DEEP: RCRA "Contained-In" Policy

Connecticut’s RCRA "Contained-In" Policy

Characterization of Contaminated Soil and Groundwater

RCRA hazardous waste determinations for contaminated soil and groundwater may compare contaminant concentrations with the characterization criteria below. If the concentrations are below these criteria then the soil and 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 and groundwater and to encourage remediation of contaminated sites.

This policy applies to contaminated soil 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 and groundwater must be handled as non-hazardous contaminated soil and groundwater subject to applicable RSR polluted soil reuse requirements and to Connecticut solid waste requirements.


 Characterization Criteria

Characterization Criteria

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:
(A) Industrial/Commercial Direct Exposure Criteria in RSR2 and
[choose one method from B]:

(B) either TC Table1
100 x GA Pollutant Mobility Criteria in RSR3
100 x Groundwater Protection Criteria in RSR4

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:

Content Last Updated on August 8, 2019