Frequent Questions

What RCRA hazardous waste code would apply to soil contaminated with cyanide? We suspect that the soil may be contaminated as a result of an electroplating operation that generates F007 and F009 waste.

Contaminated environmental media can become subject to regulation if they "contain" hazardous waste.  EPA generally considers contaminated media to contain hazardous waste:  when they exhibit a characteristic of hazardous waste, or when they are contaminated with concentrations of hazardous constituents from listed hazardous waste that are above health-based levels.

Environmental media that contain listed hazardous waste must be managed as hazardous waste as long as they contain listed wastes.

Media that are contaminated with hazardous waste must be managed as if they were hazardous waste until they no longer "contain" the listed waste.  EPA believes that such levels for media are most appropriately determined on a site-specific basis by the EPA Region (or authorized State) overseeing cleanup of such materials.

A waste which contains a listed waste remains a hazardous waste until it is delisted.

References:  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)
57 FR 958, 986, January 9, 1992
61FR 18780, 18785, April 29, 1996
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