listed, hazardous if characteristic; spent solvent from extractor is listed hazardous waste

06/26/1986SILVER IN WASTES AND IN SEWER DISCHARGES FROM THE PHOTO-FINISHING INDUSTRYMemo Description: RCRA does not limit photo-finishing (photography) industry’s ability to discharge silver-containing wastewater (D011) to the public sewer; sewer discharge regulated under CWA

06/16/1986RESIDUAL WATER DERIVED FROM AN EXEMPT WASTE (COAL ASH) IS EXEMPTMemo Description: residual water that becomes corrosive (D002) from Bevill exempt fossil fuel combustion waste is also exempt; residual water derived from an exempt waste is exempt

06/02/1986PAINTING CONTRACTOR WASTES-SMALL QUANTITY GENERATORMemo Description: methylene chloride is listed waste (F002) when used as solvent and can be toxic; muriatic acid is likely to be corrosive (D002) but not toxic; generators who produce greater than 100 kg/mo are subject to regulation; CESQGs may dispose of hazardous waste in any state approved landfill

05/30/1986WASHWATERS GENERATED FROM WASHING PESTICIDE APPLICATOR TRUCKSMemo Description: truck, service vehicle wash rinsewater contaminated with pesticide from ground application not hazardous waste (HW) via mixture rule; residue not discarded CCP because released into environment from use; rinsewater HW only if characteristic (SEE ALSO: RPC# 7/22/85-01)

05/27/1986RESIDUES FROM MUNICIPAL WASTE RESOURCE RECOVERY FACILITIES; MUNICIPAL WASTE COMBUSTION RESIDUES-ASH AND SLUDGEMemo Description: municipal waste combustion (MWC) ash may exhibit toxicity characteristic; hazardous ash disposed in landfills is subject to all hazardous standards; EPA has authority under CAA and RCRA to control dust; RCRA is primary authority for groundwater protection at active landfills (SEE ALSO: RPC# 10/1/94-02; 59 FR 29372; 6/7/94; 60 FR 6666; 2/3/95; RPC# 3/22/95-01)

05/12/1986DEIONIZATION ACID REUSED, NOT A WASTEMemo Description: corrosive materials (deionization acid) that are beneficially reused as effective substitutes for a virgin material, meet relevant specifications for contamination levels, and used under controlled conditions are not solid waste; retroactive application of exclusions from the definition of solid waste; surface impoundment holding waste which has never been solid waste need not be closed

05/09/1986HEALTH ASSESSMENT INFORMATION IN LISTING DECISIONSMemo Description: EPA uses health assessment information such as relative carcinogenic potencies, along with other evaluations of potential exposure and mismanagement, in deciding whether a waste is hazardous

05/05/1986LABORATORY EQUIPMENT USED TO RUN THE TOXICITY CHARACTERISTIC LEACHING PROCEDURE (TCLP)Memo Description: steps necessary for designation of substitution TCLP zero-headspace extractor

05/02/1986ACTIVATED CARBON CANISTERS USED TO COLLECT SOLVENT VAPORS GENERATED DURING PAINT APPLICATIONMemo Description: F-listings do not apply to solvents such as 1,1,1-trichloroethane, Freon 113, and methylene chloride that are used as ingredients or reactants in CCPs (e.g., paint); activated carbon used to collect solvents volatilized during paint application would only be hazardous waste if characteristic; solvent use includes use as cleaning or degreasing agent, as medium for chemical reactions, as extractants, and as diluents

04/30/1986FLUORESCENT AND MERCURY VAPOR LAMPS AND CLASSIFICATION USING THE EP TOXICITY TESTMemo Description: fluorescent and mercury vapor lamps may exhibit toxicity characteristic (TC) for mercury as determined using extraction procedure (EP) (SUPERSEDED: See 261.24) (SEE ALSO: RPC# 12/7/92-01); some States regulate waste based on total mercury, and not leachable mercury

04/28/1986GENERATOR USE OF TOTAL CONSTITUENT ANALYSIS IN LIEU OF THE EP OR TCLP TESTSMemo Description: generator may use knowledge to make characteristic determination, including total waste concentration; when using total waste analysis in lieu of extraction procedure (EP) or TCLP tests, generator must assume all the contaminant present in waste will migrate or leach into liquid extract; maximum theoretical extract concentration (MTEC) (SEE ALSO: RPC# 1/1/94-01)

