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EHSO'S Free RCRA Hazardous Waste Identification Guidance Memos from the EPA

Identifying Hazardous Waste

Hazardous Waste Guidance Memos from the EPA

• Document Date, Document Title, Document Type
• 10/01/2000IDENTIFICATION OF UNDERLYING HAZARDOUS CONSTITUENTSMemo Description: characteristic wastes must meet universal treatment standards (UTS) for all underlying hazardous constituents (UHCs) prior to land disposal; fluoride, vanadium, and zinc are excluded from the definition of UHC because they do not appear in Part 261, Appendix VIII; 3004(m) authorizes EPA to develop treatment standards for constituents other than those for which a waste is listed
• 02/01/1988IDENTIFICATION NUMBERSMemo Description: definition of generator keyed to both person and site; where different persons conduct different regulated activities at one site, each person must apply for separate EPA ID number; Region or State implementing agency may assign same number to both entities
• 12/03/1990SHIPS AS GENERATORS AND EPA IDENTIFICATION NUMBERSMemo Description: The Navy and a contractor generating hazardous waste on a ship are cogenerators and can mutually pick who assumes generator responsibilities. Cogenerators operating at the same site normally use that site's EPA ID number for the manifest. A generator may use an "internal" tracking number to identify the contractor generating hazardous waste. Normally, there should only be one EPA ID number per site. Regions can make their own determinations on assigning EPA ID numbers to port facilities (SUPERSEDED: see RPC# 12/4/01-01).
• 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
• 02/05/1987RAPID ISSUANCE OF IDENTIFICATION NUMBERS TO SITES UNDER INVESTIGATION BY DEAMemo Description: EPA will issue provisional identification numbers by telephone to Drug Enforcement Administration (DEA) agents shipping hazardous waste from clandestine laboratories secured by DEA
• 03/04/1994USING A GENERATOR IDENTIFICATION NUMBER AND/OR MANIFEST TO DETERMINE LIABILITYMemo Description: The presence of an EPA ID number on the manifest is not the decisive factor in assessing liability. Cogenerators of waste are all potentially liable. While a second EPA ID number can be placed on the manifest to designate cogenerators, this is not required. There is no national policy on the issuance of EPA ID numbers for waste generated on ships (SUPERSEDED: see RPC# 12/4/01-01).
• 02/01/1990MANIFESTING REQUIREMENTS AND EPA IDENTIFICATION NUMBERSMemo Description: two facilities owned by same company but separated by a river must have separate EPA ID numbers; waste transported from one facility to another by public highway must be accompanied by manifest (SUPERSEDED: manifest exemption for shipments along the border of contiguous properties; 62 FR 6622; 2/12/97)
• 05/01/1988HAZARDOUS WASTE IDENTIFICATION - K111 LISTINGMemo Description: K111 listing includes product washwaters from the production of dinitrotoluene (DNT) as an intermediate to trinitrotoluene (TNT)
• 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)
• 06/13/1990USED OIL AND IDENTIFICATION OF LISTED HAZARDOUS WASTEMemo Description: F001-F005
• 04/06/1998USE OF CAS NUMBERS AS HAZARDOUS WASTE IDENTIFICATION AIDMemo Description: both anhydrous chloral and chloral hydrate are referenced generically as chloral and are regulated as U034; even though the CAS number under the U034 listing corresponds to anhydrous chloral, CAS numbers are added solely as an identification aid; the hazardous waste codes in 261.33(e) and (f) apply to all commercial chemical products or manufacturing intermediates having the generic name listed
• 12/22/1992IDENTIFICATION OF SPENT SOLVENT IN CERTAIN INDUSTRIAL PROCESSESMemo Description: toluene-containing polyurethane coating used in manufacture of marine buoys and fenders is not F005 when used to mechanically clear spray gun nozzle (i.e., not solubilizing) as long as solvent is not used for its solvent properties
• 05/15/1986UPPERMOST AQUIFER IN FILL, IDENTIFICATION OFMemo Description: groundwater monitoring must detect contamination in the uppermost saturated zone
• 06/12/1990CHEMICAL ETCHING PROCESS-HAZARDOUS WASTE IDENTIFICATIONMemo Description: bright dipping is chemical etching, a type of electroplating; wastewater treatment sludge from bright dipping process is F006
• 10/01/2002APPLICABILITY OF HAZARDOUS WASTE IDENTIFICATION RULE (HWIR) TO AS-GENERATED WASTESMemo Description: A waste listed solely for the characteristic of ignitability, corrosivity, and/or reactivity (i.e., hazard code I, C, and/or R) that does not exhibit a characteristic at the point of generation is not considered a listed hazardous waste and is not subject to the land disposal restrictions (LDR) requirements. A waste listed solely for the characteristic of ignitability, corrosivity, and/or reactivity that exhibits a characteristic at the point of generation and subsequently loses the characteristic is no longer considered a listed hazardous waste, but is still subject to LDR requirements (SEE ALSO: 66 FR 27266; 5/16/01).
