United States
Environmental Protection
Agency
Office of
Solid Waste
EPA/530-SW-85-003
April 1985
Solid Waste
Petitions to Deiist
Hazardous Wastes
A Guidance Manua!

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This  report  has  been reviewed by the  Office  of  Solid
Waste,  U.S. Environmental Protection Agency,  and approved
for  publication.   Mention of trade names  or  commercial
products does not constitute endorsement or recommendation
for use.

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   PETITIONS TO DELIST HAZARDOUS WASTES;
              A GUIDANCE MANUAL
                  April  1985
                Prepared  for:

        Waste Identification  Branch
Office of  Solid Waste and  Emergency Response
    U.S. Environmental Protection Agency
                     by:

            The Cadmus Group,  Inc.
              375 Concord Avenue
              Belmont, MA  02178
             Under subcontract  to
         Industrial Economics,  Inc
           Contract No. 68-01-6892
            Work Assignment No.  3
              U S Environmental Protection Agency
              Region 5, Library (PL-12J)
              77 West Jackson Boulevard, 12th hoof
              Chicago, IL  60604-3590

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00
                              ACKNOWLEDGEMENTS
          The authors are grateful to the following individuals and
          organizations for their assistance  in  the writing  of this
          manual:  Mr. William Sproat, Jr.,  of the U.S. EPA°s Office
          of Solid Waste (OSW),  who managed  the  Work Assignment and
          who provided the necessary leadership,  guidance  and en-
          couragement;  Messrs. James  Poppiti  and  Myles  Morse,  also
          of OSW, who supplied us with  information and advice at
          critical points;  and Ms.  Nancy Hammett, of Industrial Eco-
          nomics, Inc.,  who managed the contract  under which this
          Work Assignment  was performed and who greatly eased the
          administrative  aspects of the task.   In addition,  the
          following people and  firms contributed draft materials
          that formed the basis  for  some of the  sections.   Their
          assistance is sincerely appreciated.

                         Ms. Janie Harris
                         JRB Associates

                         Mr. Calvin Spencer
                         Ms Karen Christensen
                         Radian Corporation

                         Mr. George Parris
                         Dynamac  Corporation

                         Mr. Michael  Pich
                         Industrial Economics, Inc.

                         Mr. Mark Wagner
                         Geraghty & Miller, Inc.

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                        TABLE OF CONTENTS

                                                         Page

1.0  INTRODUCTION                                           1

     1.1  Purpose of This Manual                            1
     1.2  How Wastes are Listed as Hazardous                2
     1.3  The Rationale for the Delisting Procedure         3
     1.4  The Guidance Manual:  Contents and                5
              Organization

2.0  THE ELEMENTS OF THE DELISTING PROCESS                  9

     2.1  Submitting the Petition                           9
     2.2  Review of the Petition                           11
     2.3  Decision to Grant or Deny                        11

3.0  ADMINISTRATIVE INFORMATION AND SUMMARY                13

4.0  PRODUCTION PROCESSES                                  15

     4.1  General Process Information                      15
     4.2  Assessment of Hazardousness                      16
     4.3  Special Procedures for Certain Industries        18

5.0  THE WASTE STREAM                                      23

     5.1  Description of the Waste Stream                  23
     5.2  Description of Waste Management Methods          24

6.0  SELECTING CONSTITUENTS FOR WHICH TO TEST              25

     6.1  General Considerations                           25
     6.2  Engineering' Analysis to Determine What is        26
              Likely to be Present in the Waste
     6.3  Supporting Your Selection of Constituents        27

7.0  SAMPLING THE WASTE STREAM                             29

     7.1  Representative Sampling                          30
     7.2  Sampling Equipment                               31
     7.3  Sampling Techniques fpr Specific Forms           38
              of Waste
     7.4  Sample Handling, Storage, and Documentation      43
     7.5  The Written Sampling Plan                        46

8.0  SELECTION OF WASTE ANALYSIS METHODS                   47

     8.1  Tests for Characteristics                        47
     8.2  Tests for Constituents                           49

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9.0  PRESENTATION OF ANALYTICAL DATA                       51

     9.1  General Information                              51
     9.2  Sampling Information                             51
     9.3  Test Results       .                              52
     9.4  Quality Assurance and Quality Control            53


APPENDIXES


A.  Optional Form for Delisting Petitions

B.  Hazardous Waste Delisting Regulations (40 CFR 260 Subpart C)

C.  State Hazardous Waste Agencies and Delisting Contacts

D.  Hazardous Waste Characteristics (40 CFR 261 Subpart C)

5.  Lists of Hazardous Wastes (40 CFR Subpart D)

F.  Hazardous Constituents (40 CFR 261, Appendix VIII)

G.  How to Use a Random Number Table

H.  Typical Prices for Hazardous Waste Test Procedures

I.  Examples of Delisting Petitions:

                    Inorganic Wastes
                    Organic wastes

J.  Test Methods Not Available in SW-S46:

                    Extraction procedure for Oily Wastes
                    Total Organic Carbon
                    Total Oil and Grease
                    Determination of Reactive Cyanide and Sulfide
                    Determination of Photodegradable Cyanide
                    Explosive Hazard

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                        1.0  INTRODUCTION
1.1  Purpose of This Manual


     Under Part 261 of the hazardous waste regulations, the Envi-
ronmental Protection Agency has listed approximately 90 industrial
waste streams as hazardous.*  These wastes were listed because
they typically and frequently exhibit one or more of the charac-
teristics of hazardous wastes, or they typically and frequently
contain certain specific constituents that are known to be toxic
or otherwise hazardous at levels of regulatory concern.  A waste
stream from any facility which qualifies as one of the streams
listed in Subpart' D of the regulations is regulated as hazardous;
the Agency does not need to show for any particular plant that the
hazardous constituents are actually present.

     EPA has recognized, however, that a listed waste from a
particular facility may not actually be hazardous.  This could be
the case if the waste (a) does not exhibit the characteristics or
contain the constituents for which it was originally listed, or
(b) because it contains these constituents at relatively low
concentrations, or (c) although the waste contains the listed
constituents, they are present in an immobile form.**  These
situations could occur, for example, if a facility uses different
processes or raw materials than were assumed when the regulations
were written.  The regulations (in Sections 260.20 and 260.22),
therefore, contain a procedure for anyone to petition the Agency
to exclude, or "delist," s-uch waste streams from regulation.

     The purpose of this manual is, to assist persons who gene-
rate or manage listed wastes to submit delisting petitions.  Due
to the need to ensure that hazardous wastes do not reach the
environment, the delisting procedure requires you to submit infor-
     *The Agency also has listed approximately 360 commercial
chemical products as hazardous when they are discarded or intended
for discard.

     **The delisting criteria were recently modified by the Hazar-
dous and Solid Waste Amendments of 1984 to require the Agency to
consider any factors (including additional constituents) other
than those for which the waste was listed, if there is a reason-
able basis to believe that such factors could cause the waste to
be hazardous.

     ^References to Section numbers in this manual are current as
of March of 1985 .  Amendments to the delisting procedures after
this date may result in the renumbering of some Sections.

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mation on the processes and chemicals used.,  the results of tests
for hazardous constituents and hazardous waste characteristics,
the waste management practices currently in.effect,  and other,
related topics.  Due to the large amount of information required,
many petitions have contained errors and omissions.   This manual
is intended to address this need, and thus to avoid the costs and
delays that have frequently resulted.

     In the remainder of this Introduction,  we address some topics
that will help petitioners understand the background of the list-
ing and delisting processes.
1.2  How Wastes are Listed as Hazardous
     It is useful to understand how EPA. lists wastes as hazardous,
because that process forms the basis for the delisting procedure.
Subpart B of Part 261 of the hazardous waste regulations directs
EPA to list any waste as hazardous if it meets one or more of the
following criteria:

     1.   It exhibits any one of four hazardous waste
         characteristics;

               Ignitability
               Corrosivity
               Reactivity, or
               Extraction procedure (EP) toxicity.

         (The definitions of these terms are given in Chapter 8 of
         this manual.)

     2.   It has been found to be fatal to humans in low doses; or,
         in the absence of human toxicity data, it has any of the
         following properties:

          •  an oral LD50 (rat) less than 50 mg/kg,

          •  an inhalation LC^Q (rat) less than 2 mg/1, or

          •  a dermal LDcQ (rabbit) less than 200 mg/kg;

         or it has been found to otherwise cause or contribute to
         serious irreversible or incapacitating illness. Such a
         waste is called an acutely hazardous waste, and is sub-
         ject to control at smaller quantities than other hazar-
         dous wastes.

     3.   It contains one or more of approximately 350 hazardous
         constituents listed in Appendix VIII of Part 261 unless,
         after considering certain relevant factors, the Adminis-
         trator concludes that the waste cannot pose a substantial
         threat to human health or the environment when improperly

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         managed or disposed of.   Many of these constituents
         have been shown to cause cancer, genetic mutation, or
         embryonic damage in humans or other animals.

     Using these three criteria,  EPA produced  three  lists of haz-
ardous wastes,  which are given in Subpart D of the regulations.
The first two lists are based primarily on the third criterion
(i.e., presence  of  hazardous constituents).  The  lists are:

     1.   Hazardous waste from non-specific sources.   (Section
         261.31)   These  consist mainly of spent solvents and elec-
         troplating wastes.

     2.   Hazardous waste from 'specific sources.   (Section  261.32)
         These are mostly residues from manufacturing and waste-
         water  treatment processes.

The third list contains specific  commercial chemical products and
is based on all three criteria:   the  four hazardous waste charac-
teristics, the definition of "acutely" hazardous, and the presence
of hazardous constituents.   Specifically, it includes:

     3.   Discarded commercial chemical products, off-specifica-
         tion species, containers, and spill residues thereof.
          (Section 261.33)   This list is divided into two parts:
         acute hazardous wastes and other hazardous wastes.
1.3  The Rationale for the Delisting Procedure


     As we mentioned above,- EPA included in its regulations (in
Sections 260.20  and  260.22) a procedure  for  delisting  a waste  from
an individual facility if it can be shown that the waste does not
meet any of the criteria for  which  the waste was listed.  Until
recently, EPA required petitioners to demonstrate only that the
waste was not hazardous based on the criteria used by the Adminis-
trator in listing it.  Since  the petitioner was not? required to
test for other hazardous properties,  wastes containing hazardous
constituents at significant levels,still could be delisted.  Like-
wise, wastes that exhibited one or  more of  the hazardous waste
characteristics still could be delisted.  In several cases, EPA
found that wastewater treatment sludges from electroplating opera-
tions, although non-hazardous by virtue of  their  low heavy metal
content, contained high concentrations of several toxic solvents.-

     The delisting procedures  (as revised by the recently enacted
Hazardous and Solid Waste Amendments of 1984, Section 222) require
you to provide a more comprehensive description of the waste so
that EPA can judge whether factors  other than those for which  the
waste was originally  listed  may cause  the  waste  to be hazardous.
To characterize the  waste  adequately,  four  additional types of
information should be provided:

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     1A. A complete listing of raw materials, intermediate pro-
         ducts, by-products and final products, divided into three
         separate lists:

          •  all those materials that are used or produced in the
             processes at the plant or facility generating the
             waste;

          •  of those materials identified above, those that are
             discharged into or likely to be present in the waste,
             as well as the approximate quantities used or pro-
             duced; and

          •  of those materials identified above, those that you
             do not believe are discharged into or likely to be
             present in the waste,  and the basis for this belief?

     or

     IB. Representative analytical data for all hazardous waste
         constituents (as listed in Part 261, Appendix VIII) that
         are likely to be present in the waste at significant
         levels.  For all other hazardous constituents in Appendix
         VIII,  provide your rationale for why they are not expect-
         ed to be present at significant levels;

     and all of the following:

     2.  Test results on representative samples showing whether
         the waste exhibits any of the four hazardous waste char-
         acteristics (as given in Subpart C of Part 261).  Alter-
         natively, if you can explain why the waste cannot exhibit
         one or more of the four characteristics, you may submit
         your rationale in- lieu of test results for those charac-
         teristics .

     3.  Test results on representative samples for total organic
         carbon (TOC).

     4.  Test results on representative samples for total oil and
         grease.*

In addition, we shall collect ground-water monitoring data, if
available,  from the states and regional offices for consideration
in our petition review process.

     While this may seem like a lot of information for us to
request, it is justified by the seriousness of the harm that could
result if wastes that are still hazardous are delisted and escape
into the environment.
     *Data on total oil and grease have been requested of peti-
tioners since before the passage of the RCRA amendments of 1984
We list these items here for completeness.


                             - 4 -

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1.4  The Guidance Manual;  Contents and Organization


     This manual is intended to be a complete guide on how to
satisfy the delisting petition requirements.   It is intended to be
used by plant managers,  operators, and engineers.  In order to
keep it concise, we have not described the details of the various
waste testing procedures.   Most of the necessary information may
be found in the following  EPA publication:

     "Test Methods for Evaluating Solid Waste:  Physical/Chemical
     Methods," U.S. EPA Office of Solid Waste and Emergency Re-
     sponse, Publication SW-846 (second edition), July 1982.

This document and its supplements and revisions are available from
the Government Printing Office.   (Its order number is 055-002-
81001-2.)  You need to acquire it, however, only if you plan to do
the waste sampling and testing yourself.

     Many of the required procedures — particularly those re-
lating to the sampling and analysis of wastes — are complex and
must be performed by qualified personnel.  While some facilities
may have the required staff in house, others may need help from
consultants or commercial testing laboratories.  If you decide to
get outside help, you should make sure that the consultant or
laboratory is familiar with the procedures in the publication
cited above.

     The rest of this manual is divided into the following
sections:

          2.0  The Elements of the Delisting Procedure
          3.0  Administrative Information and Summary
          4.0  Processes and Materials
          5.0  The Waste Stream
          6.0  Selecting Constituents for which to Test
          7.0  Sampling the Waste Stream
          8.0  Waste Analysis Methods
          9.0  Presentation of Analytical Data

Appendices are also provided on the following subjects:

           A.  Optional Petition  Form
           B.  Delisting Procedures (Section 260.22)
           C.  State Hazardous Waste Agencies
           D.  Hazardous Waste Characteristics (Sections 261.21,
                    261.22, 261.23, 261.24)
           E.  Listed Waste Streams (Sections 261.31, 261.32,
                    261.33)
           F.  Hazardous Constituents (Part 261, Appendix VIII)
           G.  Use of a Random Number Table
           H.  Price Ranges for Hazardous Waste Test Procedures
           I.  Examples of Petitions for Organic wastes and
                    Inorganic wastes
           J.  Test Methods Not Available in Other References
                             - 5 -

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The optional petition form in Appendix A is intended to assist you
in reporting the required information.  You may substitute your
own reporting format as appropriate,  provided that it is clear and
complete.  In particular, facilities  having special petitioning
requirements as described in Section  4.3 will need to adapt the
optional form to suit their needs.

     A summary of the information required in most petitions is
given below.
     Administrative Information:

          Name,  Address,  Contact  Person,  Telephone Number,
               RCRA ID number
          Statement of Interest.
          Description of  Proposed Action
          Certification Statement

     Detailed Description of the  Manufacturing Process
          (Including Schematic Diagrams)

     Waste Stream Information:

          EPA Hazardous Waste Number
          Description of  the Waste
          Estimate of Average and Maximum Monthly and Yearly
               Quantities Generated
          Waste Management Information: Current and Proposed

     Sampling and Testing Information:

          Name and Address of Laboratories Used
          Names and Qualifications of Persons  Performing the
               Sampling and Analysis
          Dates of Sampling and Analysis
          Names and Model Numbers of the  Testing Equipment  Used
          Detailed Description of Methods Used to Obtain
               Representative Samples
          Description of  Sample Handling  and Preparation
          Description of  Chain of Custody Procedures
          A Statement and Evaluation of the Representativeness of
               the Samples
          Identification  or Description of the Tests Performed
          Quality Control and Quality Assurance Measures Taken

     Data on Representative Samples for the Listed Constituents
          and a Discussion of Why the Waste is Non-Hazardous
                             - 6  -

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Data to Determine Whether Other Hazardous Constituents  May
     Reasonably be Present:

     Listing of All Raw Materials Used in the Process
          Generating the Waste; of  Those  Materials,  a  Listing
          of Those Expected  to be Present in the  Waste  as
          well as Approximate Quantities  Used or  Produced;
          and of Those Materials Used in the Process,  a
          Listing of Those Not Expected  in the Waste and  the
          Basis for this Judgment;  or

     Representative Test Data for All Hazardous Constituents
          Expected in the Waste and an Explanation of  Why
          Those Not Tested For can  be Excluded

Data on Representative Samples for  Total  Organic  Carbon (TOC)

Data on Representative Samples for  Oil and Grease

Data on Representative Samples for the Hazardous  Waste
     Characteristics
                        - 7 -

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           2.0  THE ELEMENTS OF THE DELISTING PROCESS
     This section summarizes the delisting process.   There are
three major steps:

          A.   !fou submit the petition.

          B.   The Agency reviews the petition.   If it is incom-
              plete,  we request the missing information.  When all
              of the information is complete,  we review the peti-
              tion and make a tentative decision whether to grant
              or deny the request.

          C.   We then publish a proposed decision in the Federal
              Register and request comments.  If there are no
              comments, and if no new significant information
              comes to light, the Agency then publishes a final
              decision.  If new facts are brought forward, the
              Agency re-evaluates its tentative (proposed) deci-
              sion.

Below, we describe your responsibilities in each of these steps,
and what you should expect from us.
2.1  Submitting the Petition


     Before you submit a petition, there are several preliminary
issues that you should consider.

     Determining why your waste is hazardous.  You should review
the reasons why your waste was determined to be hazardous.  The
regulations issued on May 19, 1980 required all generators of
solid waste to determine whether their waste was hazardous (Sec-
tion 262.11).  Hazardous wastes were defined as those that are
either: (a) listed in Subpart D of Part 261 or (b) exhibit one of
the four characteristics (ignitability, corrosivity, reactivity,
or EP toxicity) described in Subpart C of Part 261.  If your waste
was listed, then it is possible that it can be delisted (assuming
the appropriate conditions are met).  If it exhibits one of the
four characteristics, however, it cannot be delisted and there is
no point in submitting a delisting petition.

     Determining whom to petition.  Both the Federal government
and the individual State governments have jurisdiction over haz-
ardous wastes.  In general, States whose hazardous waste programs
have been authorized by EPA to make delisting decisions can pro-
cess oetitions without EPA review.  (Note that delisting by a
                             - 9 -

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State does not exempt the waste from the Federal hazardous waste
program or from regulation in other States.)   Under the new RCRA
amendments, however, States will need to have their delisting
programs re-authorized to reflect the changes required by the
amendments in order to continue to delist wastes.  These changes
include the consideration of "other factors"  (including additional
constituents) in evaluating the hazardousness of the waste and the
requirement for notice and comment.  Therefore,  you should contact
either the Federal Regional Office or the State hazardous waste
agency to determine who administers the delisting program for your
State.  A list of Regional delisting contacts and State hazardous
waste agencies is included in Appendix C.

     Content of the petition.  The elements  of the petition are as
follows:

     A.  Administrative information and summary
     B.  Description of_the manufacturing processes, including
         schematic diagrams
     C.  Description of the waste stream and  management methods
     D.  The rationale for selecting the hazardous constituents
         for testing
     E.  Development of the sampling plan
     F.  Selection of waste analysis methods
     G.  Presentation of analytical data

The following chapters describe in detail what you are to report
within each topic heading.  In addition, two  Appendixes are pro-
vided to assist you in writing your petition:

       •  Appendix A presents a form that you may use as a guide.
          You may adapt it or use your own format if you wish,
          provided that the submission is complete and clear.

       •  Appendix I gives examples, drawn from petitions received
          by EPA in the past, that illustrate the content and
          level of detail that we look for.

Petitions are to be submitted to:

               The Administrator
               U.S. Environmental Protection  Agency
               401 M Street, S.W.
               Washington, D.C.  20460

A copy of the petition should also be submitted to:

               Chief, Waste Identification Branch
               Office of Solid Waste (WH-562B)
               U.S. Environmental Protection  Agency
               401 M Street, S.W.
               Washington, D.G.  20460
                             - 10 -

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2.2  Review of the Petition


     The petition review process is represented schematically in
Exhibit 2.1.   Petitions  that are  received  are  logged in and filed
with the Public Docket and with the Waste Identification Branch of
the Office of Solid Waste.  A  person from  the  delisting staff is
assigned to review the petition and to handle correspondence with
the petitioner.   Notices of all petitions  received are period-
ically published  in the Federal Register.

     We then conduct an initial review to  determine:

     •  Whether the waste is eligible for exclusion,  i.e.,  that it
        is a currently listed waste and

     •  Whether the petition is complete and the analytical data
        are representative of the waste stream.

If the information submitted is judged to  be incomplete, addi-
tional data are requested.  Once a petition is judged to be com-
plete, the reviewer makes  a tentative decision to grant or deny
the petition.   If the  tentative decision is to deny it, then you
are notified of this by letter and you are offered the opportunity
to withdraw the petition.  If  you decline  to withdraw it,  a draft
Federal Register notice is prepared that proposes to deny the
petition.   TT, however,  the decision is to grant the petition, a
draft Federal Register notice is prepared announcing that deci-
sion.  We also may recommend that the petition be granted on
condition that certain measures (for example,  monitoring)  be in-
stituted .

     The draft notices are then sent to a  workgroup consisting of
representatives from OSW and other Offices within EPA.  The work-
group carefully evaluates  the quality and representativeness of
the supporting data,  and submits comments  to OSW.   When all of the
comments raised by the workgroup have been addressed, the notice
is sent to the Office of the General Counsel  for  its  concurrence.
If that Office concurs,  the final recommendation is sent to the
Assistant Administrator for Solid Waste and Emergency Response for
his final review  and decision.
2.3  Decision to Grant or Deny


     The Assistant Administrator decides whether to approve the
Office's recommendation.   A notice of his proposed decision is
published in the Federal Register, along with a request for com-
ments on the action.   When the comment period closes,  the Office
reviews the information received  in response to the Notice, and
the proposed decision is  again reviewed by the workgroup and the
                             - 11 -

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                   EXHIBIT  2.1:    PETITION  REVIEW  PROCESS
                                         Log In
                                    Reviewer Assigned
                                          I
                                    Reviewer Checks For
                                     Complete Petition

                                   • Representative Samples
                                • Complete Process Description
                                   • Waste Quantity, Etc.
                                 Reviewer Makes Preliminary
                                   Assessment Of Whether
                                   Petition Can Be Denied
              Letter Sent
          Informing Petitioner
         Deny/Withdrawal Option
Additional Information
     Required
Petitioner
Responds
i

    Letter Sent
Requesting Additional
   Information
                                  Reviewer Recommends To
                                   Grant Or Deny Petition
                                     Reviewer Prepares
                                     Proposal And All
                                  Associated Documentation
                                                           Reviewer Prepares
                                                            Final Notice And
                                                        Associated Documentation
                                                            Takes Comments
                                                              and Evaluates
process  described above is repeated.   The Assistant  Administrator
then  makes  a  final  decision,  which  is  published  in the  Federal  Re-
gister as a final rule.
                                       -  12  -

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           3.0  ADMINISTRATIVE INFORMATION  AND  SUMMARY
     In this section,  we  describe  the  administrative  information
that you are required to  provide in your petition.  We also
suggest you provide a summary  of the technical  information;  this
will assist us in our review.   The material in this  section  cor-
responds to Section A of  the optional  petition form  in Appendix A.

