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M/ Y :IE QYOw.fO 0225 EPA Fj90L948 <br /> ' 10 Yq <br /> UNITED STATES ENVIRONMENTAL IROTECTION AGENCY <br /> P <br /> ;f WAShIIN GTO N, D.C, 2046 <br /> •I IVi111�' <br /> IJI IIVI ,)1 <br /> .ASI 14 1990 sc,l .v W.:,,1 :.H1, �.,, 1•..r„c1' Ni1VnnA. <br /> SUBJECT: RCWa is Classification of Laboratory Standards <br /> FROM: Dav ssaard; Director <br /> Characterization and Assessment Division (01;-330) <br /> To: Howard Wilson, Manager <br /> Environmantnl compliance Program <br /> Environmental Health and safety Division (PM-273) <br /> This is in response to your memorandum of March 1, 1990, in <br /> which you requested that we provide clarifinxti.on for the <br /> classification of wastes generated in laboratories. <br /> Specifically, you presented examples relevant to the _areparation <br /> of laboratory standards using substances ruyulatad under <br /> 30 CFR 261 . 33 (e) and (f) (the P and U lists) . <br /> 1) D_UESTION: In the preparation of performance evaluation (pE) <br /> samples containing P or U-listed chemicals, an aliquo•: of the <br /> sample is taken and diluted 100 - loon fold to a final volume of <br /> one liter of water or solvent before analysis. The first <br /> question related to this scenario is whether the PF sample is a <br /> commercial chemical Yruduct (CCP) or is eligible for exclusion as <br /> a sample_ Second, if the PE sample is indeed considered a <br /> commercial chemical product, you inquired whether the dilution of <br /> the PE sample before analysis is considered "use. ,, <br /> Fnr oandmple, organic semi-volatile PE oamplca to be analyzed <br /> for SOP" <br /> and NPDES certification will contain toxaphene (P123) . <br /> Would the disposal ofexcess analytical solution be considered <br /> P123 , D015 (if over o . 5 mg/L) , D002 <br /> of the above? (if pH < 2) , Or a combination <br /> ANSWER- Such samples are regulated as commercial chemical <br /> products provided that they have only one active ingredient. <br /> In the example you provided, the formulatiuf, coaslets of <br /> water plus the ccP as the sole active ingredient and, <br /> Pawl a Id.ryc4d Pap. <br /> R-959 202 260 0225 05-25-42 01 : 25?M PCO2 =31 <br />