04/21/1986PRECIPITATION WHICH IS CORROSIVE DUE TO CONTACT WITH EXEMPT WASTES (COAL GASIFICATION ASH)Memo Description: precipitation that becomes corrosive (D002) solely as a result of contact with Bevill exempt fossil fuel combustion wastes (such as coal gasification ash) is exempt since characteristic is derived from the exempt waste

04/07/1986ENVIRONMENTAL RELEASES FROM WOOD PRESERVING PLANTSMemo Description: summary of EPA regulations applicable to releases from wood preserving facilities; wood preserving process wastewater effluent subject to CWA (SEE ALSO: 261.4(a)(9)); storage or mixing tanks, kraft bags can be empty containers under 261.7; applicability of F020, F021, F026, F027 listings; dioxin wastes are acutely hazardous and are subject to 1 kg threshold; wastewater treatment sludges from creosote and pentachlorophenol (PCP) are K001; closure of units used to treat these process wastewaters; applicability of EP (extraction procedure) toxicity characteristic (SUPERSEDED: see 261.24) to wood preserving wastes; 3004(u) and (v) corrective action at wood preserving facilities

04/07/1986WOOD PRESERVING AND SURFACE PROTECTION FACILITIES, CONTROLLING ENVIRONMENTAL RELEASES FROMMemo Description: summary of EPA regulations applicable to releases from wood preserving facilities; wood preserving process wastewater effluent subject to CWA (SEE ALSO: 261.4(a)(9)); storage or mixing tanks, kraft bags can be empty containers under 261.7; applicability of F020, F021, F026, F027 listings; dioxin wastes are acutely hazardous and are subject to 1 kg threshold; wastewater treatment sludges from creosote and pentachlorophenol (PCP) are K001; closure of units used to treat these process wastewaters; applicability of EP (extraction procedure) toxicity characteristic (SUPERSEDED: see 261.24) to wood preserving wastes; 3004(u) and (v) corrective action at wood preserving facilities

03/21/1986CHROMIUM WASTES: TRIVALENT AND HEXAVALENT, CHROMIUM IN TANNERY WASTESMemo Description: extraction procedure (EP) toxicity based on total chromium (hexavalent and trivalent) (SUPERSEDED: see 261.24); trivalent chromium oxidizes to hexavalent when drinking water treated with chlorine; tannery wastes containing solely trivalent chromium are excluded; extraction procedure thresholds 100X drinking water standard

03/12/1986DETECTION LIMIT FOR EP-LEACHATE CONCENTRATION OF SELENIUMMemo Description: detection limit for extraction procedure (EP) leachate concentration of selenium in petition

03/03/1986SPENT CARBON USED TO REMOVE DISSOLVED PENTACHLOROPHENOL (PCP) FROM GROUNDWATERMemo Description: spent carbon used to treat groundwater contaminated by product pentachlorophenol (PCP) spill is acute hazardous waste F027; under other circumstances, carbon is not regulated (SEE ALSO: 261.24 and 261.31: F032)

02/04/1986REGULATORY STATUS OF PHOTOGRAPHIC FILMS AND PAPERS UNDER RCRA SUBTITLE CMemo Description: photo film and paper not listed hazardous waste (HW); HW if characteristic; data suggest usually not toxic by extraction procedure (EP) (SUPERSEDED: See 261.24); generator must make determination; even if not contaminated, used photo film and paper removed from service to recycle are spent materials; unless characteristic, spent material status irrelevant

02/01/1986FOSSIL FUEL COMBUSTION WASTE EXCLUSIONQuestion & Answer Description: quench water that becomes corrosive (D002) as result of contact with ash from coal combustion is exempt under 261.4(b)(4) Bevill exclusion for fossil fuel combustion wastes since the characteristic is derived from exempt waste

01/22/1986COPPER PLATING SOLUTIONMemo Description: materials incorporated into products used on land are solid waste (SW) and potentially hazardous waste (HW) under use in manner constituting disposal provisions; corrosive (D002) spent copper sulfate bath used in fertilizer is SW and HW; commercial fertilizer product derived from characteristic HW not regulated