     The following information should  be included at the beginning
of your petition.   Items  that  are  required  by  the  regulations  are
indicated by the appropriate Section number.   The  other items  are
not required,  but make it easier for us to  review the petition.

     o  The name and address of the individual or firm submitting
        the petition.   (Section 260.20(b)(1))

     o  The name,  address,  and RCRA identification number  of the
        specific facility to which the petition applies.   (Section
        260.22(1)(4))

     o  The names,  titles and telephone numbers of people  to
        contact for additional information.

     o  A brief description of the requested  delisting action  and
        a summary of your justification for the action (Section
        260.20(b) (2),  (3), and  (4)). (A detailed justification,
        along with supporting data, should  be furnished in later
        parts of the  petition.)

     o  The following statement signed by you, as generator  of the
        waste, or by your authorized representative  (Section
        260.22(i)(12)):

           I certify under penalty of  law that I have person-
           ally examined and am familiar with the information
           submitted  in  this  demonstration and all  attached
           documents, and that, based on my inquiry of those
           individuals immediately responsible for  obtaining
           the information,  I  believe that the submitted  in-
           formation is  true, accurate, and complete.   I am
           aware that there  are  significant  penalties  for
           submitting false information,  including the possi-
           bility of  fine and  imprisonment.

        An "authorized representative" is a person responsible for
        the overall operation  of a facility or an operational  unit
        (for example, a plant manager, superintendent, or  person
        of equivalent responsibility).  Consultants  or other out-
        side parties may not sign  the certification statement.
                             - 13 -

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                    4.0  PRODUCTION PROCESSES
     This section requests information on the manufacturing opera-
tions or other processes which generate the waste.  We require you
to submit sufficient information for us to determine what hazar-
dous waste characteristics and toxic constituents may be present
in the waste.  You must submit a description of the manufacturing
or other process that generates the waste.  You may choose either
to furnish a list of raw materials or to test for Appendix VIII
constituents; these options are described in greater detail below.
Special data requirements for petroleum refineries and multiple
waste treatment facilities are also described.

     This chapter corresponds to Section B of the optional peti-
tion form in Appendix A.  (Facilities having special petition
requirements should adapt the optional petition form as appro-
priate. )
4.1  General Process Information


     Please provide a description of the manufacturing processes
or other operations that produce the listed waste.  Examples may
include, as appropriate, the following items:

     •  Descriptions of production lines and major items of
        equipment.  Also describe the stages of the typical oper-
        ating cycle (e.g., startup, steady-state operation, clean-
        ing and maintenance) on a daily, weekly, or other basis as
        appropriate.

     •  A description of any surface and equipment preparation,
        cleaning, degreasing, coating or painting processes used
        in the facility that you have not included in the
        description of the production lines.

     •  A schematic diagram of all manufacturing processes, sur-
        face preparation, cleaning, and other operations that may
        provide influent to the waste stream.

You do not need to provide an exhaustive description of the pro-
cess.  Rather, you need only provide sufficient information to
allow us to understand your process, how and where the waste is
formed, and how the toxic constituents may end up in the waste.

     The regulatory requirement for the information requested in
this section may be found in Section 260.22 ( i)(5).
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4.2  Assessment of Hazardousness
     You may use either of the two approaches described below to
provide information on those constituents that may be present
in the waste.
Approach A;


     Please provide the following information:


     •  Test results on representative samples for the following:

          -  The specific hazardous constituents for which the
             waste was listed  (i.e.,  total  concentration of each
             listed constituent found in Appendix VII of Part
             261) ;

             The four hazardous waste characteristics;*

          -  Appropriate leachate tests for the EP toxic metals,
             nickel, and cyanide;

             Total concentrations of the EP toxic metals and
             nickel;

             Total organic carbon  (TOG); and

             Total oil and grease.

     •  A list of all materials used in the manufacturing or
        other operations that produce the waste.   To the extent
        possible, use the chemical name rather than the generic
        name (e.g.,  "sodium hydroxide"  instead of "caustic
        cleaner").   Specify the approximate quantities used annu-
        ally.  Examples of materials to be included are:

                    Raw materials
                    Intermediate products
                    By-products
                    Products
                    Oils and  hydraulic fluids
                    Surface preparation materials (solvents,
                         acids, cleaners,  surface preparation
                         agents, paints,  etc.)
     *Note that you may provide an explanation of why the waste
does not exhibit a  particular  characteristic,  in  lieu of testing
for that characteristic.
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     •  An indication of  which materials on the above  list  are
        either discharged into  the waste  or are  likely to be
        present in the waste.  For each material  so indicated,
        provide an estimate of  the amount that enters the waste
        stream annually.   (Please specify  kilograms,  pounds,  or
        similar units.)   For  any  of these  materials that  is speci-
        fied only in terms of a generic or trade name, please
        furnish a Materials Safety Data Sheet.

     •  From the above list of all materials  that are used  or
        produced at the plant or  facility, an indication  of which
        ones are not discharged into or likely to be present in
        the waste.  Also give the basis  for this  belief.

     •  Your assessment of the likelihood that these  processes,
        operations, or feed materials might produce a waste stream
        that is not included in  this petition.  Include considera-
        tions such as startup and shutdown operations,  mainte-
        nance, spills, leaks, and other  accidents.


Approach B;


     If you decline to furnish  the information requested  in Ap-
proach A above, then you  should  furnish the following information
instead:

     •  Test results on representative samples for the following:

             The specific hazardous constituents  for  which  the
             waste was listed (i.e.,  total concentration  of each
             constituent found  in Appendix VII of Part 261);

             All other constituents listed in Appendix VIII of Part
             261 that are likely  to be present in the waste at
             significant levels;

          -  The four hazardous  waste characteristics;

             Appropriate leachate tests  for EP toxic  metals,
             nickel, and cyanide;

             Total organic carbon; and

             Total oil and grease.

     •  For those constituents  listed in  Appendix VIII of Part 261
        that the petitioner does  not expect to find (and  thus does
        not analyze for), an explanation  of why  this  is reason-
        able.  Your explanation may be presented  on a substance-
        by-substance basis or for a group of  substances.   If  the
        Agency does not find your explanation satisfactory, we
        shall  either ask that you analyze for the additional
        constituents or ask that  a better  explanation be  provided.


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4.3  Special Procedures for  Certain Industries


     Certain industries generate wastes  whose constituents  vary
widely, and for which raw materials data cannot generally be
provided.   Therefore, we require petitioners  in  these  industries
to perform testing  for  certain  constituents that we  feel  can
reasonably be expected to be present in  the waste  streams.  Also,
we request additional information on manufacturing  and  waste
treatment processes beyond that which was requested in Section 4.1
above. The industries covered by these special procedures are
Petroleum Refining and Multiple  Waste Treatment (i.e.,  commercial
offsite waste treatment facilities that  accept waste from a vari-
ety of  generators).


     Petroleum Refining Wastes

     In lieu of Approaches A or B above, please furnish the
following information:


     •  Test results on a representative number  of  samples for
        each of the following:

           The four hazardous waste characteristics.   If  your
           waste contains greater than  1 percent oil and  grease,
           use both the extraction procedure from Section 261.24
           and the extraction procedure  for oily waste  when test-
           ing for EP toxicity.  (The oily waste procedure is
           required for all wastes that  have  an  oil and grease
           content greater than  1  percent.)

           Total organic carbon (if total  oil and grease  is  less
           than 1,percent).

           Total oil and grease.

           Weigh»t of the solid residue remaining after Step 9 of
           the EP toxicity test for oily waste.

           Total concentrations of EP toxic metals  in  the waste.

           Total concentration of each  of the  constituents shown
           in Exhibit 4.1 (some of  these will already have been
           included  in the tests for EP toxic metals).

     •  Your assessment of the likelihood that these processes,
        operations, or feed  materials might produce a  waste stream
        that is not  included in  this petition.   Include considera-
        tions such as startup and shutdown operations,  mainte-
        nance, spills,  leaks,  and  other accidents.
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   EXHIBIT  4.1:   CONSTITUENTS OF  PETROLEUM  REFINING WASTES
1 .   Metals

    Antimony
    Arsenic
    Barium
    Beryllium
    Cadmium
    Chromium
    Cobalt
    Lead
    Mercury
    Nickel
    Selenium
    Vanadium
2.  Volatiles

    Benzene
    Carbon disulfide
    Chlorobenzene
    Chloroform
    1,2-Dichloroethane
    1,4-Dioxane
    Ethyl benzene
    Ethylene dibromide
    Methyl ethyl ketone
    Styrene
    Toluene
    Xylene
3.  Semivolatile Base/Neutral
    Extractable Compounds
    Benzo(b)fluoranthene
    Benzo(k)fluoranthene
    Benzo(a)pyrene
    Bis(2-ethylhexyl)  phthalate
    Butyl benzyl phthalate
    Chrysene
    Dibenz(a,h)acridine
    Dibenz(a,h)anthracene
    Dichlorobenzenes
    Diethyl  phthalate
    7 ,1 2-Diinethylbenz( a)anthracene
    Dimethyl phthalate
    Di(n)butyl phthalate
    Di(n)octyl phthalate
    Fluoranthene
    Indene
    Methyl  chrysene
    1-Methyl naphthalene
    Naphthalene
    Phenanthrene
    Pyrene
    Pyridine
    Quinoline
4.  Semivolatile Acid-Extractable
    Compounds

    Benzenethiol
    Cresols
    2,4-Dimethylphenol
    2,4-Dinitrophenol
    4-Nitrophenol
    Phenol
    Anthracene
    Benzo(a)anthracene
                                - 19  -

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     Wastes from Multiple Waste Treatment Facilities

     Multiple Waste Treatment Facilities (MWTFs)  typically receive
large numbers of individual waste shipments having a wide variety
of compositions.   Therefore,  MWTFs  cannot describe  adequately the
"raw materials"  for  the treatment process or use  a  mass  balance to
demonstrate the  presence or absence of a constituent in  the treat-
ment residue.   In addition,  it is more difficult  for them to
demonstrate that waste samples are  representative.

     Due to the  differences between this hazardous  waste category
and others, we have  specified a more  rigorous sampling and testing
strategy than is otherwise required.   In addition,  petitioners
must submit a  plan for testing each batch of treated sludge before
it is disposed of, for as long as the facility is  in operation.
This plan  is referred to as the "contingency plan"  and is de-
scribed in more  detail below.

     In lieu of Approaches A or B,  please submit  the following
information:

     •  A description of your procedure for prescreening clients
        and wastes;

     •  Test results, on a representative number of samples  (but
        no fewer than eight)  taken  over a two-month period, for
        each of the following:

           The four hazardous waste characteristics.  For the EP
           toxicity test, use the extraction procedure for oily
           wastes in addition to the extraction procedure in
           Section 261.24 as  appropriate.

           Total concentrations of  the EP toxic metals and nickel.

           Appropriate leachate tests for the EP  toxic metals,
           nickel, and cyanide.

        -  Total organic carbon. *

           Total oil and grease.

           Long-term stability, using the Multiple Extraction
           Procedure  (see SW-846).   This tes't is  required only for
           stabilized wastes,  and only  four samples are required
           if these will be  representative.

           Cyanide:  total, free, and leachable.

           Appendix VIII constituents.  Test for  all constituents
           that  can reasonably be  expected to be present in the
           treatment  residue.  At a minimum, these  should include
           the 129 Priority Pollutants.
                             - 20 -

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•  The percentage of the total number of waste types received
   during the year  that are  represented  by  the wastes  sampled
   and tested for in this petition.

•  For those Appendix VIII constituents  for which you do not
   analyze,  your basis  for  not  analyzing  them (i.e., why it
   is reasonable that these  constituents are not expected to
   be present in the treatment residue at significant levels)

•  Your contingency plan for continuous  testing of the
   treated sludge.   The following tests  will be required for
   each batch of treatment residue that  is  disposed of:

      Appropriate leachate tests for the EP toxic metals,

      Representative organic toxicants as determined from the
      test results for Appendix VIII constituents, and

      General screening tests such as TOX and TOC.

   In addition,  composite samples must be tested periodically
   for the 129 Priority Pollutants.   Monthly composites  must
   be tested for base-neutral compounds, and biweekly compo-
   sites must be tested for  volatiles.  Contact the delisting
   staff of the  Waste Identification Branch for guidance in
   developing this plan.
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                      5.0  THE WASTE STREAM
     In this section,  you are asked to describe the waste stream
that you request be delisted and to give its hazardous waste
number.   The regulatory requirement for this information is found
in Section 260.22( i)(6).   You also  are  asked for  information on
how the waste is managed, and how it will be managed if your
petition is granted.  The material in this section corresponds to
Section C of the optional petition  form in  Appendix A.
5.1  Description of the Waste Stream


     The lists of regulated  wastes  are found  in Sections 261.31,
261.32,  and  261.33.  From those lists, please  furnish  the follow-
ing information regarding the waste that  is the subject of  your
petition:

     •  Its EPA'hazardous waste number.   If several wastes  are
        combined or mixed,  please provide the hazardous waste
        numbers for all listed wastes.
        •

     •  Its common name (e.g., electroplating  sludges, spent
        xylene, dissolved  air flotation  (DAF) float from the pet-
        roleum refining  industry).

     •  Its physical  form  (i.e.,  aqueous  stream,  sludge,  dry
        solid; for sludges, please  indicate the percentage  of
        solids).

From your operating records,  please estimate the following amounts;

     •  Average amount generated monthly

     •  Maximum amount generated monthly

     •  Average amount generated annually

     •  Maximum amount generated annually

Please state clearly the units of measurement.  Avoid using vague
units (such as "truckloads"  or  "barrels").

     •  Examples:  kilograms, pounds, English tons, metric tons,
                   gallons

In addition, please specify which of these descriptions applies to
the waste stream:
                             - 23 -

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     •  It is presently being generated.

     •  It will be generated in the future.

     •  It has been generated in the past and is presently being
        treated or stored on-site.
5.2  Description of Waste Management Methods


     Briefly describe how you treat or dispose of the waste at
present.  Include the following items:

     •  A paragraph describing the waste management techniques
        currently used (e.g., landfill, lime treatment, etc.)
        Please indicate whether the waste is managed on-site or
        off-site.

     •  A schematic flow diagram (if appropriate) of the waste
        treatment system, showing the processes, equipment, and
        storage methods used.

     •  The names and locations of any commercial treatment, stor-
        age, or disposal facilities that are used.

Describe, in a paragraph, the following as appropriate:

     •  How you treated or disposed of the waste before November
        19, 1980 (when EPA's Hazardous Waste Management System
        became effective), and

     •  How you will treat' or dispose of it if your delisting
        petition is granted.
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          6.0  SELECTING CONSTITUENTS  FOR WHICH  TO  TEST
     This chapter is intended  to  guide  you  in  determining  the
constituents for which you should test.   The actual  sampling and
testing procedures ar.e described  in the following chapters.  The
material in this chapter corresponds to Section D of the optional
petition form in Appendix A.
6.1  General Considerations
     As we have already stated in  previous  chapters,  the revised
delisting procedures suggest that  you submit either;


     1A. A complete listing of raw materials,  intermediate pro-
         ducts, by-products  and  final products, divided  into  three
         separate lists:

          •  all those materials  that are used or produced  in the
             processes at the  plant or facility generating the
             waste;

          •  of those materials identified  above,  those  that  are
             discharged  into or likely to be present in  the waste,
             as well as  the approximate quantities used  or pro-
             duced; and

          •  of those materials identified  above,  those  that  you
             do not believe are discharged  into or  likely to  be
             present in the waste, and the  basis  for  this belief
             (Approach A);

or

     B.  Representative analytical data  for all constituents
         listed in Appendix VIII of Part 261 that are likely  to be
         present in the waste  at significant levels,  as well  as
         your basis for not  analyzing  for the  other Appendix  VIII
         toxic constituents (Approach B).

     If you have elected to take Approach A, then you need to test
a representative number of samples of the waste for the  following:

     •  The specific hazardous constituents for which the waste
        was listed  (i.e.,  total  concentration  of each listed  con-
        stituent found in Appendix VII of Part 261);
                             - 25  -

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     •  The four hazardous waste characteristics;

     •  Appropriate leachate tests for the EP toxic metals,
        nickel, and cyanide;

     •  Total concentrations of the EP toxic metals and nickel;

    ,•  Total organic carbon (TOG);  and

     •  Total oil and grease.

After examining the data on raw materials, we may request further
analytical testing for those constituents that are  likely to be
present in the waste  at  levels of regulatory concern.   The rele-
vant test procedures are discussed in Chapter 8 of this manual.

     If you have chosen this option,  you may omit the  rest of this
chapter.

     If you have chosen Approach B, then  you should perform all of
the tests specified above — i.e., listed Appendix  VII  constit-
uents,  total oil and grease, TOG, and hazardous waste  characteris-
tics — on representative samples of  the  waste.   You must also
test representative samples for all Appendix VIII constituents
that may "reasonably  be  expected"  to  be present in  the  waste,
whether or not they were used as a basis  for listing.   In the
remainder of  this chapter,  we describe  engineering  analysis me-
thods that can assist you in determining  which constituents are
likely to be in the waste.

     Note that in selecting constituents for testing,  you must
specifically consider each item on the  list in Appendix  VIII of
Part 261,  and either  test for its presence or state why it is not
likely to be present.  This subject  is  discussed further in Sec-
t ion 6.3 be low.
6.2   Engineering  Analysis  to  Determine What  is  Likely to be
     Present in the Waste
     The list of likely hazardous constituents  usually can be
reduced to a reasonable  number  by  specifying  the  chemicals going.
into a process,  the products coming  out,  and  an understanding  of
the chemical and physical attributes of the process.   This type of
approach involves:

     •  A mass balance to allow calculation of the total amount
        of constituents in the wastes,  and

     •  An examination of the chemical  reactions occurring in  the
        process  to  identify' other  likely  constituents  in the waste
        stream.
                             - 26  -

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A mass balance for  the  process will  show what  raw materials  are
used, their use rates,  and whether they are likely  to  be  present
in the waste at significant  concentrations.  For example,  consider
a process involving the production of aniline by the reduction of
nitrobenzene.   Based on plant data,  for each 100 Ib of  nitroben-
zene used, 72 Ib of aniline is formed, which  indicates that 5 Ib
of nitrobenzene is  lost in the  process  per  100 Ib  used.   Further-
more, it is known that  2000 gal of wastewater  results  from the
production of each  72  Ib of  aniline.  Therefore, one can  estimate
that the maximum concentration  of nitrobenzene in  the  wastewater
is about 300 ppm, assuming that all  of the nitrobenzene is in the
wastewater.  Based  on this calculation, the generator would  likely
test the wastewater treatment sludge for  nitrobenzene.

     The area of by-products is  the  most difficult  to  consider,
because expert chemical judgment (supported by appropriate exam-
ples from the  literature)  must  be applied  to  predict the  types and
relative amounts of by-products expected  from a reaction.  Unfor-
tunately, demonstrating that a chemical reaction does not  actually
produce traces of hazardous  substances also can be  inconclusive.
For example, any reaction  involving  chlorinated phenols might
produce some chlorinated dibenzodioxins, which are  considered to
be hazardous at trace levels, although  it  is  not a  very probable
reaction in most circumstances.   In  such cases, you  should include
the substance  as a constituent for testing.

     The more detail  that  is provided by the  engineering  analysis,
the more likely our reviewers are to accept your judgment on which
constituents are likely to be present.  For example, if a  reactant
is described as "technical benzene," questions about the  presence
of toluene and other  aromatics  (and  their by-products)  in  the
waste stream may be raised.   On  the  other hand,  identification of
the reactant as "90% benzene, 9%  toluene, 1% xylenes and  less than
10 ppm sulfur" limits the likely composition of the waste stream.

     You may not wish to disclose some items of process informa-
tion, even under the protection of the confidential business
information (CBI) restrictions.   In  such cases, a greater  burden
is placed on the analytical  chemist  as discussed below.  Every
attempt should be made  to  exclude possibilities from consideration
even when the  process itself cannot be discussed.   For  example, if
none of the starting materials,  solvents, or catalysts  contain
halogens,  the  waste stream probably  does not contain halogenated
constituents.

     In some instances  —  for example,  chemical mixtures  used in
maintenance,  cleanup, and  other  non-process applications  —  it may
not be possible to  construct a  mass  balance.   In such  cases, you
should list the known constituents  in each mixture  and  estimate
the amounts disposed  of based on usage rates.
                             -  27  -

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6.3  Supporting Your Selection  of  Constituents


     In your petition,  you should describe how  you  selected  the
constituents for which  you will test.  In  addition, we shall
require you to give your basis  for not analyzing  any particular
constituent or group of constituents listed  in  Appendix VIII  of
Part 261.   You should state,  for each  hazardous waste  constituent
(or group  of constituents) for  which you do not test,  why you do
not believe it may "reasonably be expected to be  present in the
waste."  Substances  on  the list  that may be  found  in your  indus-
try°s wastes (although  not in your particular facility°s  wastes)
should be  addressed individually.   The remaining  constituents may
be addressed as,a group by stating that  your  facility  neither uses
nor produces any of the substances in  question, nor any chemicals
that could  form the  substances  in question.

     The mass balance approach  described above  can  be  quite useful
for eliminating or  identifying  those constituents that are present
or absent  from the waste.   If you  use  this approach, however,  you
should describe how  it  affected your choice of constituents.
                             - 28 -

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                 7.0  SAMPLING THE WASTE STREAM
     Your delisting petition must be supported by analytical data
for samples of the waste in question.  It is particularly im-
portant for you to demonstrate in the petition that the samples
are representative of the waste and that their integrity was
preserved until the required analyses were performed.  Specific
reporting procedures are described in Chapter 9 of this manual.
The specific regulatory requirement for this information may be
found in Section 260.22(h).

     Information to evaluate whether the collected samples are
representative of the waste is inadequate or totally lacking in
many delisting petitions.  A simple statement that the samples are
representative is not sufficient for the Agency to conclude that
the waste has, in fact, been adequately characterized.  In order
for us to make a finding of representativeness, you must provide a
detailed rationale as to why the samples that were collected do
represent the waste's composition as it varies in time and space.
This rationale should be based in part on considerations of how
the waste-generating process itself varies.

