Connecticut’s RCRA "Contained-In" Policy
For the Characterization of Contaminated Soil, Sediment, and Groundwater
RCRA hazardous waste determinations for contaminated soil, sediment or groundwater may compare contaminant concentrations with the characterization criteria below. If the concentrations are below these criteria then the soil, sediment or groundwater do not need to be managed in Connecticut as RCRA hazardous waste. If the concentrations are above these levels then the soil/water must be treated, stored, transported, and disposed in the same manner as hazardous waste.
To simplify the management of non-hazardous contaminated soil, sediment, and groundwater and to encourage remediation of contaminated sites.
This policy applies to contaminated soil, sediment, and groundwater managed in Connecticut. It does not establish cleanup criteria. When contaminant concentrations are below the levels described in this policy, but are greater than applicable Connecticut Remediation Standard Regulations ("RSR") criteria, then the soil, sediment or groundwater must be handled as non-hazardous contaminated soil, sediment, or groundwater subject to applicable RSR polluted soil reuse requirements and to Connecticut solid waste requirements.
Soil and Sediment
|Characteristically hazardous waste " D codes"||
Non-hazardous if below levels in Toxicity Characteristic Table in 40 CFR 261.24 ("TC Table")1
|Non-hazardous if below levels in Toxicity Characteristic Table in 40 CFR 261.24 ("TC Table")|
|Listed hazardous waste "F,K,P,U codes"
See 40 CFR 261.33 for "P" & "U"
See 40 CFR 261 Appendix VII to identify constituents for which " F" & "K" wastes are listed.
Non-hazardous if below the lower of A and B:
(B) either TC Table1
|Non-hazardous if below 100 x GA Groundwater Protection Criteria in RSR|
1. via Toxicity Characteristic Leachate Procedure ("TCLP")
2. via mass analysis
3. via mass analysis or leachate analysis
4. via leachate procedure (e.g., TCLP or Synthetic Precipitation Leachate Procedure ["SPLP"])
For more information about the application of the Contained in Policy in Connecticut, see the following:
Characterization of Remediation Waste - Overview of Key Concepts: A PowerPoint presentation providing guidance on how to properly characterize remediation-derived waste under RCRA. See in particular slides 6 - 8.
"Contained-In" Policy References: A list of EPA documents that elaborate on the Contained-In Policy and its application in certain particular situations.
Content Last Updated on February 14, 2020