01/22/1986COPPER PLATING SOLUTION REACTED WITH A CHELATING AGENT TO PRODUCE A COMMERCIAL FERTILIZERMemo Description: materials incorporated into products used on land are solid waste (SW) and potentially hazardous waste (HW) under use in manner constituting disposal provisions; corrosive (D002) spent copper sulfate bath used in fertilizer is SW and HW; commercial fertilizer product derived from characteristic HW not regulated (SUPERSEDED: see 266.20(b))

01/17/1986SPENT IRON SPONGE REGULATION AND TREATMENTMemo Description: spent iron sponge which produces more than 500 mg/kg hydrogen sulfide is reactive (D003) (SUPERSEDED: see RPC# 4/21/98-01)

01/07/1986EXCLUSION FROM REGULATION FOR CHARACTERISTIC AND LISTED WASTES - LEACHATE LEVELS; DELISTING CRITERIA/LEACHATE LEVELSMemo Description: delisting criteria for variable constituent levels depending on waste volume; for delisting EPA considers original listing constituents and other factors; mixture of solid waste (SW) and hazardous waste (HW) listed solely for characteristic not HW if not characteristic under 261.3(a)(2)(iii) mixture rule exemption for wastes listed solely for exhibiting a characteristic (SEE ALSO: 268.3); leachate test used depends on nature of waste; use of extraction procedure (EP) for Oily Waste (SUPERSEDED: See 261.24)

01/06/1986RECYCLING OF MOLDING AND CASTING SANDSMemo Description: foundry sands are spent materials and are solid wastes when reclaimed (SEE ALSO: RPC# 3/28/2001-01); foundry sands are hazardous wastes if they exhibit the toxicity characteristic for lead; once regenerated or reclaimed, foundry sands are not solid wastes, and are exempt even if shipped off-site for coating before use; reclamation process is exempt; storage and transportation of spent material before reclamation is subject to regulation

12/01/1985USED OIL AS DUST SUPPRESSANTQuestion & Answer Description: used oil that exhibits characteristic of extraction procedure (EP) toxicity (SUPERSEDED: See 261.24) can be used as 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: extraction medium in extraction procedure (EP) (SUPERSEDED: see 261.24) may not be appropriate for determining hazardousness of oil shale; listing process may be used if data indicate 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: no determination on appropriate tests used to identify mining or Bevill exempt mining and mineral processing wastes to be regulated as hazardous waste; TCLP designed to simulate leachability of industrial waste co-disposed with sanitary waste; although 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

09/24/1985REGULATORY STATUS OF CREOSOTE-TREATED RAILROAD TIESMemo Description: creosote-treated railroad ties are not listed and are unlikely to exhibit any characteristic; FIFRA may place controls on handling and disposal

09/18/1985WATER/METHANOL MIXTURE WASTESTREAMMemo Description: mixture of F003 and wastewater exempt if mixture not ignitable; another option is to discharge to sewer; RCRA 3005(h) requires waste minimization plan (SUPERSEDED: see current 261.3(a)(2)(iii), 268.3)

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 substitute for the extraction procedure (EP) (SUPERSEDED: See 261.24) when analyzing oily wastes

07/16/1985CREOSOTE TREATED CROSS TIES, DISPOSAL OF, FIFRA INTERFACEMemo Description: creosote-treated railroad cross ties not likely characteristic; FIFRA may place controls on handling and disposal; U051 creosote and K001 and K035 do not apply to treated cross ties destined for disposal

07/16/1985SULFIDE REACTIVITY CHARACTERISTICMemo Description: no approved test method for reactivity characteristic (D003); 500 mg/kg available sulfide adopted as interim action level (SUPERSEDED: see RPC# 4/21/98-01); surface impoundment which is neutralization pond receiving only corrosive waste (D002) exempt from groundwater monitoring

07/12/1985INTERIM THRESHOLDS FOR TOXIC GAS GENERATION REACTIVITY (§261.23(A)(5))Memo Description: EPA provides interim thresholds of 250 mg HCN/Kg and 500 mg H2S/Kg respectively for solid waste that merit designation as reactive hazardous waste (D003) per 261.23(a)(5) for their potential to release toxic cyanide and sulfide gases (SEE ALSO: RPC# 11/8/93-01) (SUPERSEDED: see RPC# 4/21/98-01)