     This chapter of the manual summarizes the elements that must
be considered in the development of a good sampling program.   (A
detailed discussion of sampling methods may be found in EPA Publi-
cation SW-846.)  In the first section (7.1), the concept of repre-
sentative sampling is discussed, especially with respect to het-
erogeneous wastes.  Two basic strategies for obtaining represen-
tative samples of heterogeneous waste are described:  time compo-
site sampling and two-dimensional random sampling.  In Section
7.2, the most common sampling equipment is briefly described.  In
Section 7.3,  sampling techniques are described for process dis-
charges, drums, landfills, lagoons, and waste piles.  In each
case, specific techniques are presented for obtaining representa-
tive samples, and suitable equipment from Section 7.2 is suggest-
ed.  Section  7.4 discusses sample handling and storage, as well as
documentation of the sampling effort.  Finally, Section 7.5 de-
scribes how your sampling effort should be documented in the
petition.  The material in this manual corresponds to Section  E of
the optional  petition form in Appendix A.

     Sampling is a complex procedure and the representativeness of
the sample is critical to the acceptability of your petition.
Therefore, we strongly recommend that you contact the delisting
staff of the  Waste Identification Branch for guidance before you
actually draw the samples.
                             - 29 -

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7.1  Representative Sampling


     The waste to be sampled may be homogeneous,  or it may vary in
time or space.  The selection of a sampling strategy depends on
what type of variability the waste exhibits.


     Time Variability

     Time variability is most often encountered when point dis-
charges are sampled, such as flow from pipes.   Time composite
sampling usually is used in such cases.  In this method,  a number
of grab samples of equal volume are taken at regular time inter-
vals.  These intervals must adequately characterize the variations
in process flow over time.  The individual samples then are com-
bined into a series of composite samples,  which are analyzed for
the various constituents.

     You must collect and analyze enough composite samples to
characterize the variability of the waste stream over time.  The
frequency of collection and the number of samples to be taken from
a production process depend on the process and its operating
schedule, and on the schedule of variation of the waste composi-
tion, if that is known.  The greater the variability, the more
composite samples must be taken.  The volume of waste required
also must be determined beforehand, and usually is dictated by the
analyses to be performed and the homogeneity of the waste mate-
rial.  For example, a one-liter daily composite could consist of
five 200-ml samples taken at two-hour intervals throughout the
day; a weekly composite could consist of seven samples taken on
seven consecutive days and then combined.   The schedule for a
composite sample is process-dependent and should be decided upon
by someone who is familiar with the process and who understands
the need for a representative sample.


     Spatial Variability

     Spatial variability within a container,  pile, landfill, or
lagoon may be vertical or horizontal.  Contained wastes have a
much greater tendency to vary in a vertical rather than a hori-
zontal direction because of (1) the settling of solids and the
denser phases of liquids and (2) variations in the composition of
the waste as it entered the container.

     It is necessary to characterize the waste's variability in
both the horizontal and vertical dimensions.   This usually means
collecting a complete vertical sample of the waste at each of
several randomly selected points on a horizontal grid.  Appro-
priate methods for accomplishing this are described in Section
7.3.  The number of samples to be taken will vary with the size of
the containment area and the degree of spatial variability.  A
minimum of four samples should be drawn from each storage location


                             - 30 -

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or container, even if the waste appears to be homogeneous.  In
many cases, however, more than four samples will be required to
adequately characterize the waste.  (Drums form a partial excep-
tion to this rule, as described below; one sample per drum will
usually suffice.)


     An Example

     To illustrate the application of the above principles, we
consider the case of an electroplating line that generates sludge
continuously from rinsing operations (Waste No. F006).  Once every
six weeks, however, the plating baths themselves are dumped into
the waste stream.  The waste is held in a tank with a residence
time of about two days, and neutralized before being discharged to
a surface impoundment via a pipe.  The plating process used in the
plant was implemented two years ago, prior to which a different
process was used.

     First, let us assume that the delisting petition applies only
to the currently discharged waste stream.  On the basis of the
above information, the Agency would expect the generator to sample
the waste stream over at least a six-week period.  In particular,
samples should be taken during the two days in which the plating
baths themselves are resident in the sludge, to demonstrate the
variability of the neutralized sludge due to discharge of the
plating baths.

     If the petition includes the sludge stored in the surface
impoundment in addition to the current discharge, then the genera-
tor must take representative samples of the sludge in the impound-
ment as well.  Because the waste-generating process was changed
two years ago, there will most likely be vertical non-homogeneity
in the stored sludge.  Therefore, full-core samples of the im-
pounded sludge would be necessary.  In addition, it is likely that
horizontal variability will occur in the impoundment because the
sludge is discharged into it at a fixed point.  Therefore, samples
should be collected at randomly spaced points on a horizontal
grid.
7.2  Sampling Equipment


     This section contains a brief description of the most common
sampling devices:  dippers, weighted bottles, COLIWASAs, thiefs,
triers, and augers.  Detailed descriptions and directions for
obtaining or constructing the equipment can be found in EPA Publi-
cation No. SW-846, "Test Methods for Evaluating Solid Waste,"
second edition.
                             - 31 -

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     Dipper

     A dipper consists of a glass or nonreactive plastic beaker
clamped to the end of a pole,  which serves as the handle (see
Figure 7.1).  It is used to sample flowing liquids and slurries.
The dipper can be varied in size depending on the flow rate of the
waste stream.
     Weighted Bottle

     This sampling device consists of a glass or nonreactive
plastic bottle with an attached sinker or weight, stopper, and a
line which is .used to lower,  raise, and open the bottle.  It is
used to sample liquids and slurries.  Figure 7.2 depicts a weight-
ed bottle sampler.
     COLIWASA

     A COLIWASA (composite ^Liquid waste s_ampler)  is a glass,
plastic, or metal tube with an end closure that can be opened and
closed while the tube is submerged (see Figure 7.3).  This sam-
pling device is useful for free-flowing liquids and slurries
contained in drums,  shallow open-top tanks,  pits,  and similar
containers.  It is especially useful for sampling wastes that
consist of several immiscible liquid phases.  The COLIWASA is
lowered into the waste at a rate slow enough to permit the level
of liquid inside and outside the sampler to remain the same.  When
the sampler hits the bottom, the stopper is closed.  In this
manner, a sample is obtained that is representative of the entire
depth of the waste.


     Thief

     A thief consists of two slotted concentric tubes usually made
of stainless steel or brass (see Figure 7.4).  The outer tube has
a conical pointed top- which permits the sampler to penetrate the
material being sampled.  The inner tube is rotated to open and
close the sampler.  A thief is used to sample dry granules or
powdered wastes whose particle diameter is less than one-third the
width of the slots.  A thief is available at laboratory supply
stores.

     Trier

     A trier consists of a tube cut in half lengthwise with a
sharpened tip that allows the sampler to cut into sticky solids
and loose soil (see Figure 7.5).  The trier is then rotated to cut
a core of the waste.  A trier samples moist or sticky solids
having a particle diameter less than one-half the diameter of the
trier.  Triers can be found at laboratory supply stores, or they
can be fabricated.
                             - 32 -

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                    FIGURE  7.1:   DIPPER  SAMPLER

(Source:   Test Methods for  Evaluating  Solid Wastes,  2nd Edition,
                    U.S. EPA,  SW-846, July 1982)
              Varigrip Clamp
                               Telescoping Aluminum Pole
                               2.S to 4.5 Meters (8 to IS ft.)
   Beaker
 150lo600ml
                                -  33  -

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              FIGURE 7.2:  WEIGHTED BOTTLE  SAMPLER

(Source:  Test Methods' for Evaluating Solid Wastes,  2nd Edition,
                  U.S. EPA, SW-846, July  1982)
                                             Washer

                                              Nut
                             -  34 -

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           FIGURE 7.3:   COMPOSITE LIQUID  WASTE SAMPLER

(Source:   Test Methods for Evaluating Solid Wastes,  2nd Edition,
                    U.S. EPA,  SW-846, July 1982)
                                                  2.86cm (1 1/8")
c





Tapered v
Stopper 1
f
II
II
II
II
II
1
I 1
1!
II
II
II
1 1
II
II
II
II
II
II
II
II
ii
II
II
II
II
II
II
II
II
II
II
35
13





i
T-Handle fr
6.35 cm (2 Vt Locking 	 J
Slock H
1
1
1
1
1
I
1
1
1
1
1
1
1.52m (S'-O") 1
1
1
I
1
1
1
1
1
|
~y _, 1
1
1
1
1
r |
IT
IT
17.8 em (7")
4,
1
| Stopper Rod. PVC
0.95cm (3/8") 0. D.
I
1
1 Pipe, PVC. 4.13 cm (1 5/8") I D.
I ^ 4.26cm (1 7/8") 0. D.
I
I
I
I
I
I
I
I
I
I
I
I
I

J ., Stopper, Neoprene. No. 9 with
-1 ' 3/8" S. S. or PVC Nut and Watfier
           SAMPLING POSITION
                                          CLOSE POSITION
                               -  35 -

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                   FIGURE 7.4:   THIEF SAMPLER

(Source:  Test Methods for Evaluating Solid Wastes, 2nd Edition,
                  U.S. EPA,  SW-846,  July 1982)
                    60-100 cm
                                V
                             1.27-2.54 cm
                               36 -

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FIGURE 7.5:   SAMPLING  TRIERS
(Source:  Test Methods  for Evaluating  Solid Wastes
                   U.S.  EPA,  SW-846, July 1982)
                                     2nd Edition,

-^ ,___.. 122-183 cm _. 	
(48-72")
^\



T
                                   5.08-7.32 cm
            60— 100cm
                 \
                   \
                   1.27-2.54 cm
           - 37 -

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     An auger consists of sharpened spiral blades attached to a
•hard metal central shaft.  Augers sample hard or packed solid
wastes or soil.  They are available at hardware stores or labora-
tory supply stores.
7.3  Sampling Techniques for Specific Forms of Waste


     In this section, sampling techniques are presented for va-
rious sampling situations:  sampling from pipes and other process
discharges; drums; landfills; lagoons; and waste piles.  We also
describe an approach for taking samples at multiple waste treat-
ment facilities.

     •The variety of physical forms of waste and the uniqueness of
each sampling situation necessitates a flexible approach to ac-
quiring samples.  The procedures discussed here are believed to
represent the best approaches to sampling different forms of
waste; however, the technique that you select should be devised in
each case by a person familiar with the process and with general
principles of sampling.


     Pipes and Other Process Discharges

     Representative samples from pipes and other process dis-
charges are best obtained through time composite sampling, which
was described in section 7.1 of this chapter.  Composite sampling
may be performed through the use of automatic compositers, or it
may be done manually.  This discussion assumes that manual sam-
pling is performed.

     There are two general types of process discharges:  liquid or
slurry discharges, and solid or semi-solid discharges.  Liquids or
slurries generally will be sampled from pipes, valves, or sluice-
ways.  Solid process discharges are often sampled  from conveyor
belts or filter presses.

     For slurry and liquid discharges, a dipper-type sampler
should be used.  The dipper can be easily constructed out of
materials on hand at the plant.  The dipper bucket should be of an
appropriate non-reactive material, similar to the  sample contain-
ers.  The size of the bucket used should increase with increasing
stream flow rate.  A dipper should be used to sample only one
waste stream and it should be cleaned aftuer each sample is
collected.

     Each time a grab sample is taken, the dipper  is first rinsed
in the sampled stream.  Then the dipper is passed  in one sweeping
motion through the discharge stream so that the dipper is filled


                             - 38 -

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in one pass.  Do not sample from the edge of the stream only. , If
the cross-sectional area of the stream is large in comparison with
the size of the dipper, more than one pass may be necessary to
sweep the entire cross-sectional area of the stream.  Each grab
sample should be emptied into the composite container and the
entire contents mixed well.

     Solid or semi-solid discharges on a belt should be sampled
with a scoop or a shovel.  The shovel should be chosen or fabri-
cated to match the width and general contour of the belt as close-
ly as possible.  The grab samples can be taken at any convenient
point along the belt, as long as the entire width of the belt is
sampled.  Any fines or liquid present on the belt at the sampling
point should be included in the sample.

     Another common type of solid discharge is filter cake.  If
samples are taken as the material is produced, then a trowel or
shovel may be useful, depending on the type of filter.  Care
should be taken so that the entire waste stream is represented by
the sample

     In each case, the frequency of sampling and the number of
individual grab samples that are combined to form a composite
depends on the variability of the waste over time and on the time
span which the sample is to represent.  For sampling point dis-
charges as they are generated, samples can be taken every hour for
eight to 24 hours, depending on the process schedule, and combined
to form a daily composite.  As an alternative, samples can be
taken daily for a week, and the daily samples combined into a
weekly composite.  Again, the sampling period and number of sam-
ples will vary for each petitioner.  Therefore, it is important
that whoever takes the sample be familiar with the spatial and
temporal variability of the waste stream.

     Often solid discharges, such as filter cakes, fall from the
press or plate-and-frame filter into a hopper or storage area.
In this case, a more long-term composite may be obtained by samp-
ling the material after it has accumulated for a period of time.
For example, filter cake can be allowed to accumulate in a hopper
for 24 hours, and then random core samples can be taken using a
simple two-dimensional random sampling strategy.  (If separation
of the waste — such as by the expression of liquids — appears to
have occurred in the storage container, mix the waste well before
drawing the samples.)  The samples would be combined to form a 24-
hour composite.  The process would be repeated enough times to
obtain the number of samples required for analysis.  Sampling
filter cake from a hopper would require the use of a thief or a
trier, depending on the water content of the material.  In each
case, the composite should be mixed until it is homogeneous before
sub-samples are split for analysis.
                             - 39 -

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     Drums

     If the waste is contained in drums, then ideally each drum
should be sampled.  If there are too many drums for this to be
practical, then a representative number of individual drums must
be randomly selected.  This is easily done by assigning a number
to each drum consecutively and then using a random number table to
choose the sample.  A detailed method for selecting drums for
sampling may be found in the following publication:

     "Waste Analysis Plans:  A Guidance Manual,"  U.S. EPA Office
     of Solid Waste, Publication EPA/530-SW-84-012, October 1984.

     For each drum,  a single sample that samples the entire depth
of the drum along its axis is sufficient.  Equipment used for sam-
pling waste in drums includes weighted bottles (for heterogeneous
wastes), COLIWASAs,  thiefs, and triers.  COLIWASAs and weighted
bottles are best suited to sampling liquids and slurries; if the
sample is dry granules or a powder, a drum thief should be used.
A trier should be used to sample moist or sticky solids.


     Landfills

     Wastes contained in landfills are primarily solids or moist
solids.  These wastes are best sampled using a two-dimensional
random sampling strategy as described below.  (The procedure is
also illustrated in Figure 7.6).

     (1)  On a dia.gram, divide the landfill to be sampled into
          sections of equal area.  If the area is under 40,000
          square feet, then it should be divided into four equal
          quadrants.  If the area is over 40,000 square feet, then
          it should be divided into equal sections of not more
          than 10,000 square feet each.

     (2)  Divide each quadrant or section into an imaginary 10x10
          grid to get 100 squares (or rectangles) of equal size.
          Number the grid lines in each dimension from 1  to 9.

     (3)  For each section, determine the number of sampling
          points necessary to characterize the waste.  This number
          will depend on the degree of spatial variability within
          the landfill.

     (4)  Select a two-digit number using a random number table.
          Repeat this procedure until you have one two-digit num-
          ber for each sampling point in the section.  (Random
          number tables are available in any introductory statis-
          tics text or handbook.  Their use is explained in.Appen-
          dix G. )

     (5)  Locate the grid intersections whose coordinates corres-
          pond to each of the two-digit random numbers.  These
                             - 40 -

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FIGURE 7.6: SCHEMATIC  DIAGRAM  OF SAMPLING GRID  FOR A LANDFILL
   The Figure  shows a  30,000  sq ft landfill  (150 ft x  200 ft)
            divided into four  7,500 sq  ft quadrants.
 i


 2


 3


 4


 S


 6


 7


 8


 9
               Quadrant 1
Sampling point (corresponds
 to randoa nuaber 82)
                                              Quadrant 2
                                 Quadrant 4
      I   Z
                              -  41 -

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          intersections are the locations of the randomly selected
          sampling points.

     (6)  Sample each selected grid point vertically along the
          entire distance from the top to the bottom of the land-
          fill.

     (7)  Combine the samples for each section and mix them well
          to form a homogeneous composite sample.  Do not, how-
          ever, combine samples from different sections.

For example, a landfill of 10,000 square feet would be divided
into four quadrants of 2,500 square feet each.  In each quadrant,
a sufficient number of core samples would be taken and combined.
The result would be four homogeneous composite samples, one from
each quadrant.  Similarly, a landfill of 60,000 square feet would
be divided into six sections of 10,000 square feet each, yielding
six homogeneous composite samples.

     It is particularly important to obtain vertical samples along
the entire depth, including the bottom.  Hollow-stem augers com-
bined with split-spoon samplers are frequently useful for sampling
landfills.  Triers or modified triers also may be used.


     Lagoons

     Lagoons are similar to landfills in that they cover a large
area and stratification and settling are likely to occur.  The
same two-dimensional randomized sampling strategy therefore may be
used.  Again, it is important that each sample include material
from the entire depth of the lagoon, including the bottom.*  This
can be done by using a COLIWASA.


     Waste Piles

     Ideally, waste piles should be divided into quadrants (in a
similar fashion to landfills), and each quadrant sampled using a
two-dimensional grid and random vertical core samples.  Equipment
commonly used to sample piles includes thiefs, triers, and shovels.


     Multiple Waste Treatment Facilities

     The variety and number of incoming wastes accepted at mul-
tiple waste treatment facilities (MWTFs) result in less control
over the variability of constituent concentrations.  Since  -
inherent variability makes it difficult to collect representative
     *Note that if the listed waste is a sludge (e.g., Waste No,
F006), the liquid above the sludge, if any, need not be sampled.
                             - 42 -

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samples, the MWTF petitioner has  fewer  options available to demon-
strate the non-hazardousness of his waste.   To obtain  representa-
tive samples, the following guidelines are suggested:

     •  Analyze as many samples as necessary to  represent  varia-
        bility in toxicant concentrations in the treatment residue
        generated annually.   (The Agency  believes that a minimum
        of eight weekly composite samples should be collected over
        a minimum period of two  months.)

     •  Determine what percentage of waste treated annually is
        treated during the sampling period.

     •  Explain why the remaining percentage of  the  waste would not
        be expected to contain any hazardous constituents;  dif-
        ferent levels of these constituents; or  different charac-
        teristics than the waste  sampled.
7.4  Sample Handling, Storage, and Documentation
     Samples collected must be handled,  labeled, and stored so
that sample integrity is preserved.  In addition,  proper documen-
tation of sample collection, preservation, and custody is essen-
tial.
     Handling and Storage

     Containers.  Samples should be collected and composited in
glass, polytetrafluoroethylene  (PTFE), or plastic containers with
tight, screw-type lids.  PTFE lid liners should be used if organic
analyses are to be performed on the sample.  Containers made of
plastic other than PTFE should  not be used if organic analyses are
to be performed.

     On-Site Preservation.  Once a sample has been collected,
steps must be taken  to  preserve  the physical  and  chemical integri-
ty of the sample during transport and analysis.   Sample preserva-
tion and storage requirements  vary according  to  the analysis to be
performed.  Therefore,  it may be necessary to prepare more than
one container of the waste material to accommodate the different
analyses.  Again,  refer to EPA Publication SW-846 for detailed
preservation procedures.

     Identification and Labeling.  Each  container should be as-
signed a unique  sample  identification number.  An  indelible label
should be secured to the container that  identifies the sample.
The label should contain the following information:
                             - 43 -

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               Sample identification number
               Name of collector
               Date and time of collection
               Place of collection

The label should be filled out after the container is filled to
avoid spilling the sample onto the label.  Finally, the label
should be completely covered with wide cellophane tape to ensure
that the labels remain attached and dry throughout shipping and
analysis.

     Shipping.  After the samples have been preserved, labeled,
and sealed,  they are ready for shipping.  Samples should be ship-
ped and analyzed as rapidly as possible to ensure that the most
accurate and reliable data can be obtained.

     There are four areas of concern:  1) protection of carriers
and receivers, 2) preservation of samples, 3) rapid and efficient
transit, and 4) compliance with DOT regulations.

     Specific DOT requirements for the packaging of hazardous
environmental laboratory samples can be found in 49 CFR 173.24 and
173.6.  In general, these requirements state that hazardous sam-
ples must be packaged in such a way that under normal conditions
of transportation, no significant release of hazardous materials
to the environment will occur due to breakage, leakage, or reac-
tion with packing materials.

     The following recommendations are patterned after EPA-recom-
mended procedures which are designed to comply with DOT regula-
tions.

     •  Shipping containers must be designed such that they will
        withstand a four-foot drop on solid concrete in the posi-
        tion most likely to cause damage.  A good example is a
        metal clad cooler lined with plastic.  The container
        should be taped shut and the drain plug at the bottom
        secured to prevent leakage.  The container should be
        marked "THIS END UP" in proper position.

     •  Glass containers must be packed in a shipping container in
        a manner that minimizes the possibility of breakage or
        leakage.  Screw-type lids should be securely tightened.
        Large glass bottles should be separated by cushioning
        material.  Containers should be sealed in plastic bags or
        packed in absorbent material in case breakage does occur.

     •  Plastic- containers, though not requiring packaging to
        prevent breakage, are packed with a cushioning material to
        prevent leakage by puncture.  Screw-type lids should be
        tightened securely.

     •  If the sample is to be analyzed for volatile organics, it
        should be packed in a cooler and maintained at 4°C.
                             - 44 -

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     Documentation

     In addition to labels and seals,  there are three types of
documentation necessary to ensure the integrity of the sample:  a
chain-of-custody record, a field log book,  and a sample analysis
request sheet.

     A chain-of-custody record should be filled out and should
accompany every sample.  The record should contain the following
information:  sample identification number, signature of collect-
or, date and time of collection, place and address of collection,
and waste type.  A place also should be provided for the signature
of each person who has the samples in their possession, along with
the inclusive.dates of possession.

     In addition, all information pertinent to a field survey or
sampling must be recorded in a log book.  Entries in the log book
should include the following items:

          Date and time of sampling

          Collector's name and affiliation

          Process sampled

          Type of waste (e.g., sludge, wastewater)

          Exact location of all sampling points (drawings
               may be helpful)

          Description of sampling methodology

          Number, volume, and appearance of samples

          Any field measurements made

          Field observations

Any deviations from the sample plan or any problems should be
noted.  In general, sufficient information should be recorded so
that the sampling can be entirely reconstructed without reliance
on the collector's memory.

