Are lead containers whose primary use is for shielding in disposal operations, hazardous waste under RCRA?
No. While lead containers and lead container liners may exhibit the hazardous characteristic for lead, those containers whose primary use is for shielding in low-level waste disposal operations are not considered wastes and thus, are not subject to the hazardous waste rules. These same containers and liners if disposed of or discarded would be considered wastes and if they exhibit the hazardous characteristic, would be subject to the hazardous waste rules. It should be noted that EPA recognizes that all lead containers and liners may be equally hazardous to human health and the environment when placed in the ground independent of its legal classification as a waste or container. Therefore, EPA recommends that all lead containers and lead liners be managed in an environmentally safe manner (e.g., managed in a permitted hazardous waste facility or treated such that it no longer exhibits its characteristic).Encapsulation may be a viable mechanism to mitigate lead migration from these cont
