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06/26/92 18:18 0202 700 0226 EPA �OOJ/OOH <br /> therefore, the excess analytical solution is correctly <br /> classified as EPA Hazardous Waste No. P123 . <br /> 2) QUESTION: In the preparation of laboratory standards, P and <br /> U-listed chemicals are mixed with water, acids, bases, or <br /> solvents. The resulting standard solutions are disposed of when <br /> there is an excess, when they have exceeded their shelf life, or <br /> When they have been contaminated (not through use) . 'rhe disposal <br /> of these waste standard solutions bring about several waste <br /> classification questions. <br /> 2A) oUESTION: Are these waste standard solutions P or U-listed <br /> wastes in cases in which the P/U liatcd aeluto io dioaolvod in <br /> water, acidic/basic solutions, organic solvents, or homogeneously <br /> mixed in an inert medium such as soil? <br /> ANS14ER: The answer in all these situations is 11yas. " <br /> Dissolving or diluting those chemical products to make <br /> laboratory standards (in lieu of buying such solutions) does <br /> not constitute use of these chemicals . The Federal Recister <br /> notice which describes the sole active ingrodient rule <br /> (9261. 33 (d) ) refers to the fact that many of the compounds <br /> listed under §261. 33 (x) and (£) are frequently dissolved in <br /> solvents, preservatives, and the like, but this tact does <br /> not detract from the material 's meeting the listing <br /> dn.scription (Raa 6ri Za 7AS29, November 26, 1960) . Assuming <br /> that there is a sole active ingredient (or, in this case, <br /> analyte) , the mixtures you describe in your question meet <br /> the listing description in 40 CFR 251. 73 even if the <br /> solvent(s) used aro also listed in 9261.33 . <br /> 2B) QUESTrON: If in the preparation of standards an acid or <br /> base is used as the solvent for a P or U-listed chemical and the <br /> final solution is corrosive, is the solution, upon disposal, 0002 <br /> or DO04 - D017 if it exceeds the EP Toxicity criteria, or a P/U- <br /> listed waste? For example, the atomic absorption analysis of <br /> arsenic requires the preparation of a standard with arsenic <br /> trioxide. Specifically, 1. 32 q of AsaO3 (P012) (analytical <br /> reagent grads) is dissolved in one liter of distilled water, and <br /> several milliliters of concentrated nitric acid are added for <br /> preservation. Would the correct waste classification be P012, <br /> 0004, or D002 (if pg, < 2) or a combination thereof? <br /> ANSWEg: This situation is similar to the previous question. <br /> The solution you describe derinitely meets the listing <br /> description for P012 . Even if the waste is classified as a <br /> listed waste, waste generators should furnish information <br /> regarding whether the waste also exhibits any hazardous <br /> waste characteristics. There are several reasons for this: <br /> 1) saLety or personnel at these facilities; 2) Ttere are <br /> restrictions in 99264 and 265 regarding various <br /> characteristic wastes (e.Q• , reactivity and ignitabillty) in <br /> landfills or surface impoundments; and 3) The Land Disposal <br /> 2 <br /> A-95% 202 250 :225 05-26-92 01 : 25235 ?003 031 <br />