CO6GVRMDI - Laserfiche WebLink

Home Browse Search

RCRA CODE RQ NAME 0901 100 Unlisted hazardous wastes characteristic of ignitability 6002 100 Unlisted hazardous wastes characteristic of corrosivity 0003 100 Unlisted hazardous wastes characteristic of reactivity Unlisted hazardous wastes characteristic of toxicity: A corrosive characteristic waste is defined as having a pH less than or equal to 2 based on the regulatory definition below. § 261.22 Characteristic of corrosivity. (a) A solid waste exhibits the characteristic of corrosivity if a representative sample of the waste has either of the following properties: It is aqueous and has a pH less than or equal to 2 or greater than or equal to 12.5, as determined by a pH meter using Method 9040C in "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," EPA Publication SW- 846, as incorporated by reference in § 260.11 of this chapter. It is a liquid and corrodes steel (SAE 1020) at a rate greater than 6.35 mm (0.250 inch) per year at a test temperature of 55 °C (130 °F) as determined by Method 1110A in "Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," EPA Publication SW-846, and as incorporated by reference in § 260.11 of this chapter. (b) A solid waste that exhibits the characteristic of corrosivity has the EPA Hazardous Waste Number of D002. [45 FR 33119, May 19, 1980, as amended at 46 FR 35247, July 7, 1981; 55 FR 22684, June 1, 1990; 58 FR 46049, Aug. 31, 1993; 70 FR 34561, June 14, 2005] Semiannual pH readings from the North Pond (the source of the spill material) from 2016 -2021 indicate an average pH reading of 2.57 with a range from 2.11— 3.95. We do not believe our pond water is corrosive and thus not subject to a RQ. Regarding the prior spill on May 13, 2021, associated with an overturned guzzler truck (Record ID# C041KW1EE), that spilled material was similar in that it was also from our lined process water ponds. As you noted, the waste was shipped off as non-RCRA hazardous waste solid (CA waste code 181). Please note that the pH (from characterization samples, —6.5 to 7.5) did not trigger a hazardous waste characterization and none of the metals exceeded the CA hazardous waste limits. We have found in many cases that profile acceptance is more expeditious when we conservatively characterize wastes such as this as a Non-RCRA California hazardous waste. Please let me know if you have any follow-up questions on the waste characterization. Greg Greg Meyer Environmental Manager J.R. Simplot Company Tel. (209) 858-6470 I Cell. (209) 401-9845 Greg.MeyerSimplot.com Simplot 6