     Finally, a sample analysis request sheet should accompany the
sample to the laboratory.  The sheet should specify the following
items:
               Sample identification number

               Description of sample

               Date

               Analyses to be performed

               On-site preservation


                             - 45 -

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     You should preserve all chain-of-custody documents, log
books, and similar records in case a question arises regarding the
sampling portion of your petition.
7.5  The Written Sampling Plan


     A written sampling plan should be prepared for even the
simplest sampling efforts.   This will ensure that proper planning
has taken place and that planned procedures are followed.  The
sampling plan .also will serve as the basis for demonstrating the
representativeness of your samples in the petition.  A good sam-
pling plan should contain the following information:

     •  Purpose of the sampling effort

     •  List of the waste stream or streams to be sampled

     •  Name of the sampler (or sampling crew for larger efforts)

     •  Professional qualifications of the samplers

     •  Sampling strategy,  e.g., time composite

     •  Detailed sampling procedures, including location of sam-
        pling points,  equipment needed,  and sample containers

     •  Safety procedures,  including safety equipment

     •  Any on-site preservation that will be performed

     •  Analytical lab to be used and method of transport

     •  Analyses to be performed

     •  Plans for documentation of the sampling effort


Instructions for reporting  your sampling procedures are given in
Section 9 below.
                             - 46 -

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             8.0  SELECTION OF WASTE ANALYSIS METHODS
     In this section,  we describe briefly the methods to be used
to analyze the waste for the hazardous characteristics and con-
stituents.  The methods themselves are complex and require fairly
elaborate laboratory facilities.  Most of the methods specified
for these tests may be found in the following EPA Publication:

     "Test Methods for Evaluating Solid Waste:  Physical/Chemical
     Methods," and its supplements and revisions, SW-846 (second
     edition), June 1982.  Referred to here as "SW-S46".

Additional methods ara contained in Appendix J of this Manual.

     The design and execution of the testing program should be
done by an analytical chemist with the proper qualifications.  If
you do not have the necessary personnel or laboratory resources
in-house, you should contract with a commercial testing laboratory
or a consulting analytical chemist with experience in hazardous
waste.  A list of typical 1984 prices for the tests described in
this section is included in Appendix H.
8.1  Tests for Characteristics


     You must determine whether the waste exhibits one of the four
characteristics (ignitability, corrosivity,  reactivity, and EP
toxicity).  This determination may take the form of an explanation
of why the waste cannot exhibit one or more of the characteris-
tics.  (For example, a waste stream composed entirely of organic
solvents would not contain any of the EP toxicants listed in
Section 261.24.)  If you cannot explain conclusively a character-
istic's absence, you must test for it instead.  If you test for a
characteristic, any analyses must be performed on as many samples
as are necessary to be representative of the waste (see Chapter 7
above), but on no fewer than four samples.

     1.  Ignitability.  (See Section 261.21)  This characteristic
identifies wastes that either present fire hazards under routine
storage, disposal, and transportation or are capable of severely
exacerbating a fire once it is started.  Ignitability for a liquid
is defined in terms of its flash point.  For a non-liquid, it is
the ability to cause fire through friction,  absorption, moisture,
or spontaneous chemical change.  The most common test for ignita-
ble liquids, the Pensky-Martens Closed-Cup method, involves heat-
ing a sample slowly and determining the minimum temperature at
which a small flame ignites the vapor above the sample (see SW-
                             - 47 -

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346).   The  ignitability characteristic for  non-liquids is a de-
scriptive standard, and does not specify a test procedure.

     2.  Corrosivity.   (See Section 261.22}   This  characteristic
identifies  wastes which might  pose  a hazard  to  human health or the
environment due to their ability to:

     •  Mobilize toxic metals;

     •  Corrode handling, storage,  transportation, and management
        equipment; or

     •  Destroy human or animal tissue in the event of inadvertent
        contact.

A waste is defined as corrosive if: (a) it is aqueous and has a pH
of less than or equal  to 2 or greater  than or equal  to 12.5, or
(b)  it is a liquid and corrodes a  specific  grade of steel at a
rate greater than 6.35 mm per  year  under  standardized test con-
ditions.  Test methods  are given in SW-346.

     3.  Reactivity.    (See  Section 261.23)   This characteristic
identifies  wastes which, because of their extreme  instability and
tendency to react violently or to explode,  pose  problems  at all
stages of the waste management process.  In particular,  such
wastes have any of the following properties:

     •  They readily undergo violent chemical change;

     •  They react violently OT form potentially explosive
        mixtures with water;

     •>  They generate  toxic fumes  when mixed with  water or, in the
        case of cyanide or  sulfide-bearing wastes, when exposed
        to acidic or basic  conditions;

     •  They explode when subjected to a strong initiating force;

     •  They explode at normal temperatures and pressures; or

     •  They fit within the Department of Transportation^
        forbidden explosives classifications.

     Several methods for testing for reactivity are available,
although none are comprehensive.  The  Defense Logistics Agency°s
Explosives Hazard Classification Procedures  (DLAR  8220.1) pre-
scribe a blasting-cap  test  (see Appendix J).  Methods 9010 and
9030 in SW-846 measure cyanide and sulfides, respectively.  In
addition,  a gas-generation test for reactive cyanide and sulfides
in waste is contained  in Appendix  J, as is a test for photo-
degradable cyanide.  Descriptions  of reactive wastes may be found
in SW-846.   In general, if  you are  dealing  with  an explosive
waste, please contact  EPA°s Waste  Identification  Branch  at (202)
475-8551 for further guidance on test  methods.
                             - 48 -

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     4.   Extraction Procedure (EP)  Toxicity.   (See Section 261.24)
The Extraction Procedure  is designed  to simulate  the  leaching  that
a waste will undergo if it is disposed of  in a sanitary landfill.
In a laboratory,  a representative sample  of a waste is extracted
with deionized water maintained at a pH of 5 using acetic acid.
The extract obtained from the procedure (the "EP extract")  is
analyzed to determine if any of the thresholds for the eight
metals, four pesticides,  and  two herbicides specified in the
regulations have  been exceeded.*  At least one EP toxicity test
for each EP metal should be run  using the method  of standard
additions.   Spike and  recovery  concentrations and recovery effi-
ciency should be  reported.
8.2  Tests for Constituents


     In addition to testing for the characteristics as described
above, the following tests should be conducted as appropriate for
the waste stream.

      •  If cyanide was a constituent for which the waste was
         listed, or if it is expected to be present in the waste,
         analyze for total cyanide  (see SW-846).   If the  total
         concentration recorded is greater than 1 ppm, test for
         free cyanide  (see SW-846).   If the concentration of  total
         cyanide is greater than 10 ppm,  perform  the photoconver-
         sion test for photodegradable cyanide (see Appendix  J).

      •  If the cyanide analysis indicates the presence of an
         interference  in the waste that produces  non-representa-
         tive concentrations, note and explain the  interference.
         In addition,  perform the following  test  (see Appendix J):

             "Test Method for the Determination of Reactive Cya-
             nide and  Sulfide Containing Wastes,  Final Method".

      •  Perform a total constituent analysis by  complete acid
         digestion for all the EP metals and nickel (if nickel is
         a constituent for which the waste was listed).   See  SW-
         846 for a description of the method.

      •  Perform the Total Oil and Grease analysis to determine
         the percent of total mass that is oil and  grease.  The
     *Note that if the total constituent analysis described below
shows that one or more of the EP metals is not present or is
present at concentrations of less than regulatory concern,  then
you may not have to test for those metals  in  the SP Toxicity Test.
Contact the Waste Identification Branch for guidance on specific
cases.
                             - 49 -

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         method  involves drying the waste and  then  extracting  the
         constituent oil  and grease with an organic solvent such
         as freon.

      •  If the  Total  Oil and  Grease  analysis  shows that the total
         oil and grease  content of  the  waste is  1 percent  or more,
         the EP  Toxicity Test  for Oily Wastes  should be used (see
         Appendix J).

      •  Analyze,for  Total Organic Carbon (see Appendix J).  In
         this test, organic carbon  is converted  to carbon  dioxide
         by analytic  combustion or  wet  chemical oxidation. The
         COo formed can  be measured or  converted to methane  (CH4)
         and measured.   The amount  of C02 or CH^ is directly
         proportional  to the concentration of  carbonaceous mater-
         ial in the  sample.

      •  Identify and  quantify individual organic constituents.
         This must usually be  done  using  gas chromatography-mass
         spectrometry  (GC-MS)  methods.  Applicable  methods are
         contained  in  SW-846.

     If chromium,  cyanide, and nickel are  listed constituents,
tests for them may be  combined with the EP toxicity test.  For the
first two compounds, the  following  special procedures apply:

     •   Analyze the EP.extract for total chromium and hexavalent
         chromium separately.   Report initial  and  final pH data on
         the hexavalent  chromium EP analysis.   If  the pH drops
         from an alkaline or neutral  value to  ah acidic pH, then
         alkaline digestion  of the  waste  is required  before ana-
         lyzing for  hexavalent chromium (Method 3060 in SW-846).

     •   Test for extractable  cyanide using the EP  procedure,
         using distilled water only (instead  of acetic acid) as
         the extract  medium.
                             - 50 -

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               9.0  PRESENTATION OF ANALYTICAL DATA
     The data from the analytical tests should be presented in a
format that supports your contention that the waste:

     a. Does not exhibit any of the hazardous waste characteris-
        tics, and

     b. Is not hazardous based on the constituents for which it
        was listed.

In addition, you must provide the necessary information on other
hazardous constituents so that the Agency can determine whether
the waste may reasonably be hazardous for any other reason.  We
also request data on other topics such as quality control proce-
dure.  This chapter corresponds to Part S of the optional petition
form in Appendix A.
9 .1  General Information


     Please provide the names and addresses of the consultants or
laboratory•facilities that

     (a) sampled the waste, and

     (b) tested the samples.

If sampling or testing were performed using in-house staff and
equipment, indicate that fact.  In addition, please provide the
names and qualifications of the persons who designed the sampling
plan, drew samples, designed the test plan and performed the
analytical tests (Section 260.22(i)(l) and (2)).
9.2  Sampling Information


     Demonstrating that the waste samples are representative is a
particularly important requirement of the delisting process.  Many
of the petitions we receive are deficient in this area.  There-
fore, please submit:

     •  A detailed description of your sampling strategy.  The
        description should state why you believe the samples
        tested are representative of the waste stream,  including
        any variations in the waste's properties over time and


                             - 51 -

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        space.  In the case of process buttlows, state whether all
        major equipment items, raw materials,  and operating condi-
        tions are represented.  In the oUsJ) of storage locations,
        describe how sampling points werV^elected and how samples
        were drawn.  Note that each outflow and storage loca-
        tion included in this petition must be sampled in a rep-
        resentative manner.

     •  A description of the documentation system used to track
        the samples;  or, a statement that the Chain-of-Custody
        system specified in Section 1.3 of' SW-846 was used.


     In addition,  please furnish the following information for
each sample:

     •  The sample number,  as it appears in your logbook or other
        record.

     •  The location where the sample was taken.  Specify the
        general location (e.g.,  the outflow, lagoon, pile, etc.)
        and the specific point of sampling (e.g., quadrant and
        depth in a lagoon).  Include a diagram.

     •  The equipment used for drawing the sample (Section
        260.22(i)(8)).

     •  The date on which it was drawn (Section 260.22(i)(3)).

     •  The time of day when it was drawn.

     •  The handling and preparation techniques used, including
        techniques for  extraction, containerization, and preserva-
        tion (Section 260.'22(i) (9) ) .
9.3  Test Results


     For each test performed on each sample,  please report the
following information:

     •  The hazard being tested for;

     •  The specific substance or parameter being tested for;

     •  The date the test was performed (Section 260.22(i)(3));

     •  The test method used (Section 260.22(i)(10));

     •  The source of the test method used.  Sources  for methods
        are:
                             - 52 -

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        - "Test Methods for Evaluating Solid Waste:   Physical/
          Chemical Methods," and its supplements and revisions,
          SW-846 (second edition),  June,  1982,  and

        - Appendix J of this manual.

     •  The sample workup or preparation method.

     •  The names and model numbers of all equipment used in the
        tests (Section 260.22(i)(11)).

     •  The test results, expressing concentrations  in common
        units such as mg/1, ppm, etc.  (Section 260.22(i)(10)).

     •  Quality control procedures.

     •  Any supplementary information needed to interpret the
        test procedures or results.

Append a discussion explaining any inconsistencies or deviations
among the analytical results presented.
9.4  Quality Assurance and Quality Control


     It is important to report the methods taken to insure the
quality of the sampling and testing procedure, so that our review-
ers will know how much confidence to place in the results.  In the
case of inorganic substances, Standards Addition Analysis can be
used for this purpose.  In this method, a sample of the waste is
"spiked" with a known concentration of the substance in question
prior to being analyzed.  'The spike concentration should be ap-
proximately the same as the anticipated level of the constituent
in the waste.  If the concentration of the constituent is below
the detection limit, then the spike concentration should be be-
tween three and ten times the detection limit.  At least one test
should be run for each substance.  You should report:

     •  The spike concentration,

     •  The recovery concentration, and

     •  The recovery efficiency.

     In the case of organic constituents, you should spike the
sample with the substance of interest if possible.  It may be
necessary, however, to use a surrogate substance.  This may be the
case because a standard is not otherwise available, or because of
interferences from other substances in the waste.  Surrogates
should be chosen on the basis of similar chemical structure to the
substance of interest; similarity of physical properties such as
boiling and melting points may also be considered.  The spike
concentration for the substance or its surrogate should be as


                             - 53 -

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described above.  Methods for calibrating the gas chromatography
apparatus when using internal or external standards are described
in SW-846 (see, for example,  Section 7.2 of Method 8020).

     When reporting the results of the spike analysis for or-
ganics,  give the spike concentration,  recovery concentration, and
recovery efficiency as specified above.  In addition, please spe-
cify which substance, if any, was used as a surrogate for the
compound of interest, and provide details of the method used to
calibrate the analytical equipment.

     Describe any other quality control measures taken as well.
                             - 54 -

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             APPENDIX A




OPTIONAL FORM FOR DELISTING  PETITIONS

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           OPTIONAL FORM:




DELISTING PETITION FOR WASTE STREAM
           Submitted by:
               Date:
               A-3

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                           INSTRUCTIONS
1.  This form is meant to assist you in submitting a petition to
    delist a RCRA hazardous waste under the provisions of Section
    260.22  of  the hazardous waste  regulations.   Its  use is option-
    al.   Any part of the form may be changed or adapted to your
    circumstance,  provided that all information submitted is
    clear,  complete, and conforms to the regulatory requirements.

2.  Instructions for completing this petition form are contained
    in the document entitled, "Petitions to Delist Hazardous
    Wastes:  A Guidance Manual," EPA/530-SW-85-003,  April 1935.
    The manual is available  from the National Technical Informa-
    tion Service.   Please review the manual thoroughly before
    attempting to develop your petition.  Should you need further
    assistance,  it may be obtained by calling the  Environmental
    Protection Agency's RCRA Hotline,  at (800) 424-9346 (in the
    Washington,  D.C. area, 382-3000).

3.  Certain types of facilities, such as petroleum refineries and
    multiple waste treatment facilities, are required to submit
    information in addition to or in lieu of the information
    specified in this form.   Petitioners for such  facilities
    should refer to Section 4.3 of the  Guidance Manual and adapt
    this form as appropriate.

4.  Items that you are required to submit are designated by refer-
    ences to the appropriate parts of the hazardous waste regula-
    tions .

5.  If insufficient space is provided for your answers, attach
    extra sheets as necessary.

6.  Please submit completed petitions to:

               The Administrator
               US Environmental Protection Agency
               401 M Street SW
               Washington, D.C.  20460

    In addition, send a copy to:

               Chief, Waste Identification Branch
               Office of Solid Waste (WH-562B)
               US Environmental Protection Agency
               401 M Street, SW
               Washington, D.C.  20460
                              A-5

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7.  Please be sure to provide the following items,  which are often
    omitted.   Their omission will delay the review process and may
    cause extra work for you and for EPA.

          RCRA ID Numbers
          Facility contact(s) and telephone numbers
          Material safety data sheets,  where requested
          Waste generation quantities
          Signed certification statement
          Statement of sample representativeness
          Statement of waste's ignitibility/reactivity/corrosivity
                              A-6

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           SECTION A:   Administrative Data and Summary
1.  Name [260.20(b)(1)]

       a.   Name of firm:
       b.   Address of firm:   Street:

                             City:
                             State:    	 Zip:

       c.   RCRA Generator ID number:   	
2.  Facility Location [260.20(b)(1)]

       a.  Name of facility:   	
       b.  Location of facility:  Street:

                                  City:
                                  State:           Zip:
3.  Name(s) of personnel to be contacted for additional informa-
    tion pertaining to this petition:

          Name                  Title                  Telephone
                              A-7

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4.  Description and Justification  for the Proposed Action

    Please describe briefly the proposed delisting action, why it
    is needed,  and how  it will  affect your  operation.  Describe
    why you believe that the waste stream of  concern  (a) is not
    hazardous for the reasons it was originally  listed and  (b)
    contains no other constituents or characteristics that render
    it hazardous as defined in 40 CFR 261.  [ 260.20(b) (2), (3) and
    (4)]
5.   Certification of Accuracy and Responsibility  [260.22(i) (12)]


    I certify under penalty of law that I have personally examined
    and am familiar with the information submitted in this demon-
    stration  and all attached  documents,  and that based  on my
    inquiry of those individuals  immediately  responsible  for ob-
    taining the  information, I believe that the submitted informa-
    tion is true, accurate, and complete.   I  am aware  that  there
    are significant penalties for submitting false information,
    including the possibility of  fine  and  imprisonment.


                                        Signed,>
                                        Waste Generator, Title or
                                        Authorized Representative*
                                        of Waste Generator, Title
     *Note:   An  "authorized representative" is a person  respon-
      sible  for  the  overall operation of a facility or an opera-
      tional unit  (for example, a plant manager, superintendent,
      or person  of equivalent responsibility).  Consultants or
      other  outside  parties may not sign the certification state-
      ment .
                             A-8

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                SECTION B:   Production Processes
1.   Description of Manufacturing Processes  and  Other Operations
    C260.22(i)(5)].

    a.   Please  provide a brief description  of the  on-site
        manufacturing/generating process(es)  that  produce  the
        waste stream.   Include descriptions of  major equipment
        items .and production lines.   Also,  describe the stages of
        the typical operating cycle  (e.g.,  startup,  steady-state
        operation, cleaning and maintenance)  on a  daily, weekly,
        or other basis as appropriate.
    b.  Please provide a description of all surface and equipment
        preparation,  cleaning,  degreasing,  coating or painting
        processes used in your facility that you have not
        described in (a) above.
        Attach a schematic diagram of all manufacturing processes,
        surface preparation, cleaning, and other operations that
        may provide influent into the waste stream.
                              A-9

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2.   Materials Used or Produced

        You may comply with the requirements  for additional
        information in either of two ways;  see Section 4 of the
        Guidance Manual for a detailed description of the two
        approaches.
    Approach A;

    a.   List all materials  used or  produced  in  the  manufacturing
        or other process generating the  waste  stream(s).   Use the
        correct  chemical name wherever possible.  Include  mate-
        rials such as:

                    Raw materials
                    Intermediate products
                    By-products
                    Products
                    Oils and  hydraulic fluids
                    Surface preparation  materials
                      (solvents, acids,  cleaners, surface
                      preparation agents,  paints, etc.)
        Also:

        •  For each material  on the list,  indicate  whether it is
           discharged to or likely  to be present  in the  waste,  and
           the estimated amount entering the waste  stream  annual-
           ly.  (Specify kilograms,  pounds,  or  similar units.)
           Describe your estimation method.

        •  For each material  on the list that you do not expect  to
           be present in the  waste,  give supporting reasons for
           this  expectation.   Supporting reasons may include mass
           balance and  process information.

        •  Attach Materials Safety  Data  Sheets  (MSDS)  for  all
           materials that are identified by  trade or generic name
           only  and that are  discharged  into or likely to  be
           present in the waste stream.

                                             Estimated  Amount
                        Material            Entering the  Waste
                                             Stream Annually
           (Continue on additional  sheets  as  necessary)


                              A-10

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b.  Please give your assessment of the likelihood that the
    processes, operations, or feed materials described above
    might produce a waste stream that is not included in this
    petition.
Approach B;

You need not furnish any other information regarding your
facility's processes and materials.  You must, however, test
your waste for additional constituents as described in Chap-
ters 4 and 6 of the Guidance Manual.
                          A-ll

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                   SECTION C:   The Waste  Stream
1.  EPA hazardous waste number  and description  of waste  stream
    (from 261.31 or 261.32):
    No.	Description
    Form of the waste (e.g., aqueous solution, sludge,  dry  solids):
    If the waste is  a sludge,  give  the percent  solids:
2.   Estimated average and maximum monthly and annual quantities
    generated:   (Please  use  consistent units of measurement.)

                                    Average             Maximum

          Monthly               	

          Annually              	
3.   This waste stream:  (check all  that  apply)

                 Is  currently being generated.

                 Will be generated in the future.

          	  Has been generated in  the past and is currently
                 being  treated/stored on-site.

                 Has been generated in  the past and is currently
                 being  treated/stored off-site.
                              A-12

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4.  Present methods of on-site storage,  and amounts being stored:

                                       Amount

          Surface impoundment,      	

          Evaporation pond          	

          Percolation bed           	

          Waste pile(s)             	

          Tank(s)                   	

          Containers                	

          Landfill                  	

          Drums                     	

          Other (please specify)    	



5.  Waste Management Methods:

    Briefly describe:

          (a)  how the waste is currently managed;

          (b)  how it was managed before November 19, 1980;  and

          (c)  how it will be managed if this petition is approved,

    As appropriate, provide names and locations of off-site treat-
    ment, storage or disposal facilities, and names and addresses
    of waste transportation firms.

    If the waste is treated prior to disposal, please attach a
    schematic flow diagram of your present waste treatment system,
    showing the processes and equipment used.
                              A-13

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        SECTION D:  Selection of Constituents for  Testing
    The procedures described  below  apply  to  all  types  of  wastes
    other than those from petroleum refineries and multiple  waste
    treatment facilities.   Petitioners  for these facilities  should
    refer to Section 4 of  the Guidance Manual and adapt this
    section of the petition appropriately.


1.  If you have followed Approach A in  Section B above, please
    submit test results on representative samples for  the follow-
    ing:

          •  The specific hazardous constituents for which the
             waste was listed (i.e., total concentration  of  each
             listed constituent  found  in  Appendix VII  of  Part
             261) ;

          •  The four hazardous  waste  characteristics  (but see the
             Note  immediately below);

          •  Appropriate leachate tests for  the  EP  toxic  metals,
             nickel,  and cyanide;

          •  Total concentrations of the  EP  toxic metals  and
             nickel;

          •  Total organic carbon  (TOC);  and

          •  Total oil and grease.

    Note;   If you  can explain why the waste  cannot  exhibit one or
    more of the four  hazardous waste characteristics,  you may
    submit your rationale in  lieu of test results for  those  char-
    acteristics.   For  example, if the waste  is composed exclusive-
    ly of organic solvents and there is no chance (on  the basis of
    process considerations) that  it contains  any of the EP toxi-
    cants,  you need not test  for the EP Toxicity characteristic.

    You may omit the  rest  of  this section and go to Part  E.


2.  If you have opted for Approach 3 in Section  B above,  then you
    must perform the  tests specified in the  above paragraph, and
    you should test for all hazardous constituents  that may  "rea-
    sonably be expected" to be in the waste,  whether or not  they
    were used as a basis for  listing.

