Frequent Questions

Is investigation-derived waste containing tetrachloroethylene (otherwise known as perchloroethylene or PCE) generated from soil found beneath a former dry-cleaner business a listed hazardous waste?

PCE contaminated media may be regulated as listed hazardous waste because contaminated environmental media is subject to regulation when it contains hazardous waste. Generally, EPA considers contaminated media to contain hazardous waste when it exhibits a characteristic of hazardous waste, or when it is contaminated with concentrations of hazardous constituents from listed hazardous waste that are above health-based levels (Management of Remediation Waste Under RCRA, EPA530-F-98-026). In addition, spent PCE used in dry cleaning is classified as F002 when the spent solvent formulation meets the ten percent (by volume) criterion in the listing (Call Center Monthly Report Question; October 1992, RCRA Online #13565). Therefore, contaminated media that contains spent PCE meeting the F002 listing description in §261.31 is regulated as F002. 

A generator must know the source and the before use concentration of PCE in order to determine if the F002 listing applies. If the source of the PCE is from a product spill (e.g., unused solvent), it could be a U210 listed waste.  A facility owner or operator must make a good faith effort to determine if a material is a listed hazardous waste. However, if an owner or operator cannot make such a determination because documentation regarding a source of contamination, contaminant, or waste is unavailable or inconclusive, the owner or operator may assume the source, contaminant, or waste is not a listed hazardous waste and, provided the material in question does not exhibit a characteristic of hazardous waste, that RCRA requirements do not apply (Management of Remediation Waste Under RCRA, EPA530-F-98-026). 

Furthermore, media that becomes contaminated with hazardous waste must be managed as if it were hazardous waste until it no longer exhibits a hazardous waste characteristics or no longer contains the listed waste. EPA believes that such levels for contaminated media are most appropriately determined on a site-specific basis by the EPA Region (or authorized state) overseeing cleanup of such materials (Management of Remediation Waste Under RCRA, EPA530-F-98-026). 

Additional guidance regarding the applicability of the F002 hazardous waste code is available in the following documents: 

Call Center Monthly Report Question; May 1991 (RCRA Online #13469
Memo, Lowrance to Wassersug; September 22, 1989 (RCRA Online #11470

Additional guidance regarding contaminated media is available in the following documents: 

Memo, Fields and Herman to RCRA/CERCLA Senior Policy Managers; October 14, 1998 (RCRA Online #14291
Memo, Shapiro to Wright, September 15, 1995 (RCRA Online #11948
Memo, Lowrance to Ely; March 26, 1991 (RCRA Online #11593)
 Memo, Cannon to Jorling; June 19, 1989 (RCRA Online #11434)

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