Memo Detail

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RCRA Online Number: 11182
Title: SOIL CONTAMINATED WITH CHLORDANE AS A RESULT OF PESTICIDE APPLICATION
Document Date: 1986-09-29
To: Warren
From: Claussen
Organization of Recipient: Warren, Goldberg, Berman and Lubitz
Description: While unused CCP chlordane is listed as U036 when it is discarded, land application of chlordane pesticide product does not make it a solid waste even though it is used in a manner constituting disposal, since placement on land is the pesticide's intended purpose (261.2(c)(1)(B)(ii)). Soil contaminated with chlordane as a result of pesticide application is a hazardous waste only if excavated for disposal and characteristic.
Regulatory Citation(s): 261.2(c)(1), 261.24. 261.33(f)
RPPC Number: 9444.1986(20)
Official ORCR Policy: Yes
Associated Topic(s): Characteristic Wastes, Disposal, Hazardous Waste, Hazardous Waste Recycling, P-wastes, Toxicity Characteristic