    The remainder  of  this  section is to be used  to support your
    decision regarding which  constituents to test  for.
                             A-14

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List the constituents (from Appendix VIII to Part 261)
that may reasonably be expected to be in the waste.   De-
scribe the engineering,  chemical,  or other considerations
that support your choice.
Constituent:
Reasons for Selection:
                (Repeat as necessary.)
For each of the remaining hazardous constituents (or
groups of constituents) in Appendix VIII of Part 261,
specify why it may not reasonably be expected to occur in
the waste stream.   Base your reasoning on process,  engi-
neering,  mass balance or other considerations as appro-
priate.

Constituent (or group of constituents):   	

Reasons for non-occurence:
               (Repeat as necessary.)
                      A-15

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              SECTION £:  Sampling and Testing the Waste
The purpose of the data requested below is to demonstrate that
representative samples of the waste stream:

    a.  Do not exhibit any of the criteria (e.g.,  hazardous waste
        characteristics or constituents)  for which the waste was
        listed, and

    b.  Do not exhibit any other criteria that could cause it to
        be listed.

Additional information is also requested  as  a check on the test
results.  Refer to the accompanying Guidance Manual for instruc-
tions on developing a sampling plan (Chapter 7),  selecting proper
test methods,  (Chapter 8) and presenting  the test  results (Chapter
9).


1.   General Information
        Name and address of the laboratory facility performing the
        sampling [260.22(i)(1)]:
        Name

        Street
        City    	  State  	  Zip  _

        Telephone: (	)	-	


        If sampling was done by in-house staff,  check here:
        For each individual person who (a)  designed the sampling
        plan or (b~)collected samples, please provide the follow-
        ing information and attach a resume or other statement of
        qualifications [260.22(i)(2)].

        Name  	;	

        Affiliation  	_^^

        Title
                        (Repeat as necessary.)


                              A-16

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b.  Name and address of the laboratory facility performing the
    testing, if different from the sampling laboratory
    [260.22(1)(1)]:
    Name

    Street
    City    	  State  	  Zip

    Telephone: (	)	-	


    If testing was done by in-house staff,  check here:
    For each individual person who (a) designed the testing
    plan or (b) performed tests, please provide the following
    information and attach a resume or other statement of
    qualifications [260.22(i)(2)] .
    Name
    Affiliation

    Title
                    (Repeat as necessary.)
                          A-17

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   Describe the sampling strategy you followed to insure that
   the samples were representative [260.22(i)(8)] .   Please
   address specifically:
        the variation of the waste stream over time;  and

        the variation of the waste stream in space.
   All waste stream outflows or storage locations to which
   this petition applies must be sampled.   The Delisting
   Petition Guidance Manual (see Instructions to this form)
   gives .directions for developing a sampling plan.
d. State whether the Chain of Custody procedures in Section
   1.3 of SV/-846 were followed.  Please describe any devia-
   tions from those procedures and the reasons for them.
                         A-18

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2.  Sample-Specific Information


     For each individual sample,  please furnish the'information
     requested in the form on the following page.   The notes below
     refer to those items on the  form that are not self-explana-
     tory.  The Guidance Manual contains additional instructions.
                              Notes
Item f,  "Parameter/Constituent Tested For":   Enter the hazardous
        waste characteristic or constituent  that was the subject
        of the test.

Item i,  "Test Method  and Source":   See Chapter 3 of the Guidance
        Manual for a  listing of applicable test methods.  Sources
        for test methods may be designated by number,  as follows:

             1. "Test Methods for Evaluating Solid Waste:
                Physical/Chemical Methods,"  EPA SW-846 (second
                edition), July, 1982, and supplements.

             2. "Methods for the Evaluation  of Water and
                Wastewater," EPA _600 14-79-020, March, 1979.

             3. "Standard Methods for the Examination of Water
                and Wastewater," (14th Edition).

             4. Appendix J of the Guidance Manual

Item j,  "Sample Workup or Preparation Method": See Section Four
        of Reference  1 above.

Item 1,  "Test Results":   Enter concentrations in mg/1, ppm,  etc.
        as appropriate.
                              A-19

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                       Sample Number:
Sampling Information;
 a.  Sampling location:
 b.  Person(s) who drew the sample:
 c.  Equipment used for drawing the sample:
                                                               a .m,
 d.  Date and time when the sample was drawn:  	/  /  ,         p.m.

 e.  Handling, containerization,  and preservation techniques used:
Test Procedures and Results;   (Repeat for each test conducted)


 f.  Parameter/Constituent Tested For:	

 g.  Date Test Performed:   	/	/	

 h.  Person(s) who performed the test:  	
 i.  Test Method (or Number) and Source:

 j.  Sample Workup or Preparation Method:
 k.  Equipment:      Name                      Model Number
 1.  Test Results:
                              A-20

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3.  Summary Table of Analytical Results
     For each sample,  please enter the Test Results from Item 2
     above onto the form contained in the following pages.
4.  Analytical Discussion
     Please furnish explanations or additional information on the
     following topics as necessary:

     a.   Inconsistencies or deviations in the analytical results
         presented above.

     b.   Additional reasons as to why the waste stream should be
         delisted.
                              A-21

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                                                              SUMMARY OF TEST RESULTS
Ni
N>
Sample Number :
Sampling Location:
Date Sample Taken:
1 . ignitability
Liquids Flash point
Non- liquids Spontaneous
combustion
Compressed Flammability
Gas
Oxidizer Oxygen yield
2. Corrosivity pH
Corrosivity
towards steel
3. Reactivity Violent chemical
change
Reacts violently
with water
Water-reactive;
explosive









-





















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                                                   SUMMARY OF TEST RESULTS (Continued)
to
LJ
Sample Number:
3. Reactivity Water-reactive;
(Cont.) toxic gases,
vapors , fumes
Cyanide or sulfur-
bearing wastes
which, when exposed
to acidic/basic
conditions, gen-
erate toxic gases,
vapors, or fumes
Explosive when
subjected to
force or heat
Explosive at stan-
dard temperature
and pressure
DOT explosive
4. Total Arsenic
Metals
(Complete Barium
Acid
Digestion) Cadmium
Chromium









































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                                                  SUMMARY OF TEST RESULTS (Continued)
K>
Sample Number :
4. Total Lead
Metals
(cont.) Mercury
Selenium
Silver
Nickel
5. EP Toxicity Arsenic
— Metals
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Nickel


































































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                                                  SUMMARY OF TEST RESULTS (Continued)
>
NJ
Sample Number:
6. EP Toxicity Arsenic
— Metals;
Oily Waste Barium
Methods*
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
»
Nickel
7. EP Toxicity Endrin
— Pesticides
Lindane
Methoxychlor
Toxaphene
8. EP Toxicity 2,4-D
— Herbicides
2,4,5-TP (Silvex)




















                   *For wastes containing greater than 1% total oil and grease.

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                                                  SUMMARY OF TEST RESULTS (Continued)
to
Sample Number:
9. EP Toxic ity
— Organics
10. Total Organ-
ic Carbon

11. Oil and
Grease

1 2 . Cyanide Total
Free
Extraction
procedure
Photodegradable
13. Other Appendix VIII
cons ti tuents
(Add sheets as
necessary)































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5.  Quality Assurance and Quality Control

    a.  For inorganic substances,  describe the procedures used for
        Standard Additions Analysis.   Provide the  following for
        each substance tested:
                      Spike          Recovery          Percent
    Substance     Concentration    Concentration       Recovery
         For organic substances,  describe the procedures used for
         analysis of spiked samples.  For each substance tested,
         provide the information requested in the following table.
         Also, describe in writing the procedures used  to cali-
         brate the analytical equipment.
      Substance         Surrogate,       Spike   Recovery  Percent
     Tested For           if any        Cone.      Cone.    Recovery
         Describe any other QA/QC measures  followed in regard to
         the sampling and analysis procedures.
                              A-27

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                        APPENDIX B

HAZARDOUS  WASTE  DELISTING REGULATIONS (40 CFR 260 Subpart C)
       The regulations  in this Appendix are  current
       as of April 1985.   Therefore,  they  do  not
       reflect  forthcoming  changes  in  the  delisting
       procedures  to be  issued in accordance with the
       Hazardous  and  Solid Waste Amendments of 1984.

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   Subpart C—Rulamaking Petition!

§260.20  General.
  (a) Any person may petition the Ad-
ministrator to modify or  revoke  any
provision in Parts 260 through 265 of
this chapter.  This section sets forth
general requirements which apply to
all such petitions. Section 260.21  sets
forth additional requirements for peti-
tions  to add  a testing  or analytical
method to Pan 261, 264 or 265. Sec-
tion 260.22 sets forth  additional  re-
quirements for petitions to exclude a
waste  at  a  particular  facility from
S 261.3 of this chapter or  the lists ol
hazardous wastes in Subpart D of Part
261.
  (b) Each petition must be submitted
to the Administrator by  certified mail
and must include:
  (1)  The  petitioner's name and ad-
dress;
  (2)  A statement of the  petitioner's
interest in the proposed action;
  (3)  A  description  of the  proposed
action, including (where appropriate)
suggested regulatory language; and
  (4) A statement of the  need and jus-
tification for the proposed action,  in-
cluding any supporting tests, studies,
or other information.
                B-3

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Chapter I—Environmental Protection Agency
                             1260.22
  (c)  The Administrator  will make a
tentative decision to grant or deny a
petition and  will  publish notice of
such  tentative decision, either in the
form  of an  advanced notice of pro-
posed rulemaking, a proposed rule, or
a tentative determination to deny the
petition, in  the FEDERAL REGISTER for
written public comment.
  (d)  Upon the written request of any
interested person,  the Administrator
may,  at his discretion, hold an infor-
mal public  hearing to consider oral
comments on the tentative decision. A
person requesting a hearing must state
the issues  to be  raised  and explain
why written comments would not  suf-
fice  to communicate the  person's
views. The Administrator may in  any
case decide on his own motion to hold
an informal public hearing.
  (e)  After evaluating all public com-
ments the Administrator  will make a
final  decision  by publishing  in  the
FEDERAL REGISTER a regulatory amend-
ment or a denial of the petition.

§ 260.21  Petitions for equivalent testing or
    analytical method*.
  (a) Any person seeking to add a test-
ing or analytical method  to Part 261,
264, or  265 of this chapter may peti-
tion  for a  regulatory  amendment
under this section and J 260.20. To be
successful,  the  person must demon-
strate to the  satisfaction  of  the  Ad-
ministrator that the proposed method
is equal to or  superior to  the corre-
sponding method  prescribed  in Part
261. 264. or  265 of this  chapter, in
terms of its sensitivity, accuracy, and
precision (i.e., reproducibility).
  (b)  Each petition must  include, in
addition to  the information required
by § 260.20(b):
  (DA full description of the proposed
method, including all procedural steps
and equipment used in the method;
  (2)  A  description of the  types  of
wastes or waste matrices for which the
proposed method may be used;
  (3)  Comparative  results  obtained
from  using the proposed method with
those obtained  from using the rele-
vant  or corresponding methods  pre-
scribed  in Part 261. 264. or 265 of this
chapter;
  (4)  An assessment  of any  factors
which may interfere with, or limit the
use of, the proposed method; and
  (5)  A description of the quality con-
trol  procedures  necessary  to  ensure
the sensitivity, accuracy and precision
of the proposed method.
  (c) After receiving a petition for an
equivalent method, the Administrator
may request any additional informa-
tion on the proposed method which he
may  reasonably  require to evaluate
the method.
  (d) If the Administrator amends the
regulations  to permit  use  of  a new
testing method, the method will be in-
corporated In "Test Methods for the
Evaluation of Solid Waste: Physical/
Chemical Methods," SW-846. U.S. En-
vironmental Protection Agency, Office
of  Solid Waste,  Washington,  D.C.
20460.
[Comment This manual will be provided to
any person on request, and will be available
for inspection or copying at EPA headquar-
ters or any EPA Regional Office.]

§260.22  Petitions  to amend Part  261 to
   exclude a waste produced at a particu-
   lar facility.
  (a) Any person seeking to exclude a
waste at a particular generating facili-
ty from the lists  in Subpart D of Part
261  may petition for  a regulatory
amendment under this section and.
! 260.20. To be successful, the petition-
er must demonstrate to the satisfac-
tion  of  the  Administrator that  the
waste produced by a particular gener-
ating facility does not meet any of the
criteria under  which  the waste was
listed as a hazardous waste and, in the
case  of an  acutely hazardous  waste
listed under § 261.11(a)(2). that it also
does  not meet   the   criterion  of
§ 261.11(a)(3).  A waste which is so ex-
cluded may still, however, be a hazard-
ous waste by operation of Subpart C
of Part 261.
  (b)  The procedures  in this section
and g260.20 may also be used to peti-
tion the Administrator for a regulato-
ry  amendment   to   exclude   from
§ 261.3(a)(2)(ii) or (c), a waste which is
described in  those sections  and is
either a waste listed  in Subpart  D,
contains a waste  listed in Subpart D,
or is  derived  from a waste  listed in
                                   B-4

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§ 260.22
   Title 40—Protection of Environment
Subpart D. This exclusion may only be
issued  for  a  particular  generating,
storage, treatment, or disposal facility.
The petitioner  must make  the  same
demonstration as  required  by  para-
graph (a) of this section, except that
where the waste is a mixture of solid
waste  and one or more listed hazard-
ous wastes or is derived  from one or
more  hazardous wastes,  his  demon-
stration may be made with respect to
each constituent listed waste or  the
waste  mixture as  a whole.  A waste
which is so  excluded may still  be a
hazardous waste by operation of Sub-
part C of Part 261.
  (c) If the waste is listed with codes
"I", "C", "R", or "E"  in Subpart D,
the petitioner must show that demon-
stration samples of the waste do  not
exhibit the relevant characteristic  de-
fined in §261.21, § 261.22, § 261.23, or
5 261.24  using  any  applicable   test
methods prescribed therein.
  (d)  If  the waste  is listed  with code
"T" in Subpart D, the petitioner  must
demonstrate that:
  (1)  Demonstration samples of the
waste  do not  contain the constituent
(as defined  in  Appendix  VII)  that
caused  the Administrator to list the
waste,  using  the  appropriate   test
methods prescribed In  Appendix III;
or
  (2) The waste does not meet the cri-
terion of 5 261.11(a)(3) when consider-
ing  the factors  in  § 261.11(a)(3)  (i)
through (xi).
  (e) If  the waste  is listed with the
code "H" in Subpart D, the petitioner
must demonstrate that the waste does
not meet both of  the following crite-
ria:
  (1) The criterion of § 261.11(a)(2).
  (2)  The  criterion  of  § 261.11
-------
quest  any  additional   information
which he may reasonably require to
evaluate the petition.
  
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          APPENDIX  C

STATE HAZARDOUS WASTE  AGENCIES
    AND DELISTING CONTACTS

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                   STATE  HAZARDOUS WASTE AGENCIES
                         AND DELISTING CONTACTS

  (Telephone  numbers  for  delisting  contacts are  the  same
         as  for  the  agency,  unless  otherwise  shown.)
Alabama

Alabama Dept. of Environmental
  Management
Solid S Hazardous Waste
  Management Division
State Capitol
Montgomery,- Alabama  36130
(205)  832-6728

Delisting Contact:
  Bill Gallagher, (404)  881-3016
Alaska

Department of Environmental Conservation
Air &  Solid waste Management
Pouch  0
Juneau, Alaska  99811
(907)  465-2635

Delisting Contact:
  Dave Ditraglia, (907)  465-2666
American  Samoa

Environmental Quality Commission
American  Samoa Government
Pago Pago, American Samoa  96799
Overseas  Operator 633-4116

Delisting Contact:
  Lucy Mlenar (EPA Region IX)
  (415) 974-7472
California

Department of Health Services
Toxic Substances Control Division
714 P Street
Sacramento, California 95814
(916) 324-1789

Delisting Contact:
  Stan Lau, (916) 324-1807
                                                 Colorado
Colorado  Department of Health
Waste Management Division
4210 E. 11th Avenue
Denver, Colorado  80220
(303) 320-8333

Delisting Contact:
  Ken Waesche
Commonwealth of North Mariana Islands

Department of Public Health and
  Environmental Services
Division of Environmental Quality
Commonwealth of the North Mariana Islands
Saipan,  Mariana Islands  96950
Overseas Operator: 6984

Delisting Contact:
  Lucy Mlenar (EPA Region IX)
  (415)  974-7472
Arizona

Bureau of Waste Control
Department of Health Services
State Health Building
1740 West Adams Street
Phoenix, Arizona  85007
(602) 255-1170

Delisting Contact:
  Sally Mates, (602) 255-1160
Connecticut

Department of Environmental Protection
Hazardous Materials Management Unit
State Office Building
165 Capitol Avenue
Hartford, Connecticut  06115
(203) 549-4924

Delisting Contact:
  Barry Giroux, (203) 566-4869
Arkansas

Department of Pollution Control
  and Ecology
Solid Waste Management Division
PO Box 9533
8001  National Drive
Little Rock, Arkansas 72219
(501) 562-7444

Delisting Contact:
  Jay Justice, x274
Delaware

Department of Natural Resources
  and Environmental Control
Solid Waste Management Branch
89 King Highway
PO Box 1401
Dover, Delaware  19901
(302) 736-4781

Delisting Contact:
  Alan Simpson
                                      C-3

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District of Columbia

Department of Environmental
  Services
Division of Pesticides
  and Hazardous Materials
5000 Overlook Avenue, S.W.
Washington, D.C.  20032
(202) 767-8422

Delisting Contact:
  Angelo Tompros
Florida

Department of Environmental Regulations
Solid Waste Section
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, Florida  32301
(904) 488-0300

Delisting Contact:
  Craig Dieltz
Department of Natural Resources
Environmental Protection Division
270 Washington Street, S.W.
Atlanta, Georgia  30334
(404) 656-2833

Delisting Contact:
  Shirley Maxwell
Guam

Environmental Protection Agency'
Government of Guam
PO Box 2999
Agana, Guam  96910
Overseas Operator 646-3863
                            «
Delisting Contact:
  Jim Canto
Hawaii

Department of Health
Environmental Health Division
PO Box 3378
Honolulu, Hawaii  96801
(808) 548-4139

Delisting Contact:
  Lucy Mlenar (EPA Region IX)
  (415) 974-7472
Idaho

Department of Health and Welfare
Hazardous Materials Bureau
State House
Boise, Idaho  83720
(208) 334-4064

Delisting Contact:
  Daryl Koch, (208) 384-4118
Illinois

Environmental Protection Agency
Division of Land Pollution Control
2200 Churchill Road
Springfield, Illinois  62706
(217) 782-0246

Delisting Contact:
  Gary King, (217) 782-5544
Indiana
State Board of Health
Land Pollution Control Division
1330 West Michigan Street
Indianapolis, Indiana  46206
(317) 633-0194

Delisting Contact:
  Gwyn Doyle, (317) 243-5021
Iowa

Department of Environmental Quality
Hazardous Waste Program
Henry A. Wallace Building
9OO East Grand street
Des Moines, Iowa  50319
(515) 281-8853

Delisting Contact:
  Ron Kolpa, (515) 281-8925
                                                    Kansas
Department of Health and Environment
Bureau of Environmental Sanitation
Forbes Field, Building 321
Topeka, Kansas  66620
(913) 862-9360

Delisting Contact:
  John Mitchell
                                          C-4

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Kentucky
                                                    Michigan
Department of Natural Resources
  and Environmental Protection
Division of Waste Management
18 Reilly Road
Frankfort, Kentucky  40601
(502) 564-6716
                              Department of  Natural  Resources
                              Environmental  Services Division
                              Office of Hazardous  Waste  Management
                              Box 30028
                              Lansing,  Michigan 48909
                              (517)  373-2730
Delisting Contact:
  George Gilbert
                              Delisting Contact:
                                Al Howard
Louisiana
                                                    Minnesota
Department of Natural Resources
Solid Waste Management Division
PO Box 44066
Baton Rouge, Louisiana  70804
(504) 342-1216
                              Pollution Control Agency
                              Solid and Hazardous  Waste Division
                              1935  West County Road,  R-2
                              Roseville, Minnesota  55113
                              (612)  296-7333
Delisting Contact:
  Bill Greenwich, (504)  342-1227
                              Delisting Contact:
                                Gordon Myer,  (612)  296-7784
Maine

Department of Environmental Protection
Bureau of Oil and Hazardous Materials
State House - Station 17
Augusta, Maine  04333
(207) 289-2651
Delisting Contact:
  Dave Boulter, (207)
289-2651
Mississippi

Department of Natural Resources
Division of Solid & Hazardous
  Waste Management
PO Box 10385
Jackson, Mississippi  39209
(601)  961-5171

Delisting Contact:
  David Lee, (601) 961-5046
Maryland

Department of Health and Mental Hygiene
Waste Management Administration
201 Hast Preston Street
Baltimore, Maryland  21201
(301) 383-5740

Delisting Contact:
  Alvin Bowles, (301) 383-5736
Massachusetts

Department of Environmental
  Quality Engineering
Division of Hazardous waste
One Winter Street
Boston, Massachusetts  02108
(617) 292-5589

Delisting Contact:
  Steve Dreeszen, (617) 292-5832
                              Missouri

                              Department of Natural Resources
                              Solid Haste Management Program
                              PO BOX 1368
                              Jefferson City, Missouri  65102
                              (314) 751-3241

                              Delisting Contact:
                                Stan Jorgenaon
                              Montana

                              Department of Health and
                                Environmental Services
                              Solid Haste Management Bureau
                              Cogswell Building
                              Helena, Montana  59602
                              (406) 444-2821

                              Delisting Contact:
                                Roger Thorvilson
                                         C-5

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Nebraska
                                                    New York
Department of Environmental Control
Water and Haste Management Division
PO Sox 94877
Lincoln, Nebraska  63509
(402) 471-2186

Delisting Contact:
  Mike Steffensmeier
Nevada

Department of Conservation and
  Natural Resources
Waste Management. Program
Capitol Complex
Carson City, Nevada  89701
(702) 885-4670

Delisting Contact:
  Verne Rosse
New Hampshire

Department of Health and Welfare
Office of Waste Management
Health & welfare Building
Hazen Drive
Concord, New Hampshire  03301
(603) 271-4608

Delisting Contact:
  Len Poole, (603) 271-4611
New Jersey

Department of Environmental protection
Solid Waste Administration
32 E. Hanover Street
Trenton, New Jersey  08625
(609) 292-9877

Delisting Contact:
  Sonya Shashova, (609) 292-8341
New Mexico

New Mexico Health and Environment
  Department
Environmental Improvement Division
PO BOX 968
Santa Fe, New Mexico  87504
(505) 984-0020

Delisting Contacts:
  Peter Pache, (SOS) 984-0020, X340
  Trent Thomas, (505) 827-5271
Department of Environmental
  Conservation
Division of Solid Waste
50 Wolf Road
Albany, New York  12233
(518) 457-6603

Delisting Contact:
  Jim Moran, (518) 457-6858
North Carolina

Department of Human Services
Environmental Health Section
Solid s Hazardous Waste
  Management Branch
PO Box 2091
Raleigh, North Carolina  27602
(919) 733-2178