07/01/1985EP TOXICITY CHARACTERISTIC AMENDMENTSQuestion & Answer Description: discussion of draft TCLP; TCLP will be suitable for determining mobility of organic and inorganic compounds present in liquid, solid, and multiphase wastes

06/30/1985RCRA METHODS AND QA ACTIVITIES (NOTES)Memo Description: metal determination in groundwater (total recoverable, dissolved metals); organic determinations made only on groundwater samples that have not been filtered; dioxin method 8280; performance audits on gas samplers (organic cylinder gases); method 3540 validation; reactivity test methods

06/06/1985PROHIBITION ON USE OF HAZARDOUS WASTE FOR DUST SUPPRESSION AND ROAD TREATMENTMemo Description: HSWA ban on use of hazardous waste (HW) and characteristic used oil for dust suppression (exception for ignitable only wastes (D001)); prohibition applies to HW whether or not part of a mixture; decharacterized wastes not subject to ban; used oil that has not been mixed with hazardous waste and does not exhibit a characteristic may be used as dust suppressant (SUPERSEDED: see 279.82)

05/31/1985EMPTY DRUMS CONTAINING METALLIC NICKEL OR NICKEL OXIDEMemo Description: metallic nickel and nickel oxide are not listed or characteristic compounds; drums that contained these compounds are not hazardous

05/15/1985BATTERIES, WASTE ELECTROLYTE FROM RECHARGEABLE NICKEL-CADMIUMMemo Description: disposal of spent nickle-cadmium battery (batteries) potassium hydroxide electrolyte into sewer is excluded; spent electrolyte may be corrosive (D002) or toxic

03/04/1985DIOXIN IN WASTES FROM WOOD PRESERVING PROCESSES USING PENTACHLOROPHENOLMemo Description: F-listed dioxin wastes are rarely generated at wood preserving facilities, although if wood preserving facility makes chlorophenolic formulations or discards unused chlorophenolic formulations, they would generate F-listed dioxin wastes; EPA may amend K001 to address chlorinated dioxins and furans (see also: 261.31: F032-F035); F021 and F027 are listed for acute toxicity (H), while F028 is listed as a toxic waste (T)

02/26/1985AQUEOUS SOLUTION, IGNITABILITY DEFINEDMemo Description: alcohol exclusion created for beverages, but broader as alcohol defined by functional hydroxyl group [-OH]; use 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)

01/01/1985POLLUTION CONTROL SLUDGE FROM TREATMENT OF MINING WASTE - EXCLUSIONQuestion & Answer Description: pond sludge from the treatment of drainage from an active coal mine is exempt under 261.4(b)(7) Bevill exemption for mining and mineral processing wastes, even if it meets the definition of corrosivity; pollution control residues from treatment of mining wastes are exempt under 261.4(b)(7)

01/01/1985SOIL CONTAMINATED WITH CHLORDANEQuestion & Answer Description: soil contaminated with chlordane would only meet the U036 listing if the chlordane is spilled or discarded prior to use; soil is hazardous if it exhibits characteristic

12/20/1984RCRA METHODS AND QUALITY ASSURANCE ACTIVITIES (NOTES)Memo Description: RCRA Laboratory Evaluation Program; rationale for proposal of standard methods for testing groundwater at hazardous waste facilities (49 FR 38786; 10/1/84); analytical report on Method 3030 - acid digestion of oils, greases, and waxes; discussion of Waste Analysis Plans Guidance Manual, including “boundary conditions” and “tolerance limits;” 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: EP (extraction procedure) toxicity test 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 electroplating sludge, total, free (amenable to chlorination), leachable, and photodegradable cyanides must be analyzed; total and free using Method 9010; leachable using extraction procedure (EP) toxicity test (SUPERSEDED: See 261.24); photodegradable using Method 9011

11/30/1984SMALL ARMS AMMUNITION REACTIVITY, OFF SPECIFICATIONMemo Description: off-specification small arms ammunition (ball and sport ammunition) is not reactive hazardous waste (D003)

