What is the current guidance regarding the reactivity characteristic? I heard that EPA had withdrawn the method for Reactive Cyanide and Reactive Sulfide as specified in Chapter 7 of SW-846. Is this true?
40 CFR §261.23 includes 8 different properties of a waste that is hazardous because of the characteristic of reactivity. A waste is a reactive hazardous waste if it exhibits one or more of those properties. The regulations do not require specific test methods for any of these properties. Therefore, generators must use waste knowledge to determine whether their waste exhibits the characteristic of reactivity.
According to property (5) under 261.23, a waste is hazardous if it is a cyanide- or sulfide-bearing waste which generates toxic gases or vapors at a quantity sufficient to present a health danger. In July 1985, EPA issued interim guidance describing certain threshold levels for cyanide- and sulfide-bearing wastes and laboratory methods for evaluating such wastes. In April 1998, EPA withdrew the July 1985 guidance in a memo from Bussard and Johnson to Love (http://yosemite.epa.gov/osw/rcra.nsf/0c994248c239947e85256d090071175f/1C580639372378C985257067006D94CE/$file/14177.pdf (RCRA Online #14177)). Therefore, EPA does not recommend use of the interim threshold levels or methods to determine if a waste is hazardous based on the characteristic of reactivity. The reactivity guidance threshold levels and laboratory methods were removed from SW-846 Chapter Seven in Update IIIB.