Delisting Contact:
  Jerry Rhodes, (919) 733-2178
North Dakota

Department of Health
Division of Environmental
  Waste Management & Research
1200 Missouri Avenue
Bisnark, North Dakota  58505
(701) 224-2366

Delisting Contact:
  Neil Knatterud, (701) 224-2366
Ohio

Ohio Environmental Protection Agency
Office of Land Pollution Control
9O Box 1049
Columbus, Ohio  43216
(614) 466-8934

Delisting Contact:
  Tom Carlisle, (614) 462-6735
Oklahoma

Oklahoma State Department of Health
Industrial s solid waste Service
1000 HE 10th Street
Oklahoma City, Oklahoma  <73152
(405) 271-5338
Delisting Contact:
  Donald A. Hensch,
(405)  271-5338
                                         C-6

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                                                    South Dakota
Department of Environmental Quality
Solid Waste Management Division
PO Box 1760
522 S.W. Fifth Avenue
Portland,  Oregon  97207
(503) 229-5913

Delisting Contact:
  Rich Reiter, (503)  229-6434
Pennsylvania,

Department of Environmental Resources
Bureau of Solid Waata Management
Fulton Building
PO Box 2063
Harrisburg, Pennsylvania  17120
(717)  787-9870

Delisting Contact:
  David Freedman, (215)  637-7381
Department of Water & Natural Resources
Office of Air Quality & Solid Waste
Joe Foss Building
Pierre, South Dakota  57501
(605) 773-3329

Delisting Contact:
  Kevin Tviadt
Tennessee

Department of Public Health
Bureau of Environmental Services
Division of Solid waste Management
150 9th Avenue, North
Nashville, Tennessee  37203
(615) 741-3424

Delisting Contact:
  Shirley Dunn
Puerto Rico

Environmental Quality Board
Solid, Toxics, S Hazardous Waste Program
Box 11488
Santurce, Puerto Rico  00910-1488
(809) 725-8992

Delisting Contact:
  Yacnan Lopez
Rhode Island

Department of Environmental Management
Solid Haste Management Program
Cannon Building
75 Davis Street
Providence, Rhode Island  02908
(401) 277-2797

Delisting Contact:
  Steve Majkut
South Carolina

South Carolina Department of
  Health £ Environmental Control
Bureau of Solid 4 Hazardous Waste
  Management
J. Marion Siam* Building
2600 Bull Street
Columbia, South Carolina  29201
(803) 758-5681
Texas

Texas Department of Health
Bureau of Solid Waste Management
1100 west 49th Street, T-602
Austin, Texas  78756
(512) 458-7271

Delisting Contact:
  Dick Martin (TDWR), (512) 475-2041
Utah

Bureau of Solid s Hazardous Waste
Waste Management Division
PO Box 2500
ISO West North Temple
Salt Lake City, Utah  34110
(301) 533-4145

Delisting Contact:
  Kent Gray
Vermont

Agency of Environmental Conservation
Air £ Solid waste Programs
State Office Building
Montpeliar, Vermont  05602
(802) 328-3395

Delisting Contact:
  John Miller
Delisting Contacts:
  Lynn Martin, Rick Grant
                                         C-7

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Virgin Islands

Department of Conservation and
  Cultural Affairs
Division of Natural Resources
Hazardous Waste Program
PO Box 4340, Charlotte Amalie
St. Thomas, Virgin Islands  00801
(809) 774-6420

Delisting Contact:
  Roger Van Eepoel
Virginia

Virginia Department of Health
Division of Solid and Hazardous
  Haste Management
Madison Building
109 Governor Street
Richmond, Virginia  23219
(304) 786-5271
West Virginia

Department of Natural Resources
1201 Greenbrier Street
East Charleston, West Virginia  25311
(304) 348-5935

Deliating Contact:
  Robert Jelacic
Wisconsin

Department of Natural Resources
Bureau of Solid Waste Management
PO Box 7921
Madison, Wisconsin  53707
(608) 266-1327

Delisting Contact:
  Richard O'Hara, (608) 266-0833
Delisting Contact:
  Walt Gulovich, (804)  225-2667
Washington

Department of Ecology
Solid waste Management Division
Olympia, Washington  98504
(206) 459-6317

Delisting Contact:
  Tom Cook, (206) 459-6301
State of Wyoming Department of Environ-
  mental Quality
Solid waste Management Program
Equality State Bank Building
401  West 19th Street
Cheyenne, Wyoming  32002
(307) 777-7752

Delisting Contact:
  Dave Finley
                                         C-8

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                     APPENDIX D

HAZARDOUS WASTE  CHARACTERISTICS  (40 CFR 261 Subpart C)
    The content of  this  Appendix was  reproduced
    from the Code of Federal Regulations of  July
    1,  1984.   Users  should check the current  ver-
    sion of the Code of  Federal Regulations and
    more recent issues of  the Fe3era^T~Register for
    amendments.

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     Subpart C—Characteristics of
          Hazardous Wast*

3 281.20  General.
  (a) A solid waste,  as  defined  in
9 261.2. which is not  excluded  from
regulation as a hazardous waste under
§ 261.4(b), is a hazardous waste if it ex-
hibits any of the characteristics identi-
fied in this Subpart.
[Comment:  5 2S2.11  of this  chapter sets
forth the generator's responsibility to deter-
mine whether his  waste exhibits one  or
more of the characteristics Identified In this
Subpart]  .
  (b) A hazardous waste which is iden-
tified by a  characteristic in this sub-
part, but is  not  listed  as a hazardous
               D-3

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 § 261.21
   Till* 40—Protection of Environment
 waste in Subpart  O, is  assigned the
 EPA Hazardous Waste  Number  set
 forth in  the  respective characteristic
 in this Subpart. This number must be
 used in  complying with  the notifica-
 tion  requirements  of Section 3010 of
 the Act and certain recordkeeping and
 reporting  requirements  under Parts
 262  through 265 and Part 270 of this
 chapter.
  (c) For purposes of this Subpart, the
 Administrator will  consider a sample
 obtained  using any of  the applicable
 sampling methods specified in Appen-
 dix  I to  be a representative sample
 within the meaning of Part 260 of this
 chapter.
 [Comment Since the Appendix I sampling
 methods are not being formally adopted by
 the Administrator, a person  who desires to
 employ an alternative sampling method is
 not required to demonstrate the equivalency
 of his method under the procedures  set
 forth in Si 280.20 and 260.21.]
 (45 PR 33119. May 19. 1980.  a» amended at
 48 PR 14294. Apr. 1. 19831

 9 261.21  CharmctcriaUe of ignitability.
  (a) A solid waste exhibits the charac-
 teristic of ignitability if a representa-
 tive  sample of the waste has any of
 the following properties:
  (1) It is a liquid, other than an aque-
 ous solution containing less  than 24
 percent  alcohol by volume and  has
 flash point less than 60*C (140'P). as
 determined   by  a  Pensky-Martens
 Closed  Cup  Tester, using -the test
 method specified in ASTM  Standard
 D-93-79  or D-93-80 (incorporated  by
 reference, see 5 260.11).  or a Setaflash
 Closed  Cup  Tester, using  the test
 method specified in ASTM  Standard
 D-3278-78 (incorporated by reference,
 see i 260.11), or as determined by  an
 equivalent test method approved  by
 the  Administrator  under procedures
set forth in 35 260.20 and 260.21.
  (2)  It  is not a liquid and is capable,
 under standard temperature and pres-
 sure,  of causing fire through friction.
 absorption of moisture or spontaneous
 chemical changes  and.  when ignited.
 burns so  vigorously and persistently
 that is creates a hazard.
  (3) It is an ignitable compressed gas
as defined in  49 CPR 173.300 and as
determined  by the  test methods de-
scribed  in that regulation  or equiva-
 lent test methods approved by the Ad-
 ministrator under § § 260.20 and 260.21.
  (4) It is an oxidizer as defined in 49
 CFR 173.151.
  (b) A solid  waste that exhibits the
 characteristic of ignitability, but is not
 listed as a hazardous waste in Subpart
 D,  has  the  EPA  Hazardous  Waste
 Number of D001.

 [45 PR 33119. May 19, 1980, a* amended at
 46 PR 35247. July 7. 1981]

 9 261.22  Characteristic of corrosivity.

  (a) A solid waste exhibits the charac-
 teristic  of corrosivity if a representa-
 tive sample of the waste has either of
 the following properties:
  (1) 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   either  an  EPA  test
 method or an  equivalent test method
 approved by the Administrator under
 the procedures set  forth in §§ 260.20
 and 260.21.  The EPA test method for
 pH is specified as Method 5.2 in "Test
 Methods for the Evaluation of Solid
 Waste,  Physical/Chemical   Methods"
 (incorporated   by    reference,   see
 J 260.11).
  (2)  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 tem-
 perature of 55'C (130'P) as determined
 by  the test method specified in NACE
 (National Association of Corrosion En-
 gineers) Standard TM-01-69 as stand-
 ardized in "Test Methods for the Eval-
 uation  of  Solid  Waste.   Physical/
 Chemical Methods" (incorporated by
 reference, see  § 260.11) or an  equiva-
 lent test method approved by the Ad-
 ministrator  under the procedures set
 forth in §5 260.20 and 260.21.
  (b)  A  solid waste  that  exhibits the
characteristic of corrosivity, but is not
 listed as a hazardous waste in Subpart
 D,  has   the EPA  Hazardous   Waste
 Number of O002.

 [45  FR 33119, May 19.  1980. as amended at
46 PR 35247, July 7, 1981]

 9 261.23  Characteristic of reactivity.
  (a) A solid waste exhibits the charac-
 teristic of reactivity if a representative
sample of the waste has any of the fol-
lowing properties:
                                D-4

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 Chapter I—Environmental Protection Agency
                            §261.30
   (1) It is normally unstable and read-
 ily undergoes violent change  without
 detonating.
   (2) It reacts violently with water.
   (3)  It  forms  potentially explosive
 mixtures with water.
   (4) When mixed with water, it gener-
 ates  toxic gases, vapors or fumes in a
 quantity  sufficient to present a danger
 to human health or the environment.
   (5) It is a cyanide or sulfide bearing
 waste which, when exposed to pH con-
 ditions between 2 and 12.5, can gener-
 ate toxic gases, vapors  or fumes in a
 quantity  sufficient to present a danger
 to human health or the environment.
   (6) It is capable of detonation or ex-
 plosive reaction if it is subjected to a
 strong initiating source or  if heated
 under confinement.
   (7) It is readily  capable of  detona-
 tion or explosive decomposition or re-
 action at standard  temperature and
 pressure.
   (8) It is a forbidden explosive as de-
 fined in 49 CFR 173.51. or a  Class A
 explosive as defined in 49  CFR 173.53
 or a Class B explosive as defined in 49
 CPR 173.88.
   (b) A solid  waste that exhibits  the
 characteristic of reactivity, but is  not
 listed as a hazardous waste in Subpart
 D. has  the  EPA Hazardous  Waste
 Number of O003.

 9 261.24 Characteristic of EP toxicity.
   (a) A solid waste exhibits the charac-
 teristic of EP toxicity if, using the test
 methods  described in Appendix  II  or
 equivalent methods approved  by the
 Administrator  under  the  procedures
 set forth  in 55 260.20 and 260.21. the
 extract from  a representative sample
 of the waste contains any of the con-
 taminants listed in Table  I  at a con-
 centration equal to or greater than the
 respective value  given  in  that Table.
 Where the waste contains less than 0.5
 percent filterable  solids,  the waste
 Itself,  after filtering, is  considered  to
 be the extract for the purposes of this
 section.
  (b)  A solid waste that exhibits the
 characteristic of EP toxicity. but is not
 listed as a hazardous waste in Subpart
O,  has the  EPA  Hazardous Waste
Number specified in Table I which cor-
responds  to  the  toxic contaminant
causing it  to be hazardous.
TABLE I—MAXIMUM CONCENTRATION OF CON-
  TAMINANTS  FOR  CHARACTERISTIC OF  EP
  TOXICITY
EPA
nazarooua
wuia
numMr
0004 	
0005 	
0008 	
0007 	
0008 	
0009 	
0010 	
0011 	
0012 	




0013 	

0014 	


0015 	

0016

0017 	

Contaminant
Araanic ...
Swum
Cadmium 	
Cnromum 	
Laad 	
Mwcury 	
SaMnum . .. .
Si(v«r . . ...
EnOnn (1.2.3,4.10,10-hKiicn.
ion>l.7-apo»y-
i .4,4a.5.6.7.8.8a-aciaflydro-
i ,4-
-------
                  APPENDIX E

LISTS OF HAZARDOUS WASTES  (40 CFR 261 Subpart D)
 The content of  this  Appendix was reproduced
 from the Code of Federal Regulations of  July
 1,  1984.   Users  should check the  current  ver-
 sion of the Code of  Federal Regulations and
 more recent issues of  the Federal Register for
 amendments.

-------
    Subpart 0—Lists of Hazardous
               Wastes

§ 261.30  General.
  (a)  A  solid  waste  is a  hazardous
waste if it is  listed  in this  subpart,
unless it has been excluded from this
list under !§ 260.20 and 260.22.
  (b) The  Administrator will indicate
his basis for listing the classes or types
of wastes listed in this Subpart by em-
ploying one or more of the following
Hazard Codes:
                                   (I)
COT09M W«M	    (Q
RMCM WMW	    	    (R)
EPTonqWaiw	    (&
Acun Hfivaaut w«w.   .       ....    (H)
Tone WMM	     	         (T)
Appendix VII identifies the constitu-
ent which caused the Administrator to
list the waste as an  EP Toxic Waste
(E) or Toxic Waste  (T) in {$261.31
and 261.32.
  (c) Each hazardous waste listed  in
this subpart  is assigned an EPA Haz-
               E-3

-------
§ 261.31
   Title 40—Protection of Environment
ardous Waste Number which precedes
the name of the waste. This number
must  be used in complying with the
notification requirements of Section
3010  of  the Act and certain record-
keeping  and  reporting  requirements
under Parts 262 through 265 and Part
270 of this chapter.
  (d) The following hazardous wastes
listed in § 261.31 or § 261.32 are subject
to the exclusion limits for acutely haz-
ardous wastes established in § 261.5:
[Reserved]
[45 FR 33119. May 19. 1980. as amended at
45 FR 74892. Nov. 12. 1980: 48 FR 14294.
Apr. 1. 1983]
9 261.31  Hazardous wattes from non-specific sources.
mduMry and EPA hazardous)
Generic
F001
F002
F003 	
FOO4
FOOS 	 	

FOOS

F019 	
FOOT 	

FOOS..
Fono>

F010 	
PQ11 	 	
F01Z_ 	

F024.... _ 	


Hazardoua wane

tncNoroemylene, memytens chloride. 1,1,1-lncnioroethane. caroon tetracltionda.
and cnkxinaiad fluorocarbons. and sludge* from the recovery of mese solvents m
degreaamg operations.
The louowmg spent halogenated solvents. latracntoroetnyMne methyiene chloride
incnioroetnvlena. t.i.i-incnuxoetnane. ctuorobenzene. 1.t.2-tnchloro-1.2.2-tnfluor-
oemane, orfftodicMorooenzene. and tnchlorofkjoromemane; and the sou bottoms
from me recovery ol these solvents.
Benzene. »myl ether, metnyl isoDulyl kalone. n-outyl alcohol, cydohexanone. and
memanot and the sun bonoms from ihe recovery at mese solvents.
nitrobenzene: and the still bonoms from the recovery at these solvents.

solvents.
loHowng processes: (1) suttunc aod anodomg ol Hummunr (2) tn plating on
carbon suet (3) one plating (segregated Oaaisl on carbon steel: (4) akjmmum or
anc-akimnum platng on caroon siaeh (5) cleaning/ skipping asaoaaMd witti bn.
aluminum.



wnere cyanides are used m me process (eicept lor preoous metals eMctropMlng
pMang bam skidgesl.

stripping and cleaning bam solutions).
cyandea are used n the process (except tor precious mataia heeltfeeeng
quenenjng bam sludges).
operations (except tor precious metals fteat treeing spent cyanide solutions from
sad bath pot cleaning).
cyarades are used m me process (except lor preoous metal* heat treating

rMCtor ctMfroui wawtM from the production ol cnkmnateW attpnatic hydrocar*
bons, hemng cartton conrtnt from ona to fiv*. uotemg fr*M radical catalyzad
procaaiai. [This Imtmg do»M not inchxJ* Itgm ends, soatit ftttart and ftltar aida.
wa«aa(mad«$26l.3Z]
Hazard
coda

CO


(I Tl




(Q T\




(R T)
(R T)





[48 FR 4617. Jan. 16. 1981. as amended at 46 FR 27477. May 20, 1981; 49 FR 5312. Feb. 10,
1984]
  EJTECTIVS DATS NOTE: At 49 FR 5312, Feb. 10. 1984. the waste stream Identified by EPA
hazardous waste no. P024 was added to the table In 5 261.31. eHecttve August 10, 1984.
                                   E-4

-------
Chapter I—Environmental Protection  Agency
                                                                                                  §261.32
S 261.32   Hazardous wastes from specific  sources.
industry and EPA hazardous
        waste No.
                                                        Hazardous waste
                                                                            Hazard
                                                                             code
Wood preservation. KOOI

Inorganic pigments:
  K002	
                           Bottom sediment sludge Irom the treatment ol wasiewaters trom  wood preserving
                             processes mat use creosote and/ or pentaehforopnenol.
                           Wastewsier  treatment sludge
                                                           the  production of  chrome yellow  and orange
                                                                                                      (T)
                                                                                                      m
  K003	  Wastewater treatment sludge from the production of motybdate orange pigment*	  (T)
  KOXM	  Wastewaler treatment sludge from the production of zinc yellow pigments	  (T)
  KOOS		  Wastewaler treatment sludge from the production of chrome green pigment*   .  .  .   (T)
  KOM	  Wastewaler treatment sludge from me production ol chrome oxide green pigments   (T)
                             (anhydrous and hydralad)
  K007 	  Wastawater treatment sludge from the production of iron blue pigments  	   (T)
  KOOS  	  Oven residue from me production of chrome and* green pigments	    (T)
Organic cnemcalK
  KOM	  OtsliUalion bottoms from me production of acelaldenyde from elhyiene   .  ...        (T)
  K010	   OistHlation side cuts from the production of acetaldenyae from einylene.       	.CO
  KO11  	  Bottom stream from the wastewater stnpper n me production of acrylonilnta.        j  (H. '
  K013  	    Bottom stream trom the aceioramie column in the production ol acryiontnle         !  (R. T)
  K014 	   Bottoms Irom me acatomtnle punficauon column in the production'of acryKxiunle.   ,  (T)
  KOIS    	       Sod bottoms Irom the distillation ol benzyl cnionde             ..     .       . . . |  (T)
  K016 	  Heavy ends or datdlation residues Irom the production ol carbon teiracfilonoe      j  (T)
  KOI 7  	    Heavy ends  HUH  bottoms)  Irom  the  purification  column  in the  production of   (T)
                             epicnioronydnn
  K018	   Heavy ends from me fractionation column m ethyl cnionde production   	(T)
  K019	  Heavy ends  from the  duttUanon of  afhvtene dtttvonde  m ediytene demand*   (T)
                             Production.
  K020	-		  Heevy ends  from the  Asouanon of  vinyl cnionde m  vmyl cnionde  monomer   (T)
                             production.
  K021	  Aqueous spent antimony catalyst waste Irom lluoromemanes production    	  (T)
  K022	  Otsouaoon bottom tars from the production of phenol/acetone from cumene	   (T)
  KOM		  ttsMlaBon bgm end* from the production of pmnakc anhydride from naphthalen*	  (T)
  K024	...		  emulation bottoms from me production ol pmnakc anhydride from naphthalene	  (T)
  KOM	-	  Distillation light ends from the production of pntnakc anhydride trom orthc-ryMne	  (T)
  KOM		—  OmNakon bottom* from me production of phtnakc anhydride Irom onno-iyMne	  (T)
  K02S		  OMkatnn bottoms trom me production of nitrobenzene by me nitration ol benzene...  (T)
  KOM	  Snipping sun tans trom me production of methy ethyl pyndxes	  (T)
  K027	  Centrifuge and dnaUalnn residue* from toluene dnocyenate production     	  (R. T)
  K02S 	  Spent catalyst from  the  hydrochtonnator reactor «  the production of 1.1.1-mentor-   (T)
                             oethane.
  KOM	  Waste trom the product steem sinpper m me production ol t.i.l-mcfiloroetnane	  (D
  KOM—	  Otwutation bottoms from me production of 1.1.1-tnchtoroeinane	  (T)
  KOM	  Heavy end*  from the heavy end* column from the  production of 1.1.1-tnchloroetn-   (T)
  K030.

  KOS3..
  K103..
  K104..
  KOM.
  K105..
                               I percMofoemylene.
                                          i front •VMetfw production
                                                                         production ol tncMoroediylene
  K071.

  K073..

  K10S.
  K031
  K032..
  K033..

  KQ34	


  K097	
Process residuee trom amkne extraction from me production of antne	—
Combined westewster stream* generated from rairooenzene/anien* production	
Oeunation or trac»onat>on column bottom* from m* production of cntorooenzene*	
Separated aqueous stream trom the reactor product washing step in me production
  ol cMorooeraene*.

