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according to the Resource Conservation and Recovery Act(RCRA) as part of the above <br /> regulations. Additional analyses required by the landfills were also performed. <br /> 5. A waste is considered hazardous if it either exhibits the characteristics of a hazardous waste <br /> as defined in Article 3 of Title 22, Division 4.5, Chapter 11, or is specifically listed as <br /> hazardous in Article 4 of Title 22, Division 4.5, Chapter 11. Characteristics of a waste <br /> which could result in its classification as hazardous include ignitability,corrosivity, <br /> reactivity, and toxicity. Creosote-treated wood is not specifically listed as hazardous in <br /> Article 4 and is not known to possess hazardous characteristics for corrosivity, reactivity, <br /> and ignitability (subsequent analysis of the wood debris confirmed this determination). <br /> However, the characteristic of toxicity required evaluation. The toxicity of a waste is <br /> evaluated in two ways: <br /> • Comparison of reported concentrations of specific chemicals with their <br /> applicable regulatory levels as specified in Section 66261.24, or <br /> • Evaluation of whether the waste is toxic to aquatic life, as determined by <br /> a 96-hour aquatic toxicity test specified in Section 66261.24(b)(6). <br /> 6. Specific chemicals which are known or suspected to be present in the waste for which there <br /> are specific regulatory criteria require analysis. Creosote-treated wood contains cresol <br /> compounds which have specific regulatory levels listed in Section 66261.24(x)(1) per the <br /> Toxicity Characteristic Leaching Procedure (TCLP). The TCLP was promulgated by the <br /> EPA to determine whether a waste should be managed as hazardous according to RCRA <br /> and was subsequently adopted by California as part of 22CCR 66261.20. Therefore, to <br /> evaluate the potential hazardous characteristics for toxicity, the sample from the wood <br /> material was analyzed for the following: <br /> • Cresols by TCLP, and <br /> • 96-hour aquatic toxicity test. <br /> There were no other chemicals known or suspected in creosote-treated wood for which <br /> there are specific regulatory levels. <br /> 7. In addition to the above analyses,the potential landfills required the following additional <br /> tests to satisfy their own specific permit requirements: <br /> • Total petroleum hydrocarbons (TPH) as gasoline with benzene, toluene, <br /> ethylbenzene and xylenes (BTEX), <br /> • TPH as diesel, <br /> • Pentachlorophenol by TCLP, <br /> Total metals, and <br /> 2 <br /> ENVIRONMENTAL SOLUTIONS <br />