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726 Table 2. Typical Delisting References Guidance for Quality Assurance Project Plans - EPA QA/G-5, EPA/240/R-02/009, December 2002 User���s Guide Delisting Risk Assessment Software (DRAS) Version 3.0, October 2008 Delisting Risk Assessment Software RCRA Hazardous Waste Delisting: The First 20 Years, U.S. EPA, Office of Solid Waste, June, 2002 EPA RCRA Delisting Program Guidance Manual for the Petitioner, US EPA, March 23, 2000. Document Title Steps 1 and 2 ��� Identifying Constituents of Concern. There is perhaps no other step in securing a delisting that is more important than identifying the constituents of concern (COC). The process involves reviewing a number of regulatory lists (e.g., Appendix VIII and Appendix IX)iii to determine if a given constituent is in the subject waste. For one list of chemicals in particular, Appendix VIII, it is difficult to identify all of the chemicals on the list because either standard methods do not exist, or the procedure is incredibly expensive, or the method will not work in the matrix of the waste sample. Either way, it will be important to establish with the regulatory authority the total universe of chemicals to include in your review. One thing the petitioner (the entity conducting the delisting is termed the petitioner) should keep in mind is that it is your responsibility to provide a complete and thorough characterization of your waste. Ultimately, it is not uncommon for the petitioner and the agency to settle on analyzing for all constituents (~ 222 URL Major Steps in a Delisting. There are at least 12 (twelve) major steps in a typical delisting. These major steps, along with some information on timing, are included in Table 3. It is assumed that close coordination with the controlling regulatory agency will be a part of every step identified in Table 3.

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