Frequent Questions

What is the maximum quantity of waste that may be collected and shipped in order to retain the 40 CFR §261.4(e) treatability study exclusion?

Treatability study samples being collected must be no more than 10,000 kg of media contaminated with non-acute hazardous waste, 1000 kg of non-acute hazardous waste other than contaminated media, 1 kg of acute hazardous waste, or 2500 kg of media contaminated with acute hazardous waste for each process being evaluated for each generated wastestream [see 40 CFR §261.4(e)(2)(i)].

In addition, the mass of each sample shipped must be no more than 10,000 kg. This quantity limit may be all media contaminated with non-acute hazardous waste, or may include 2500 kg of media contaminated with acute hazardous waste, 1000 kg of hazardous waste, and 1 kg of acute hazardous waste [see 40 CFR  §261.4(e)(2)(ii).

The following memorandum provides additional clarification on the rationale for quantity limits, as well as a treatability study decision tree:

Memo, Lowrance to Regions; August 30, 1988 (RCRA Online #11366 )
Memo, Lowrance to Seeger; May 4, 1992 (RCRA Online #11667)
Memo, Bussard to Paulick; September 9, 1992 (RCRA Online #11695 )

These memoranda are available in the at the RCRA Online database.

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