Laserfiche WebLink
Mftita!!2 jl:N '0206 .40 0125 EPs 0D2/000 <br /> ' .ICY•. <br /> +A ' ' UNITED STATES ENVIRONMENTAL "OTECTION AGENCY <br /> 3 <br /> k ,f WQSMIN GTO N, D.C, 20460 <br /> NEXORANDUX IN 14 (990 MI Io w :.N„ .,I n•.P NCv NiSV nry Rr <br /> SUBJECT: RC W���i�§!te Classif ' ation of Laboratory Standards <br /> FROM: DavHussard�tor <br /> Characterization and Assessment Division (03-330) <br /> TO: Howard Wilson, Manager <br /> Environmontnl 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 clarifinat.i.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 rayulatsd cinder <br /> 40 CFR 261 . 33 (e) and (f) (the P and U lists) . <br /> 1) allESTT-ON: In the preparation of performance evaluation (PE) <br /> samples containing P or U-listed chemicals, an aliquot 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 PE s;lmple is a <br /> commercial chemical Vruduct (CCP) or is eligible for exclusion as <br /> a sample. Second, it 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 axAmpls, organic semi-volatile PE oamplcu to bs analyzed <br /> for SDWA and HPDES certification will contain toxaphene (P123) . <br /> Would the disposal of exoess analytical solution be considered <br /> F123 , D015 (if over 0 . 5 mg/L) , D002 (if pH < 2) , or a combination <br /> of the above? _ <br /> sR: Such samples are regulated as commercial chemical <br /> products provided that they have only one active ingredient. <br /> In thO oxample you provided, the formulatius, consists of <br /> water plus the CCP as the sole active ingredient and, <br /> frmul aldrrycW Payr <br /> A-�5% 202 260 3225 05-26-92 01 : 25PM P002 #31 <br />