Full Document:
RCRA Online Number: 14708
Title: POLICY ON THE MANAGEMENT OF RINSATE FROM EMPTY CONTAINERS
Document Date: 2004-04-12
To: Coles
From: Springer
Organization of Recipient: Hogan and Hartson, L.L.P.
Description: Even though rinse water from an 'empty' container may be non-hazardous, 261.7 does not exempt rinse water because rinse water is not a waste 'remaining in' an 'empty' container. When residue is removed from an empty container the residue is subject to full regulation under Subtitle C if the removal or subsequent management of it generates a new hazardous waste exhibiting any characteristics identified in Part 261, Subpart C. Rinsing an 'empty' container with an agent containing solvent that would be listed when discarded would cause rinsate from an 'empty' container to be listed due to the nature of the rinsing agent, not the nature of the waste being rinsed from the 'empty' container.
Regulatory Citation(s): 261.21, .3, 261, 261.20, 261.7
Official ORCR Policy: Yes
Associated Topic(s):
Characteristic Wastes,
Containers,
Identification of Hazardous Waste,
Listing Hazardous Waste |