Frequent Questions

If a listed waste is also characteristic for ignitability, do both treatment standards have to be met?

If a listed waste were also characteristic, the treatment standard for the listed waste would operate in lieu of the characteristic treatment standard if it addresses the constituent that causes the waste to exhibit the characteristic.  For example, if an F001 spent solvent waste is characteristic for trichloroethylene (D040), only the treatment standard for F001 would need to be met because trichloroethylene is addressed by the F001 treatment standard.

However, there is conflicting EPA guidance regarding the applicable treatment standards for a listed waste that is also ignitable.  If an F003 and F005 solvent mixture exhibits the characteristic of ignitability (D001), the treatment stadards for F003, F005 and D001 need to be met because the treatment standards for F003 and F005 do not address ignitability.

If an F005 waste is also ignitable (D001), only the F005 treatment standard needs to be met because it will address ignitability.

When the listed waste treatment standard operates in lieu of the characteristic standard, the listed waste code would be included on the notification form in lieu of the characteristic code.

States may have more stringent standards.   Contact the state hazardous waste contacts.

References:  Memo, Shapiro to Nebrich, December 5, 1994 (RCRA Online #13721)
Memo, Weddle to Bowman, October 20, 1993 (RCRA Online #11787)
Memo, Lowrance to MacMillan, July 31, 1990 (RCRA Online #11545)
55 FR 22520, 22659, June 1, 1990
Memo, Shapiro to Prior, September 28, 1994 (RCRA Online #11877)
Memo, Shapiro to Dolce, March 1, 1994 (RCRA Online #11815)
Monthly Call Center Report Question, January 2001 (RCRA Online #14545)
54 FR 3864, 3867, January 31, 1991
State Contacts 

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