11/29/1984CORROSIVE SOLIDS, COMMERCIAL CHEMICAL PRODUCTS, REACTIVE WASTES DEFINEDMemo Description: solid forms of sodium hydroxide and potassium hydroxide are not D002 corrosive because no test for corrosive solids; formaldehyde residues in potato starch are not P-listed or U-listed hazardous waste; CCP comment in regulations in brackets and thus not part of regulations; reactive cyanide and sulfide levels (SUPERSEDED: see RPC# 4/21/98-01)

11/23/1984WASTE INK AND SOLVENT MIXTURES GENERATED FROM PRINTING FACILITIESMemo Description: waste solvent-containing inks are not listed spent solvents; waste may exhibit ignitability characteristic (D001)

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

09/04/1984RESPONSIBILITY OF GENERATOR IN HAZARDOUS WASTE DETERMINATIONSMemo Description: applicability of hazardous waste regulations to SULFA-CHECK spent slurry; suggested cyanide and sulfide concentrations for reactivity are less than 10 ppm (SUPERSEDED: see RPC# 4/21/98-01); generator does not perform determinations in 261.11(a)(2) to classify waste as hazardous, but rather uses process established in 262.11 to make a hazardous waste determination

09/01/1984PRECIOUS METAL ELECTROPLATING SLUDGEQuestion & Answer Description: sludge from precious metal electroplating is not F008 (SUPERSEDED: see 261.31, 50 FR 614; 1/4/85)

08/01/1984AQUEOUS WASTE AS IGNITABLEQuestion & Answer Description: ignitable (D001) aqueous waste containing no alcohol not covered under alcohol exclusion

08/01/1984LANDFILLS WITH EP TOXIC LEACHATE, REGULATION OFQuestion & Answer Description: once leachate is collected, subsequent management is regulated if leachate is hazardous waste; if extraction procedure (EP) (SUPERSEDED: see 261.24) toxic, leachate collected from sanitary landfill is pumped back into landfill, 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 which do not pass through the filter

06/04/1984CHEMICAL AGENTS GB, VX, AND HD AT MUNITIONS DISPOSAL FACILITYMemo Description: chemical agents GB (isopropyl methyl phosphonofluoridate), VX (Ethyl-S-diisopropyl aminoethyl methyl phosphonothidoate), and HD (Bis-2-chloroethyl sulfide) are reactive (D003) due to gas/vapor emission when mixed with water;

04/30/1984TOXICITY OF 2,4,D WASTEMemo Description: inclusion of 2,4,-D in toxicity characteristic and U-list based on National Interim Primary Drinking Water Standards (NIPDWS) evaluation; toxicity information for 2,4,-D

04/23/1984RCRA METHODS AND QUALITY ASSURANCE ACTIVITIES (NOTES)Memo Description: spot-check program to collect samples to verify delisting petition data; recommendation that audit cylinders containing organic compounds be used during all source measurement programs; problems with spike recovery for metals in Method 3030 - Acid Digestion of Oils, Greases, and Waxes; pH adjustment for extraction procedure (EP); materials that do not pass through 0.45um filter are solids and must be extracted; pH of oil and grease; impossible to determine pH of non-aqueous materials; unless specifically stated in method, results are to be reported “as received,” and sample is not dried before analysis

04/04/1984ANALYTICAL METHODS/EP TOXICITY TEST/REFERENCE STDS.Memo Description: adjustment of pH during extraction procedure (EP) toxicity test should be conducted with pH meter, not pH paper (SUPERSEDED: see current 261.24); extract digestion; testing manufactured articles that are structurally resistant to crushing; methods evaluation; 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 “Waste Analysis Plans Guidance Manual”; use of reference standards

03/07/1984REGULATORY STATUS OF SPENT/DISCARDED LITHIUM-SULFUR DIOXIDE BATTERIESMemo Description: lithium-sulfur dioxide batteries (battery) clearly exhibit the characteristic of reactivity (D003) because of their potential to generate toxic gas; insufficient information to make blanket determination for all lithium batteries; no determination whether lithium batteries with other cathode materials (e.g., thionyl chloride, polycarbon monofluoride, manganese dioxide, iodine, silver oxide, silver chromate, vanadium pentoxide, iron sulfide, copper oxide, and lead bismuthate) are reactive

