Laserfiche WebLink
05/26/92 10:18 $202 1160 0225 EPA _ 11003/008 <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) . The disposal <br /> of these waste standard solutions bring about several waste <br /> classification questions. <br /> 2A) QUESTION: Are these waste standard solutions P or U-listed <br /> waste* in cases in which the P/U liatcd aeluto ie dinaolvod in <br /> water, acidic/basic solutions, organic solvents, or homogeneously <br /> mixed in an inert medium such as soil? <br /> ANSWER= The answer in all these situations is "yos. " <br /> Dissolving or diluting those chemical products to make <br /> laboratory standards (in lieu of buying such sclut:ione) does <br /> not constitute use of these chemicals. The Federal Register <br /> notice which describes the sole active ingrodiont rulo <br /> (5261. 33 (d) ) refers to the fact that many of the compounds <br /> listed under 5261. 33 (x) and (f) 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 /> d^snription (Rap as; EE 7RE29, November 25, 1980) . Assuming <br /> that there is a sole active ingredient (or, in this case, <br /> analyte) , the mixtures you describe in your question meet <br /> Lha listiny description in 40 CFR 261. 33 even if the <br /> solvents) used are also listed in 4261.33 . <br /> 2B) OUESTTON: 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, D002 <br /> or D004 - 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 g of As203 (PO12) (analytical <br /> reagent trade) 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 pA < 2) or a combination thorsof? <br /> ANSWEgz Tltis situation is similar to the previous question. <br /> The solution you describe definitely 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) surety of personnel at these faeilitiest 2) Ttere are <br /> restrictions in 11264 and 265 regarding various <br /> characteristic wastes (e-.cr. , reactivity and ignitability) in <br /> landfills or surface impoundmentsr and 3) The Lard Disposal <br /> 2 <br /> R-9536 202 250 0225 05-26-92 01 :252!! P003 #31 <br />