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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