Brine purification mud* trom the mercury eel proceas n cnkmne producBon. where
  ieperaiel» prepunfied bnne i* not used.
CMomatto:  hydrocarbon waste from the purification  step ol  the diaphragm  cell
  pfOCVM UflMQ QTBpfMW •nOOJeM M cMOfUW pTOdUeileiHi.
Waeteweler Ireetmenl sludge from the mercury cell precise in cMame production.—

ay-product sun generated In the production ol MSMA and ocodykc sod	
Wastewaler treatment sludge from m* production ol chtoraene.	
            and scruo water from me  chkmmnon  of
                            production of cfttoroane.
                           RNar soed* from the fWraoon  of heieOiWrocvciopentaaene  n the producton al
                          Vacuum  stnpper atecnarge from the cNordane cnwonaior n the produoon ol
  K03S...
  K036
  K037  .
  K038...
                          Wsiiewsier treatment sludge* generated m the production of creoaote	
                          Son bottom* from toluene reclamation dlstManon in me production of dauttoton.
                          Wastewaler treatment sludges from the production of Asuncion  	
                          Wasiewaler from the wesfung and stripping of phoral* production	
(T)

(T)

m

(T)
(T)
(T)

m

m

(T)
m
m
(T)
                                                   E-5

-------
 §261.33
   Title 40—Protection of Environment
Industry and EPA nsramoim
•MM No
K039 	
K040 . 	 	
K041 	
KMS 	
K042
KIMS 	
Ci plenum.
K044
KO45
K044

K047 	
PMroMufli rafinmg:
K048
K048 	
K050
K051 	
KOS2 	
Iran and suat
K061 	
K082 	
Svcondafy l*adr
KOW 	
K100 	 	 	 	
Vciamavy pfiaffnscauttcals?
K084
K101 	 	 	 	
K102
Ink MnnuMaore KOM
CMung:
Koeo 	 	 	 	
KM7 	

Hazardous waste

pnoraia



production ol 2.4.5-T
2.6-acnkxopn*nol vnsu Irom tn» production ol 2.4-O 	




Pmft/r«d water from TNT operations




Tank bottoms (leaded) from me petroleum refining industry .. .

furnace*.
Spent pickle hquor from steel (trashing operations

Wast* leaching lobbon from acx) leaching of emission conttol dust/sludge from
secondary lead smelong.
CMOcata from arasnc or organo-anMnc compounds.
Oitttaaon tar rmduaa from aw dnudmon of antm-busd compounds n m*
pounds.
vetennary prtamiacauocais from arsenic or organo-arsanic compounds.
Solvent wasrtaa and s*xidg*n, caustic washes and sludge* or water washes and
sludge* from ctaanng tubs and equipment used m the formuiabon of mtt from
AmmonM MH time studge from coking operation*. 	 	
Decanter tank tar ikjdge from coking operations

Hazard
code
cn
rn



m
m



ia\




(T)

(C T)

(T)
(n
m

(T)
(T)


C46 FR 4618, Jan. 16,1981, u amended at 46 FR 27476-27477, May 20. 1981]
9261.33  Discarded  commercial  chemical
    product!, off'tpeeification apeciea, con-
    tminer  residues,  and  ipill  residue*
    thereof.
  The following materials or Items are
hazardous wastes if and when they are
discarded  or intended to be discarded:
  (a) Any commercial chemical prod-
uct, or manufacturing chemical inter-
mediate   having  the   generic  name
listed In paragraph (e) or (f) of  this
section.
  (b) Any off-specification commercial
chemical  product  or  manufacturing
chemical intermediate which, if It met
specifications, would have the generic
name listed in paragraph (e) or (f) of
this section.
  (c) Any container or inner liner re-
moved from a container that has been
used to hold any commercial chemical
product or manufacturing chemical in-
termediate having  the generic names
listed in paragraph (e) of this section.
or any container  or  inner liner  re-
moved from a container that has been
used  to  hold  any   off-specification
chemical  product and manufacturing
chemical intermediate which. If it met
specifications, would have  the generic
name listed  In paragraph (e) of  this
section, unless the  container is empty
as defined in 5 261.7(b)<3) of this chap-
ter.

[Comment Unless the residue Is being bene-
ficially used or reused, or legitimately recy-
                                   E-6

-------
Chapter I—Environmental Protection Agoncy
                              §261.33
cled  or  reclaimed:  or  being  accumulated.
stored, transported or treated prior to such
use.  re-use, recycling or reclamation. EPA
considers the residue to be intended for dis-
card, and thus a hazardous waste. An exam-
ple of a legitimate  re-use of the residue
would be where the residue remains in the
container and the container is used to hold
the same commericat chemical  product or
manufacturing chemical product or manu-
facturing chemical intermediate  it previous-
ly held.  An example of the discard of the
residue would be where the drum is sent to
a drum reconditioner who reconditions the
drum but discards the residue.]

  (d) Any residue or contaminated soil.
water or other debris resulting from
the  cleanup of a spill into or on any
land  or  water of  any   commercial
chemical product or manufacturing
chemical intermediate having the ge-
neric name listed in paragraph  (e) or
(f) of this section, or any residue or
contaminated  soil,  water  or  other
debris resulting from the  cleanup of a
spill, into or on any land or water, of
any off-specification chemical product
and manufacturing chemical interme-
diate which,  if it met specifications,
would have the generic name listed in
paragraph (e) or (f) of this section.

[Comment The phrase "commercial chemi-
cal product or manufacturing chemical in-
termediate having the  generic name listed
In ..."  refers to  a  chemical substance
which Is manufactured or formulated for
commercial or  manufacturing  use  which
consists  of the commercially pure grade of
the chemical, any technical  grades  of the
chemical that  are produced  or  marketed.
and all formulations in which the chemical
Is the sole active Ingredient. It does not
refer to a material, such as a manufacturing
process waste, that contains any of the sub-
stances  listed  in paragraphs (e)  or (f).
Where a manufacturing process waste  Is
deemed to be a hazardous waste because It
contains a substance listed in paragraphs (e)
or (f). such waste will be listed in either
U 261.31 or M1J3 or will be  Identified as a
hazardous waste by the characteristics set
forth in Subpart C of this part.]

  (e) The  commercial chemical prod-
ucts, manufacturing chemical interme-
diates or off-specification commercial
chemical products  or manufacturing
chemical intermediates referred to in
paragraphs (a) through (d) of this sec-
tion, are identified as acute hazardous
wastes (H)  and are subject  to  be the
small quantity exclusion defined  in
§ 261.5(e).
[Comment For the convenience of the regu-
lated  community  the primary  hazardous
properties of these materials have been indi-
cated by the letters T (Toxicity), and R (Re-
activity).  Absence of a letter indicates that
the compound only is listed for acute toxici-
ty.]

  These wastes and their correspond-
ing EPA Hazardous Waste  Numbers
are:
Hmzaroou*
WMMNO.
P023..... 	

POS7 	
P058
P066. 	
P001 	
P002 	
P003 	
P070 	
P004 	
POOS. .- 	
P00» 	
P007
P008 	
P009 	
P119 	
P010 	
P012 	
P011 	 _ 	
P01 1 	
P012
POM 	
P054 	
P013 	
POZ4 	
P077 	
P04Z. 	
P014 	
P028 	
P01S 	 	
P016. 	 	
P017 	
P012 	 	
POZ1 	
P123 	 	
P022. 	
P02Z. 	 _.

P023 	
P024 	
P026. 	
P029. 	 „ 	
POM.. 	 „..
P031 	

P037 	
P03S 	
Subatanca
Acauudanyda. cntoro-

AcaunMa. 2-fluoro-
AcaumidK acid. N-l(m«nylc«f-
bamoylK»y]tnio-. mattiyl a*tar
3-(alpn»-Aceuxiy««nry(M-"y<»o«vcoum«nn
and sans, *nan prawM at concantrattora
graalar man 0.3%
l-Acaiyt-2-ttwuraa
Acrotem
AK»cart>
Aldnn
AMyt alcohol
Alumnum pflcapfuda
4-aAmmooyndma
Ammonium (xcrmla (R)
Arcane aod
Araanc (III) oada
Anarac (V) onda
Arsarac pantanda

Anna, dwny-
Annan*
aanzanamina. 4-cftom-
Banzanamna. 4-mtro-
1 2-SanzanadKH. 4-(1-flydroxy-2-
-------
§261.33
Title 40—Protection of Environment
Hazardous
waste No
P039. .
P041 .. . .
P040 	
P043 	
POM 	
P04S 	
P071 	
P082 .

P047 	
POM 	
P048 	
P020 	
P08S
P039.
P049. . . .
P109. . ..
POSO.
POM. .
POSt 	
P042
P046 	
P084 	
P101 	
POS4 	
P097 	
POS6 	
P057 	
POM
P06S 	
POSt 	
POS1 	


P037 	
POM 	
POM 	

POBO
P082. 	
POM. 	 _.._.
P063.._. 	 .
POM 	
P084 	 	
P007
P092,...~ 	
POM. 	
POH..~ 	
pna 	
P118. 	
POS9. 	
POM. 	
P087.
POM--

POM. 	
P071 	 .. 	
P07^ 	
P073 	
P074 	
Suoslance
0.0-Oiatnyl S-(2-(einylthK»etnylJ phospnoro-
Oiinioaie
Omnyl-p-nitropnenyl phosphate
O.O-Oietnyl O-pyrazmyl pnospnorothioaia
Dusopropyl Huorophosphale
Oimetnoaie
3.3-Oimetnyl-1-(metny«hio»-2.Dutanone. O-
[(mettiylamno(carOonyl] oiirrw
O.O-Onwtnyt 0-p-nlropnenyt pnospnoro-
ihoate
Ornaihylnlrosarnine

4,6-OmKro-o-aesc4 aod salts
4.8-O«nirc-i.4:i.aHinda. endo-dnwm- «n-
onapntnelene
1,2,3 4 10 10-HexecMorc-l 4 4a.5.8 8a-
hexanyiin> 1 ,4-.S.a-endo,eiip.


HyofUHM, fiMtfiyi^
Hydrocyanic add
Hydrogen cyanide
leWcysnic i&A, nwthyl Mivf
Mercury, (aceuic-OKinenyl-
Mercury fuknrats) (R.T)
MMnane, o«yt»a(cnloro-
Memaneanol. tnc«on>
4.7.Memeno-1H»ndene. 1 ,4,5,e,7,8.8-neB-
tacntoro-a«.4,7.7a-la«anydro-
2'Memyl40ndin«


2-Metnylla)Ctonrtrtl«
Methyl paratnion
aipna-Napnmyfmiouree
Nickel carDonyl
Nickel cyenide
Hazardous
waste No.
P074
P073
P075 ....
P078..
P077 ..
P078 	
P076 	
P078 	
P081 	
P082 	
POSO

P087 	
P087 	
POM. .
P089 .. .
P034
PQ48
P047
P02Q
P009 .
P036 .. ..
P092.
P093 	
P094
P095 	
P096 	
P041 	


P089


P110
POM 	
P099 	
P070 	 „ 	

*^'^* 	

poai
P017 	
P003 	
POOS 	
P102 	

P075 	

P103 	
P1Q4 	
P1QS 	 	
pi 06. 	 	
P107 	
P108
PQt8
P108 	
P11S
P10B 	
Su&sunce
NickeMM) cyanide
Nicket letracarconyl
Nwoiine and sails
Nitric oxide
p-Nitroanihne
Nilroqan dioxid*
Nitrog«n(ll) o»d«
Nnrog«n(IV) ond*
NMroglycanrw (HI
N-NiUOSodKiwmylamna

acnioro, cyckc sultit*
Osrraum ouM
OiiTHum telronda
7-OnaacycloC2.2.t lheptane-2.3-d>caiooxylic
acid
Paratnion
Phenol. 2-cycloneKyl-4,s-flV«tro-
Phanol, 2.4
eaur
(•ttyltniotmMliyt •««
Phoaolxiroihioa aad. 0 Q dutfuii O-OHHITO
pneoyl) ester
•SMI
>rwinylamnol-iullonyl)pnenylle*ter
PlumbairM, tetfaeihyt-
PotaaMum cyand*
Pousaium mm cyanide
Propanal. 2-m«nyt.2-(memyrtn>o»-. 0-



1 2,3>farepan*Mnot tnnrtraH*> (H)
2-Propanoiw, 1-Oromo-
2-Prapevul
2-Prop«vt-ol
2-Propyn-l-ol

Pyndrw, (3>-3-vnt>t.t»ny1)-l and
uttt
Sannounn
aiver cyanide
Sodumtzide
Sodwmcyarade
Slronoum suKtde
Sttyetirwin-lO^jrw. and satta
Stiycnndm-tO-on*. 2,3-dnwamy-
Strycnrww and salts
Sultwic acid. tn*ttum(l) salt
TetrMtnykMnnoyropnoaptwa)
                                E-8

-------
Chapter I—Environmental Protection Agency
                                                                     § 261.33
 Hazardous
 wana No.
P110 ..
P111 ...
P112	
P062...
P113	
P113.	
P114	
P11S.	
P04S.	
P049.	
P014	
P116.	
P028	
P072	
P093	
P123	
P118	
P119	
P120	
P120	
PO01	

P121 .
P122,	
             SuDatanca
TetrMtnyl lead
Tettaeinylpyropnaapnale
Tetrantromatnina (R)
Tatrapnoaononc aad, twuetnyi ester
Thattconde
Tha»um(NI| onde
Thnwaa. (2-cnkmpnanyl)-
Thnuraa. 1-napnmalenyl
Thouraa. pnanyt-
Toxapnane
Tnchtorofliethaneihnl
Vanaacaod. arnmonum salt
Vanadwm pentonde
VanaduiKV) and*
Wanann.  often  preaent at  concentrations
  9ieaia> man 03%
Zmccyarade
Zinc pnoapmde. wnen preaent at concentra-
  tions greater man 10%
  (f) The commercial chemical prod-
ucts, manufacturing chemical interme-
diates, or off-specification commercial
chemical products referred to in para-
graphs (a) through (d) of this section,
are  identified  as  toxic  wastes  (T)
unless otherwise designated  and are
subject to the small quantity exclusion
defined in §  261.5 (a) and (f).

[Comment; For the convenience of the regu-
lated community, the  primary  hazardous
properties of these materials have been indi-
cated by  the  letters T (Toxicity). R (Reac-
tivity).  I  (Ignitamlity)  and C (Corrosivity).
Absence of a  letter indicates that the com-
pound is only listed for toxicity.]

  These  wastes and their correspond-
ing EPA  Hazardous  Waste  Numbers
are:
 w«
U001 	
U034	
U187 	
UOOS	
U112	
U144	
UZ14	
U002	
U003	
U248 	
U004
UOOS
AcaukMhyda (I)
AcataJdaflyda. cicnloro-
        N44-e
mathyl-
Senzenanune. 4-cnloro-2-matriy|.
Banzanamna. 4.4'-matnyleneDia(2-cnioro-
Banzenannna. 2-matnyl-. nydrccnkxida
Banzenamna. 2-metHyl-5-nitro
Benzene (I.T)
Senzeneacetic aad. 4-cn4orc-«lqna-(4-cniorc-
pnenyll-alpna-nydroiy, alnyl auar
Benzene, chloro*
1 2-8eniBna<»cart)Oxvtic aad annydnde
1.2-aenzenaacartwxylic aad. [N»<2-«myt-
heiryl)] eMer
l,2-8enzenedicartx)«ylw aad. cnbucyl eater
t.2-8enzenedicaraoiylic aad. dwtriy! eater
< ,2-SenzenaOicarboiyiic aad, amwmyl ester
Seiuene. t.2-dicnlon>
Benzene. t.3-d>cnlorc-
Benzene, 1 ,4^]icftlorc-
Senzene. (dKruoromeinyl)-
8«nz*xw dHTMttiyH' T)
B«nzen«, hwtactiloro-
3eWiZ4W, htnuttvf&o* (I)
BWIZWM, hydroxy*



Benzene. (1-me«iyletnyl)- (1)

Benzene. pantacnldn>nilR>
Benzanaaullonyt ctuonda (C.R)
Benzene. 1 .2.4,S-letraentoro-
Banzane. (tncniOfOmemvl)-(C.H.T)
Benzene. 1.3,5-lnmtro- (R.T)
Bwindma
1,2 8«nnsomcazc*n.3-ona. 1.1-dioiida
BenzoC|.k]lluorana
Banzolajpyrena
3.4-Banzopyrane
p-Sanzoqunona
                                         E-9

-------
§261.33
Title 40—Protection of Environment
Hazardous
Waste No
U023 	
U050 . .. .
U085
U021 	
U073 	
UOfll 	
U095
U024 	
U027 	
U028 	 .'...
U248 	 _ 	
U22S 	
U030 	
U128 	
U172 ...
U03S .. . .
U031 .
U159 . .
U160 .
UOS3
U074 	
U031
U136 ....
U032 . ...
IJ3M 	
U178
U178..
U177 	
U219 	
U097 	
U21S 	
U1S« 	
U033 	
U211 	
0033
U034
uo35 	 :..
U038
U026 	
U037 	
U039 	
U041
U042 	
U044 	
U047
U048 	
J049
U032
UOSO 	
UOS1 ..._ 	
UOS2 	
UOS2 	
UOS3
UOSS 	

uosa 	
UOS7
U130 	
U056
U240 	
UOS9 	
UOM 	
U081 	
U06Z 	
U133 	
U221 	
Substance
SenzoincniofKM (C.R.T)
1 .2-Benzprienantncene
2.2*-BiO]arane (1 T1
( 1 , V -SipnenylM.*' -diamine
(1,1'-Bipnenyr)-4.4'-n«acnioro-
t-aulannmne. M-Outyl-N-nn/ojo-
Butanoc add. 4.(Bn(2-cnt«oaltvyi)aminol
benzene-
t-Butanol (1)
2-Sulanone (I,T)
2 Sularwne peroxide (R.T)
2-Bulenal
2.8ulene. 1 4^jicnkxo- (I.T)
n-8ulyl alcnonol (0
Cacocrylic acid
Calcium cnromate
CarBunc acid. etOyt mac
Carbarmc acid, mathylnivoso-. etnyt asiar
CarOannda. N-«myt-N-o(f05o-
Cafturmd*. N-mamyl-N.nitroao-
Caroamde. tno-
CarOamoyl cntonOa. dmwtftyt-
Careone aod, dMnaUwm(i) an
CaroonocMondK acid, memyl mar (I.T)
CarBon oxyfluonda (R.T)
Cafoon tanachionila
Carbonyl fluonda (n.T) '
Cnloral
CMonrnoucH
Chkydane, tactvucal
CMofnapnuna
CMoroOanzafta

2OMoro»Mf*y* vmyt eww
Chloroform

oCNorapnanol
4-Cnkxo-o-tok«c*na. nydmcnionda
Cfirorrac aod, calciurn salt
Ctwyiana
Cramota
CraaoM
Craaykcaod
Cumarwd)

CydorMMan* (1)
1,3-CydooMt.idMna. 1,2,3,4,5.5-h*n(.v chtoro-
2.44-0. sail* and attars
Oaunomyon
000
DOT
cydoOuta(c.d)-pantaMn-2^)na
Oiallaia
Ownma (R.T)
Otamnotoluana
Hazardous
Waste No
U063
U063
U064 . .. .
U064 	
U066 	
U089 	
U062
U070 	
U071 	
U072 	
U073 	
U074
U07S .. .
U192 	
U060 	
U081 ..
U078
U079 .. ..
U025
U081 . ..
U082
U240 	
U083
U084
U085 	
U108 	
U086
U088 	
U089
U148 	
U090 	
U091
U092 	
U093
U094 ... .

U097 	
U098 	
U099 	
U102 	
U1M 	
U105 	
U106
U107
utoa 	
U109 	
ui 10 	
U001 	
U087 	
U076 	
U077 	
U114 .
U131
U024 	
U003 	
UI117 	
U025 	
U184 	
U208 	
U209 	
U218 	
U247 	
U227 	
U043 	
Substance
Oioenzl a.n lanmracane
I 2 5.6-Oioenzantlvacene
1.2 7,S-CNtienzopyrene
Oibenzfa.ilpyrene
1 2-Oibrofno-3-chloropropane
Qoulyl pntnalata
c-Ownkxabanzena
m-Oichlorooenzene
p-Oicniorobenzene
3.3'-Oicnioroeenzidna
1 ,4-OwrUorc-2-bulana (I.T)
Otchloroditiuoromethane
3.5-Oicnl(x o-N-( 1 . 1 -dnwtnyl-2-prooynyl)
benzamda
Oicnioro dipnanyl dunioroetnana
Dicnloro dipnenyl tncMoroathane
t I -Oicnioroetnyiane
i 2-Oicnloroeirtyiene
Oichloroetrtvl etner
2. 4-Oicnioroprienol
2.6-Oicnioropnanol
2.4-Oicnioropnanoi
1 2-EmanarjryiTM<;amamo<*W<4te ac4
Ethane. 1,1,1,2,2,2-neiaenlorc-
Etharw. 1 . 1 '-ImalHytanabuXoicy)lBiat2-chloro-
Etnananiinla (1. T)
Ethane, l.r-oiyon- (I)
Etnana. l.l'4xydi*(2-cniore-
Ethanc. pentacftkxo-
etnana, 1.l.t.2-niracr*orc-
Ethana. V1.2.2.|aliacNorc-
Ethanetmoamida
Ethane, i,l,l.-lncny-
pnanyll.
Ethane. 1,1,2-lncntoro-
Ethana. cnkxo-
                                E-10

-------
Chapter I—EnvirennMntal Protection Agency
1261.33
Hazardous
Wast* No.
UO42 	
U078 	
U079 	
U210 	
U173 	
U004 	 _.
UOOt 	
U112 	
U113 	
UJ38 	
UO38 	 _;..
U114 	
U087 	
U077 	
U11S 	

U1I7 	
U078 	
U118
U119 	
U139 	
U120 	
UI22 	
UI23
U124 . ...
U125
U147 	
U213 	 	
U125
U124 	
U206 	
U128 	
U183
U127
U128 	
U129
U130 	
U131 	
U132
U243 	
U133 	
U088 	
UOM 	 	
UOM
U109
U134 	 >i_m_
U134 	 	
Ut3S 	
UOM 	
U136
U116
Ut37
Ut39 	
U140 	
U141 	
U142 	
U143 	 	
U144 	
U14S 	
U148 	 	
UI29 	
U147 	
U148 	
U149 	
uiso 	
U1SI 	 	
U152 	
U092 	
U029 ..
U045
U048
Sufiattiie* Waste No
Elnana. l.1-dK«oro-
Etnana. trana-i,2
Etnanot 2.2Mn*oaomno)b«>.
Ethanoyl cMond* (CAT)
Ethyl acatau (0
Ethyl aoylM (1)

EtfiyMnt dcMond*
Ethton* onda (I.T)
Ethyl emer (1)
Etnynnetnacrylate
Ethyl rnetnaneauNonatt
Fluor anmana
FofmefdeAyda
Forme aod (C.T1
Furan (1)
2.S-funndnna
Furan. lavanydn-(l)
FuriuraMD
Furfuran (1)
O-Glucooyranoaa. 2-daoxy-2(3-ma
Mainanoill)
Matnapynlana
Mainoxycnkx
Mainyl alcohol (1)
Methyl DrorrMe
I Mainyibuladiene (1)
Matnyl cnionoa (i.T)
Mainyl cniorocaroonate (I.T)
Metnylcniorolorm
3-Mainylcrmaninrene
4.4 -Melhywnacxs<2-cni(XoapiUnal
2.2'-MemyianaO»(3.4,e-tncnloropnanol)
Maihylan* arorrada

Mainyl ethyl kaiona (I.T)
Matnyl ethyl kaiona paronda (R.T)
Matnyl odKJa
Matnyl isodulyl kaiona (1)
Mainyl mamacrylaia (I.T)
4.Mathyi-2-panunona (1)
MainvUNouraol
Mrtofnyctn C
S.12-Napninacamdiona. (8S-osHd-acatyl-tO-
( (3-amno-2,3.B-tndeon;-alpn*-l.-lyxo-
haiopyranoaylKuy'1-7.8.9. 10-latranydro-
8.8. 11 •tnnydroxy- 1 -niamaiy-
Napntnalan*
NapntnaMne, 2-cnloro-

mathyl-( 1 , 1 •-bipnanylM.4'oW]-oia
salt
1.4,Napnmaquinona
1-Napntnylansna
2-Napntnylamina
iipna-Napntnyta/nme

Nitrooanzana (I.T)
p-Nitropnanol
2-NHroprapana (1)
N-Nitrosoawvoulylarrena
N-Niiroaooiatnyiamina
N-Nilroio-N-propylamma
N-Nitro»o-N-amyturaa
N-Nnroso-N-metnyiuraa
N-Nitroao-N-matftyluramana

5-Nnro-o-toiuidina
1.2-Oxainiolane. 2.2-dnnde
2H-i.3.2-O>azapnospnonrw. 2-{bis(2-cnioro-
airtyDammoltairanydro-. ouoa 2-
Oarane (I.T)
                               E-ll

-------
§261.33
                                              Title 40— Protection of Environment
 Hazardous
 Wasta No
               Suostanca
            ! Owrana. 2-ene
Phospnonc acid. Lead sail
PN»pnoroditnio«  aod, 0,0--,  pnoaqnata (3:1)
1-Propano(. Z3-«ooJiy-
t -Propane!, 2-m«myt-  (!,T)
2-Propanon* (I)
2* PTOQ^O tttmi9                         a
PrepafM. 1.3-dKtNoro-
t-PrapatM. 1.1.2,3.3.3-n«iacfitoro-
2-ProparwiMnM
2-PtapananMiiU). 2-mattiyl- (I.T)
2-Propaooc acid (I)
2-Propano« add. ainyl eslec (I)
2-PrapanoK aoo. 2-m»inyt-. atfiyl mtar
2-Prooanoc aod. 2-m«tny(-, mainyl aaiar (I.T)
Propane aod, 2-R4,5-tncnioropr*anoiy)-
rvPrapylamn* (I.T)
Propytao* acMonaa
Hazardous
Wasta No
U205
U232 .
U207 	
U208 . .. .
U209
U210 	
U212 	
U213 	
U214 	
U21S 	
U21S
UZ17 	
U218 . .
U153.
U219 . .
U244 ..
U220
U221
U223
Substanca
Sullur salemda (R.T)
2.4.5-T
1 .2.4,S-Tatracniorooanzana
1.1.1 .2-Ta(racnianMtnana
1 . 1 .2.2-Taffacnioroainana
Tavacnioroathylana
2.3.4.8-Talracnioropnanol
Talrarrydrofuran (1)
ThaikurrKI) acatata
ThalkunXO carOonata
ThalaunKl) cfuonda
Thailium
4.4'-SlHb*rwdnt. ajpha.alpna'-dwtnyl-
Streotozotocin
Sulfur hydnda
Sultunc acid, dvnattyl aaiar
Sullur pnoaprwM (H)
                                                       [45  PR  78529.  78541.  Nov.  25.   1980.  as
                                                       amended at 48  PR 27477. May  20. 1981: 49
                                                       FR  19923. May 10. 1984]
                                                 E-12

-------
                    APPENDIX F

HAZARDOUS CONSTITUENTS  (40  CFR  261, APPENDIX VIII)
  The content of  this Appendix was  reproduced
  from the Code of Federal Regulations  of  July
  1,  1984.  Users  should check the current ver-
  sion of the Code of  Federal Regulations and
  more recent issues  of  the Fe"deral Register for
  amendments.

