Previous Corner.
LAST MONTH’S CONTENT FOR YOUR CONVENIENCE.
In the United States, hazardous wastes are subject to regulations mandated by the Resource Conservation and Recovery Act (RCRA). Every month, we provide clear, in-depth guidance on a different aspect of the RCRA regulations. The information presented here is an excerpt from McCoy’s RCRA Unraveled, 2025 Edition.
©2025 McCoy and Associates, Inc. All rights reserved.
Treatment Standards for Listed Wastes
Treatment standards for listed wastes are much easier to interpret and apply than the standards for characteristic wastes. Footnotes 8 and 9 of the §268.40 treatment standards table don’t appear for listed wastes. Also, none of the treatment standards for listed wastes refer to §268.48 standards; hence, UHCs don’t have to be identified/treated in listed wastes unless the waste must also carry a characteristic code. [RO 14628] Finally, very few listed wastes have any subcategories. (F001–F005 spent solvents have four subcategories. Other listed wastes with multiple subcategories are F025—condensed light ends, spent filters and filter aids, and spent desiccant wastes from the production of certain chlorinated aliphatic hydrocarbons; K069—emission control dust from secondary lead smelting; K071—brine purification muds from the mercury cell process in chlorine production; K106—wastewater treatment sludge from the mercury cell process in chlorine production; P047—4,6-dinitro-o-cresol; P065—mercury fulminate; P092—phenyl mercuric acetate; U151—mercury; and U240—2,4-D.)
Most of the time, using the table of treatment standards in §268.40 for listed wastes simply involves looking up the proper waste code. Some listed wastes have rather complicated specified methods as treatment standards. For example, the treatment standard for K123 wastewater is “CMBST; or CHOXD fb (BIODG or CARBN).” Translated, this means 1) the waste may be combusted, 2) the waste may be chemically oxidized followed by (fb) biodegradation, or 3) the waste may be chemically oxidized followed by activated-carbon adsorption.
In one case (F024), the waste has both a specified method (CMBST) and concentration-based treatment standards. EPA chose this unusual treatment standard because the waste occasionally contains dioxins. Because the permitted treatment capacity for dioxin-containing wastes is extremely limited, the agency did not want to identify dioxin as a constituent of concern. Instead, EPA specified combustion (which destroys the dioxin) and then established concentration-based standards for the other constituents.
Topic: Point of Generation for Demolition Wastes
©2025 McCoy and Associates, Inc. All rights reserved.
McCoy and Associates has provided in-depth information to assist environmental professionals with complex compliance issues since 1982. Our seminars and publications are widely trusted by environmental professionals for their consistent quality, clarity, and comprehensiveness.
Disclaimer
Considerable care has been exercised in preparing this document; however, McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with the publication of this information. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which this information may conflict. McCoy and Associates, Inc. does not undertake any duty to ensure the continued accuracy of this information.
This document addresses issues of a general nature related to the federal RCRA regulations. Persons evaluating specific circumstances dealing with the RCRA regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.
