oEPA
United SIMM
Environmental Protection
Agency
Off ice of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9441.19(85)
TITLE: Empty Drums Containing Metallic Nickel or Nickel
Oxide
APPROVAL DATE. 5-31-85
EFFECTIVE DATE: 5-31-85
ORIGINATING OFFICE: office of solid waste
® FINAL
Q DRAFT
LEVEL OF DRAFT
DA — Signed by AA or DAA
D B — Signed by Office Director
DC — Review & Comment
REFERENCE (other documents):
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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261 SUBPART A - GENERAL
DOC: 9441.19(85)
Key Words: Containers, Listed Waste
Regulations:
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Empty Drums Containing Metallic Nickel or Nickel Oxide
Frank W. Schaller, Inco Limited, Park 80 West-Plaza Two,
Saddle Brook, New Jersey 07662
Alan S. Corson, Branch Chief, Studies and Methods Branch
#9441.19(85)
5-31-85
This letter states that empty drums that contained metallic nickel or
nickel oxide are not a hazardous waste. This is because these substances are
not listed hazardous wastes/ nor are they covered by the EP toxicity charac-
teristic.
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9441.19 (85)
3f 1985
Mr. frank W. Schaller
Inco Limited
Park 30 West-Plaza Two
Saddle Brook, New Jersey 07662
Dear Mr. Schaller:
In your letter of May 8, 1985, you request an Agency
determination regarding the regulatory status of empty drums
that contained either metallic nickel or nickel oxide.
Under the current hazardous waste regulations, metallic
nickel and nickel oxide are not listed hazardous wastes nor are
they constituents covered by the EP Toxicity Characteristic.
Thus/ empty drums that contained these compounds are likewise
not a hazardous waste.
Although these waste are not covered under the Federal rules,
you should consult with State officials to determine whether State
requirements differ from the Federal. In many cases. State rules
are more stringent.
If you have questions or require additional information,
contact Jacqueline Sales, of my staff, at (202) 382-4807.
Sincerely,
Alan S. Corson
.Branch Chief
Studies and Methods Branch
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