03/01/1984XYLENE (U239) SPILLED ONTO SOILQuestion & Answer Description: if unused xylene is spilled onto ground, contaminated soil is not U239 if soil is not ignitable, due to mixture rule exclusion in 261.3(a)(2)(iii) (SUPERSEDED: see RPC# 3/22/94-03; RPC# 11/4/92-01)

01/01/1984FLAMMABLE COMPRESSED GASQuestion & Answer Description: 261.21(a)(3) should refer to flammable compressed gas, not ignitable compressed gas

10/01/1983AQUEOUS DEFINITIONQuestion & Answer Description: while EPA does not define term aqueous, as rule-of-thumb, any solution with greater than 60-70 percent water should be considered aqueous; any solution containing less than 60 percent water is nonaqueous (SUPERSEDED: see RPC# 7/1/92-03; RPC# 2/26/85-01)

07/27/1983WASTE BATTERIES AND CELLSMemo Description: waste batteries which are resistant to corrosion may be tested for with extraction procedure (EP) (SUPERSEDED: See 261.24) toxicity characteristic without particle reduction; saltwater test to measure corrosion resistance of product (battery casing)

07/01/1983MANUFACTURED ARTICLES TEST FOR EP TOXICITYQuestion & Answer Description: manufactured articles are tested for extraction procedure (EP) (SUPERSEDED: see 261.24) by reducing size of representative sample to pieces which can pass through 9.5 mm sieve, then performing extraction step; corrosion-resistant batteries (battery) do not have to be reduced in size prior to testing; guidance on determining corrosion-resistance

06/08/1983POPPING FURNACES-DOD DISPOSAL OF OUTDATED ORDNANCE BY INCINERATION - METALS RECOVERYMemo Description: outdated ordnance is reactive (D003); primary purpose of “popping” furnaces used by DOD to dispose of waste ordnance is waste disposal, not metal recycling; furnaces not exempt under 261.6, unless they can substantiate a claim of recycling; (SUPERSEDED: see 261.2, 261.6)

02/01/1983BENZENE LEAK INTO GROUNDWATERQuestion & Answer Description: benzene leaked into groundwater prior to 11/19/80 is classified as hazardous waste (HW) if pumped and treated after 11/19/80; benzene contaminated groundwater is U019; when site is reactivated, facility must comply with HW regulations

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)

01/10/1983IGNITABLE SOLID DEFINITION APPLIED TO TITANIUM SWARFMemo Description: to be ignitable (D001), a solid must be capable of causing fire and must burn so vigorously and persistently that it creates a hazard; if titanium swarf is dificult to ignite, it is not hazardous waste even though once ignited it burns vigorously

01/01/1983REGULATORY STATUS OF UNIT AND WASTE IF NONHAZARDOUS WASTE BECOMES REACTIVE WHEN DEWATEREDQuestion & Answer Description: nonhazardous wastewater that becomes reactive (D003) when dewatered may cause surface impoundment to be subject to regulation unless waste is immediately removed

12/01/1982USING LEASED PROPERTY AS BUFFER ZONEQuestion & Answer Description: owners or operators of facilities that use leased property as part of 50 foot buffer zone for containers holding ignitable (D001) and reactive (D003) wastes should ensure that lease will continue in force if land is sold; Part B permit should note that part of buffer area is leased

06/28/1981LIQUID WASTE, DEFINITION OFMemo Description: liquids are materials that pass through .45 micron filter at pressure differential of 75 psi; different phases should be evaluated separately based on liquid definition; free liquid is subset of liquid; liquids are ignitable (D001) if 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 Pensky-Martens or Setaflash Closed Cup Testers to determine flash point of potentially ignitable solid waste (D001); Tag Closed Cup Tester not 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: acceptable extractor for extraction procedure (EP) will impart sufficient agitation to mixture to not only prevent stratification of sample and extraction fluid but also insure that all sample surfaces continuously brought into contact with 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

09/16/1980FOOD PROCESSORS, IMPACT OF HAZARDOUS WASTE REGULATIONS ONMemo Description: caustic food processing waste may exhibit characteristic of corrosivity (D002); is not exempt even though neutralized before it leaves the facility as non-characteristic; waste not exempt simply because managed in safe and proper manner

01/10/1980APPLICABILITY OF 40 CFR 261.5 TO K047Memo Description: K047 (pink/red water from TNT operations) is listed for its potential to dewater over time and become reactive 

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