How are the cyanide and sulfide reactivity characteristics determined?
These parameters are no longer determined analytically. With the promulgation of the Methods Innovation Rule on June 19, 2005, SW-846 was amended to withdraw references to required methods for testing of reactive sulfide and cyanide, and also withdrew the threshold levels for conditional delisting of RCRA Facilities. Please also see the 1998 memorandum regarding this issue.
Waste generators continue to have the obligation to determine whether their waste is RCRA hazardous under 261.23(a)(5) and 262.11, as well as other parts of the regulations. One must use the regulatory narrative for the determination of reactive cyanide and sulfide. The 1998 memo provides some guidance to waste generators, and there is a more specific Land Disposal Restriction (LDR) treatment standard for wastes that are hazardous under this provision (see 40 CFR §268.40).
There are a number of sources for more general guidance on making a "knowledge-based" hazardous waste determination under 40 CFR §262.11.