• 09/29/1981STATES' ROLE IN ASSIGNING EPA IDENTIFICATION NUMBERSMemo Description: unauthorized states encouraged to assist EPA in assigning ID numbers; EPA encourages states that issue own ID numbers to adopt EPA numbering system; facilities may obtain EPA ID number if handling waste only regulated by State (not EPA); discussion of ID number issuing process
• 12/04/2001CRUISE SHIP IDENTIFICATION NUMBERS AND STATE REQUIRED ANNUAL REPORTING COMPONENTSMemo Description: Individual cruise ships should be assigned only one EPA hazardous waste identification number as a generator of hazardous waste for the purposes of RCRA. A cruise ship should determine its American-based home port state, which is the state in which it has corporate offices or its main port of call. The cruise ship should notify the selected state or appropriate EPA regional office of its hazardous waste activities and determine its generator size in accordance with 261.5(c). The home port state or region will issue a hazardous waste identification number. EPA recommends issuing ID numbers based on a ship's International Maritime Organization (IMO) number. Assigned ID numbers will remain with the ship and should be used on all hazardous waste manifests. State assigned numbers will not impact the applicability of state-specific RCRA requirements in other states.
• 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
• 01/16/1986IDENTIFICATION NUMBERS FOR RESIDUES GENERATED FROM THE TREATMENT OF HAZARDOUS WASTEMemo Description: residue from treatment of listed waste retains listing via the derived-from rule; residue from treatment of characteristic waste is regulated only if residue exhibits characteristic; TSDF is generator of treatment residue (SEE ALSO: RPC# 11/17/89-02)
• 11/17/1987COMPRESSIVE STRENGTH OF TREATED WASTES - USE OF SW-846 METHODS, WASTE IDENTIFICATIONMemo Description: EPA does not recommend that a specific compressive strength be incorporated into permits for wastes subject to liquid absorption/ adsorption treatment; compressive strength should increase over time; permit writers may require facilities to use SW-846 methods
• 08/15/1989EPA IDENTIFICATION NUMBERS AND FACILITY LOCATIONMemo Description: generators and transporters must obtain EPA ID numbers before they treat, store, dispose of, transport, or offer for transportation, hazardous waste; EPA generally issues one EPA ID number to each unique site; on-site definition may help in deciding whether facility constitutes more than one site for purposes of assigning ID numbers (SEE ALSO: RPC# 9/1/83-01); Region or State implementing agency ultimately decides how many EPA ID numbers apply to particular facility
• 08/03/1983RESPONSE TO REGION V'S EPA IDENTIFICATION NUMBER QUESTIONSMemo Description: ID numbers site-, not owner-specific; generator, TSDF at new site gets new site number; corporations at same site can have different numbers; lessor of federal property on federal site may get separate number; transporter company has one number for all trucks and trucking locations
• 05/01/1990HAZARDOUS WASTE IDENTIFICATIONMemo Description: mercury spilled from used thermometer is spent material and so is solid waste when reclaimed; mercury-contaminated soil is hazardous waste if it exhibits characteristic; P-list and U-list designation for spill residues applies to unused CCP, not used mercury
• 08/01/1989WASTE IDENTIFICATION OF DISCARDED THERMOMETERS Memo 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
• 12/05/1994LAND DISPOSAL RESTRICTIONS WASTE IDENTIFICATION REQUIREMENTS FOR ORGANIC HAZARDOUS WASTESMemo Description: if waste code for listed waste includes treatment standard for constituent that causes waste to exhibit characteristic, only the listed waste code needs to be identified for purposes of land disposal restrictions (LDR); treatment standard for the characteristic waste, including requirement to treat for underlying hazardous constituents does not have to be met
• 08/01/1996DEFINITION OF COMMERCIAL CHEMICAL PRODUCT FOR SOLID WASTE DETERMINATION VS. HAZARDOUS WASTE IDENTIFICATIONMemo Description: definition of commercial chemical product (CCP) for purposes of definition of solid waste v. for purposes of definition of P-listed or U-listed hazardous waste; for purposes of P- and U-lists, EPA intended to include only those CCPs and manufacturing chemical intermediates known by generic name listed in 261.33; P- and U- listed wastes exclude manufactured articles such thermometers and fluorescent lamps; for purposes of 261.2, CCP means all types of unused commercial products, whether chemicals or not; off-specification thermometers going for reclamation are CCPs going for reclamation and are not solid wastes; thermometers going for disposal are not U151 and are only regulated if characteristic