-------
      APPENDIX VIII— HAZARDOUS
AcetonitrUe (Ethanenitrile)
Acetophenone (Ethanone, 1-phenyl)
3-< alpha- AcetonyibenzylM-
  hydroxycoumarin and salts (Warfarin)
2-Acetylaminofluorene (Acetamide. N-OH-
  fluoren-2-yl)-)
Acetyl chloride (Ethanoyl chloride)
l-Acetyl-2-thiourea   (Acetamide,  N-(amin-
  othioxomethyl)-)
Acrolein (2-Propenal)
Acrylamide (2-Propenamide)
Acrylonltrile (2-Propenenitrile>
Aflatoxins
Aldrin           ( 1,2,3.4.10.10-Hexachloro-
  1.4.4a.5.8.8a.8b-hexahydro-endo,exo-
  M:5,8-Dlmethanonaphthalene)
Allyl alcohol (2-Propen-l-ol)
Aluminum phosphide
4-Aminobiphenyl ( C l.l'-Biphenyl]-4-amlne)
S-Amino-l.la,2.8,8tt,8b-hexahydro-a-
  ( hydroxymethy 1 )-8a-methoxy-5-methyl-
  carbamate     azirinoC2'.3>:3.41pyrrolo(1.2-
  a]lndole-4.7-dlone.  (ester) (Mltomycin C)
  :3.4]pyrroioU.2-a)lndole-4,7-
  dione,               8-amlno-8-C((amino-
  carbonyl)oxy imethyU- 1, la.2.8.8a,8b-
  hexahydro-8amethoxy-S-methy- )
5-
-------
 Part 261, App. VIII
   Title 40—Protection of Environment
 Arsenic and compounds. N.O.S.*
 Arsenic acid (Orthoarsenic acid)
 Arsenic pentoxide (Arsenic (V) oxide)
 Arsenic trioxide (Arsenic (III) oxide)
 Auramme        (Benzenamme.        4,4'-
  carbonimidoylbislN.N-Dimethyl-,   mono-
  hydrochloride)
 Azaserine    ether  (Ethane.   1.1'-
  oxybis(2-chloro-])
 N,N-Bls<2-chloroethyl)-2-naphthylatnine
  (Chlomaphazine)
 Bis(2-chloroisopropyl> ether (Propane.  2.2'•
  oxybist2-chloro-]>
 Bls(chloromethyl)     ether     (Methane.
  oxybtstchloro-])
 Bls<2-ethylhexyl)  phthalate (1,2-Benzenedi-
  carboxylic acid. bis(2-ethylhexyl) ester)
 Bromoacetone (2-Propanone. 1-bromo-)
 Bromomethane (Methyl bromide)
 4-Bromophenyl phenyl  ether  (Benzene.  1-
  bromo-4-phenoxy-)
 Brucine (Strychnidln-10-one. 2.3-dlmethoxy-
  )
 2-Butanone peroxide (Methyl ethyl ketone.
  peroxide)
Butyl benzyl  phthalate  (1.2-Benzenedlcar-
  boxylic acid, butyl phenylmethyl ester)
 2-sec-ButyM,8-dlnitrophenol       (ONBP)
  (Phenol. 2,4-dlnitro-«-
2-Cyclohexyl-4.6-dinitrophenol  (Phenol.  2-
  cyclohexy 1-4,8-dinitro-)
Cyclophosphamide    (2H-1.3,2. -Oxazaphos-
  phorine,  Cbis(2-chloroethyl)amlno]-tetra-
  hydro-, 2-oxide)
Oaunomycin  (S.12-Naphthacenedione,  (8S-
  cis)-8-acetyl-10-[(3-amino-2.3.S-trideoxy)-
  alpha-L-lyxo-hexopyranosy Doxy 1-7.8.9,10-
  tetrahydro-6.8,ll-trihydroxy-l-methoxy-)
DDD    (Dichlorodiphenyldichloroethane)
  (Ethane,     l,l-dlchloro-2.2-bis(p-chloro-
  phenyl)-)
ODE (Ethylene,  l.l-dlchloro-2,2-bls(4-chlor-
  ophenyl)-)
DDT    (Dlchlorodiphenyltrichloroethane)
  (Ethane.    l.l.l-trichtoro-2.2-bis(D
-------
Chapter I—Environmental Protection Agency
                     Part 261, App. VIII
DibenzU.h]anthracene  (1,2.5.6-Dibenzanth-
  racene)
7H-DibenzoCc,g]carbazole(3.4.5,6-Dibenzcar-
  bazole)
DibenzoCa,e]pyrene(1.2,4.5-Dibenzpyrene)
DibenzoCa.h]pyrene (1.2,5,6-Dibenzpyrene)
DibenzoCajlpyrene (1,2,7,8-Dlbenzpyrene)
l,2-Dibromo-3-chloropropane (Propane. 1,2-
  dibromo-3-chloro-)
1,2-Dibromoethane (Ethylene dibromide)
Dibromomethane (Methylene bromide)
Di-n-butyl  phthalate (1,2-Benzenedicarbox-
  yllc acid,  dibutyl ester)
o-Dichlorobenzene (Benzene, 1,2-dlchloro-)
m-Dichlorobenzene (Benzene, 1,3-dichloro-)
p-Dlchlorobenzene (Benzene, 1,4-dichloro-)
Dichlorobenzene. N.OJS.* (Benzene,
  dichlorc-. N.O.S.')
3,3'-Dichlorobenzidine   <[l,l'-Biphenyl]-4,4'-
  diamine,  3,3'-dichloro-)
l,4-Dichloro-2-butene  (2-Butene,   1,4-dich-
  loro-)
Dichlorodinuoromethane  (Methane,  dich-
  lorodifluoro-)
1,1-Dichloroethane (Ethylidene dichloride)
1.2-Dichloroethane (Ethylene dichloride)
trans-1,2-Dichloroethene (1.2-Dtchloroethy-
  lene)
Dichloroethylene. N.O.S.*  (Ethene,  dich-
  loro-, N.O.S.')
1,1-Dichloroethylene (Ethene. 1,1-dichJoro-)
Dichloromethane (Methylene chloride)
2,4-Dichlorophenol (Phenol. 2,4-dichloro-)
2,6-Dichlorophenol (Phenol, 2.6-dichloro-)
2,4-Oichlorophenoxyacetic acid (2,4-D), salts
  and «sters (Acetic acid, 2,4-dichlorophen-
  oxy-, salts and esters)
Dichlorophenylarsine  (Phenyl  dichloroar-
  sine)
Dtchloropropane.  N.O.S.* (Propane,  dich-
  loro-, N.O.S.*)
1,2-Dichloropropane (Propylene dichloride)
Dichloropropanol, N.O.S.* (Propanol, dich-
  loro-, N.O.S.*)
Dlchloropropene,  N.O.S.' (Propene.  dich-
  loro-. N.O-S.')
1,3-Dichloropropene  (1-Propene.   1,3-dich-
  loro-)
Dieldrin (1.2,3,4,10.10-hexachloro-S,7-epoxy-
  l,4.4a,5,6,7,8,8a-octa-hydro-endo,exo-
  1,4:S,8-Olmethanonaphthalene)
l,2:3,4-Dlepoxybutane <2,2'-Bloxirane>
Dlethylarsine (Arsine, diethyl-)
N,N-Diethylhydrazine    (Hydrazine,    1.2-
  diethyl)
O,O-Diethyl S-methyl  ester of phosphoro-
  dithioic  acid  (Phosphorodithioic  acid.
  O.O-diethyl S-methyl ester
O.O-Diethylphosphoric   acid,   O-p-nitro-
  phenyl ester (Phosphoric acid, diethyl p-
  nitrophenyl ester)
Diethyl phthalate (1,2-Benzenedicarboxylic
  acid, diethyl ester)
O.O-Oiethyl  O-2-pyrazinyl   phosphoroth-
  ioate (Phosphorothioic acid, O.O-diethyl
  O-pyrazinyl ester
Diethy Istilbesterol        (4.4'-Stilbenediol.
  alpha.alpha-diethyl, bis(dihydrogen phos-
  phate, (E)->
Dihydrosafrole  (Benzene,   1,2-methylene-
  dioxy-4-propyl-)
3.4-Dihydroxy-alpha-( methy lamino )methyl
  benzyl  alcohol (1.2-Benzenediol,  4-U-hy-
  droxy-2-(methylamino )ethyU-)
Diisopropylfluorophosphate  (DPP)  (Phos-
  phorofluoridic  acid,   bis(l-methylethyl)
  ester)
Dlmethoate (Phosphorodithioic acid,  O.O-
  dimethyl  S-C2-(methylamino)-2-oxoethyU
  ester
3.3'-Dimethoxybenzidine   (Cl.l'-BlphenyU-
  4,4'diamine. 3-3'-dimethoxy-)
p-Oimethylamlnoazobenzene (Benzenamine.
  N,N-dimethyl-4-( phenylazo)-)
7.12-DlmethylbenzCalanthracene   (1.2-Ben-
  zanthracene, 7,12-dimethyl-)
3,3'-Dimethylbenzidine ((l.l'-BlphenylM.^-
  diamine. 3,3'-dimethyl->
Dimethylcarbamoyl   chloride  (Carbamoyl
  chloride, dimethyl-)
1.1-Dlmethylhydrazine  (Hydrazine.  1.1-di-
  methyl-)
1.2-Oimethylhydrazine  (Hydrazine.  1,2-di-
  methyl-)
3.3-Dimethyl-l-(methylthlo)-2-butanone, O-
  [(methylamino)   carbonyUoxime  (Thio-
  fanox)
alpha,alpha-Dlmethylphenethylamine  (Eth-
  anamine, l.l-dimethyl-2-phenyl-)
2.4-Olmethylphenol (Phenol, 2.4-dimethyl-)
Dimethyl phthalate (1,2-Benzenedicarboxy-
  lic acid, dimethyl ester)
Dimethyl sulfate  (Sulfuric  acid,  dimethyl
  ester)
Dinitrobenzene, N.O^.* (Benzene,  dinitro-,
  N.O.S.')
4,6-Dinitro-o-cresol  and  salts (Phenol, 2,4-
  dinitro-6-methyl-, and salts)
2.4-Dlnitrophenol (Phenol, 2,4-dinitro-)
2,4-Dlnitrotoluene  (Benzene, l-methyl-2,4-
  dinitro-)
2.6-Dinitrotoluene  (Benzene, l-methyl-2,8-
  dinitro-)
Di-n-octyl phthalate (1,2-Benzenedicarboxy-
  lic acid, dloctyl ester)
1.4-Dloxane (1.4-Diethylene oxide)
Diphenylamine (Benzenamine, N-phenyl-)
1,2-Diphenylhydrazine  (Hydrazine.   1,2-dl-
  phenyl-)
Di-n-propylnitrosamine (N-Nitroso-di-n-pro-
  pylamine)
Disulfoton        (O.O-diethyl        S-C2-
  (ethylthio)ethyl] phosphorodithioate)
2.4-Dithiobiuret (Thioimidodicarbonic dia-
  mide)
Endosulfan (5-Norbornene,  2,3-dimethanol.
  1,4,5,6,7,7-hexochloro-. cyclic sulfite)
Endrin and metabolites  (1,2,3,4.10.10-hex-
  achloro-6,7-epoxy-l,4.4a,5,6,7,8,8a-
  octahydro-endo.endo-1,4:5,8-
  dlmethanonaphthalene, and metabolites)
                                       F-5

-------
 Part 261, App. VIII
   Title 40—Protection of Environment
 Ethyl carbamate (Urethan) (Carbamic acid.
  ethyl ester)
 Ethyl cyanide (propanenitrile)
 Ethylenebisdithiocarbamic acid,  salts and
  esters  (1.2-Ethanedlylbiscarbainodithioic
  acid, salts and esters
 Ethyleneimine (Aziridine)
 Ethylene oxide (Oxirane)
 Ethylenethiourea (2-Imidazolidinethione)
 Ethyl methacrylate (2-Propenoic acid.  2-
  methyl-, ethyl ester)
 Ethyl methanesulfonate  (Methanesullonic
  acid, ethyl ester)
 Fluoranthene (Benzotj.kJfluorene)
 Fluorine
 2-Fluoroacetamide (Acetatnide, 2-fluoro->
 Fluoroacetic  acid, sodium salt (Acetic acid.
  fluoro-, sodium salt)
 Formaldehyde (Methylene oxide)
 Formic acid (Methanoic acid)
 Glycidylaldehyde (l-Propanol-2,3-epoxy)
 Halomethane, N.O.S.*
 Heptachlor        (4.7-Methano-lH-indene.
  l,4.5,6,7,8,8-heptachloro-3a.4,7,7a-
  tetrahydro-)
 Heptachlor   epoxide   (alpha,  beta,  and
  gamma isomers) (4,7-Methano-lH-indene,
  l,4.5,6,7.8,8-heptachloro-2,3-epoxy-3a,4,7,7-
  tetrahydro-, alpha, beta,  and gamma iso-
  mers)
 Hexachlorobenzene (Benzene, hexachloro-)
 Hexachlorobutadiene       (1.3-Butadiene,
  1,1,2.3.4,4-hexachloro-)
 Hexachlorocyclohexane (all isomers) (Lin-
  dane and isomers)
 Hexachlorocyclopentadiene  (1,3-Cyclopen-
  tadiene, 1,2,3.4.5.5-hexachloro-)
 Hexachloroethane (Ethane. 1,1,1.2.2,2-hex-
  achloro-)
 1.2,3,4,10,10-Hexachloro-1.4,4a,5,8,8a-
  hexahydro-l,4:5,8-endo,endo-
  dimethanonaphthalene (Hexachlorohexa-
  hydro-endo.endo-dimethanonaph thaiene)
 Hexachlorophene  (2.2'-Methylenebis(3,4.6-
  trichlorophenol))
Hexachloropropene (1-Propene.  1,1,2.3,3.3-
  hexachloro-)
Hexaethyl    tetraphosphate   (Tetraphos-
  phoric acid, hexaethyl ester)
 Hydrazine (Diamine)
Hydrocyanic acid (Hydrogen cyanide)
 Hydrofluoric acid (Hydrogen fluoride)
Hydrogen sulfide (Sulfur hydride)
 Hydroxydlmethylarsine oxide  (Cacodylic
  acid)
 Indeno(l;2,3-cd)pyrene           (1.KW1.2-
  pheny lene )py rene)
lodomethane (Methyl iodide)
Iron dextran (Ferric dextran)
Isocyanic add, methyl ester (Methyl iso-
  cyanate)
Isobutyl alcohol (1-Propanol, 2-methyl-)
Isosafrole (Benzene, l,2-methylenedioxy-4-
  allyl-)
Kepone  (Decachlorooctahydro-1.3,4-Meth-
  ano-2H-cyclobuta(cdlpentalen-2-one>
 Lasiocarpine (2-Butenoic acid,  2-methyl-. 7-
  C(2,3-dihydroxy-2-U-methoxyethyl)-3-
  methyl-1 -oxobutoxy )methy 1 ]-2,3,5,7a-
  tetrahydro-lH-pyrrolizin-1-yl  ester)
 Lead and compounds, N.O.S.*
 Lead acetate (Acetic acid, lead salt)
 Lead phosphate (Phosphoric acid, lead salt)
 Lead   subacetate   (Lead.    bis(acetato-
  O )tetrahydroxytri-)
 Maleic anhydride (2,5-Furandione)
 Maleic hydrazide (1.2-Dihydro-3,6-pyridazin-
  edione)
 Malononitrile (Propanedinitrile)
 Melphalan       (Alanine,       3-Cp-bis(2-
  chloroethyDamlnolphenyl-, L-)
 Mercury fulminate (Fulminic acid, mercury
  salt)
 Mercury and compounds, N.O.S.*
 Methacrylonitrile    (2-Propenenitrile.    2-
  methyl-)
 Methanethiol (Thiomethanol)
 Methapyrilene       (Pyridine,      2-C(2-
  dimethylamino)ethyl]-2-thenylamlno-)
 Methoimyl     (Acetimidic     acid,     N-
  [(methylcarbamoyDoxyHhlo-,     methyl
  ester
 Methoxychlor  (Ethane,  l,l,l-trichloro-2,2'-
  bis( p-methoxy pheny 1)-)
 2-Methylaziridine (1.2-Propylenimine)
 3-Methylcholanthrene
  (Benz[j]aceanthrylene,     1.2-dlhydro-3-
  methyl-)
 Methyl  chlorocarbonate (Carbonochloridlc
  acid, methyl ester)
 4,4'-Methylenebis(2-chloroaniline)  (Benzen-
  amine, 4,4'-methylenebis-<2-chloro-)
 Methyl ethyl ketone (MEK) (2-Butanone)
 Methyl hydrazine (Hydrazine, methyl-)
 2-Methyllactonitrile (Propanenitrile, 2-hy-
  droxy-2-methyl-)
 Methyl  methacrylate (2-Propenoic acid, 2-
  methyl-, methyl ester)
 Methyl methanesulfonate (Methanesulfonic
  acid, methyl ester)
 2-Methyl-2-(methylthio)proplonaldehyde-o-
  (methylcarbonyl) oxime  (Propanal,  2-
  methyl-2-(methylthio)-,                O-
  [(methylaminOcarbonynoxime)
 N-Methyl-N'-nitro-N-nitrosoguanidine (Gua-
  nidine, N-nitroso-N-methyl-N'-nitro-)
 Methyl parathlon (O,O-dimethyl O-(4-nltro-
  phenyl) phosphorothioate)
MethylthiouracU  (4-lH-Pyrimidinone,  2,3-
  dihydro-8-methyl-2-thioxo-)
Mustard gas (Sulfide, bis(2-chloroethyl)-)
Naphthalene
 1,4-Naphthoquinone     (1,4-Naphthalene-
  dione)
 1-Naphthylamine (alpha-Naphthylamine)
 2-Naphthylamine (beta-Naphthylamine)
 l-Naphthyl-2-thiourea (Thiourea, 1-naphth-
  alenyl-)
Nickel and compounds. N.O.S.*
Nickel carbonyl (Nickel tetracarbonyl)
Nickel cyanide (Nickel (II) cyanide)
                                      P-6

-------
Chapter I—Environmental Protection Agency
                     Part 261, App. VIII
Nicotine  and  salts  (Pyridine.  (S)-3-(l-
  methyl-2-pyrrolidinyl)-. and salts)
Nitric oxide (Nitrogen (II) oxide)
p-Nitroaniline (Benzenamine, 4-nitro-)
Nitrobenzine (Benzene, nitro-)
Nitrogen dioxide (Nitrogen (IV) oxide)
Nitrogen mustard and hydrochloride salt
  (Ethanamine. 2-chloro-. N-<2-chloroethyD-
  N-methyl-. and hydrochloride salt)
Nitrogen mustard N-Oxide and  hydrochlo-
  ride  salt  (Ethanamine.  2-chloro-, N-<2-
  chloroethyD-N-methyl-,  and  hydrochlo-
  ride salt)
Nitroglycerine   (1,2.3-Propanetriol,   trini-
  trate)
4-Nitrophenol (Phenol, 4-nitro-)
4-Nitroquinoline-l-oxide (Quinoline. 4-nltro-
  1-oxide-)
Nltrosamine, N.O.S.*
N-Nitrosodi-n-butylamine    (1-Butanamine,
  N-buty l-N-nitroso-)
N-Nitrosodiethanolamine   (Ethanol.  2,2'-
  (nitrosoimino )bis-)
N-Nitrosodiethylamine   (Ethanamine,   N-
  ethy l-N-nitroso-)
N-Nltrosodimethylamine (Dimethylnitrosa-
  mine)
N-Nitroso-N-ethylurea (Carbamide, N-ethyl-
  N-nltroso-)
N-Nitrosomethylethylamine  (Ethanamine,
  N-methy l-N-nitroso-)
N-Nltroso-N-methy lurea   (Carbamide,   N-
  methy l-N-nitroso-)
N-Nltroso-N-methy lurethane    (Carbamlc
  acid, methylnitroso-, ethyl ester)
N-Nitrosomethylvlnylamine  (Ethenamine,
  N-methy l-N-nitroso-)
N-Nltroaomorphollne (Morpholine, N-nitro-
  so-)
N-Nitrosonornlcotine (Nomicotine, N-
  nitroso-)
N-Nltrosoplperidine  (Pyridine,  hexahydro-,
  N-nitroso-)
Nitrosopyrrolidine (Pyrrole, tetrahydro-, N-
  nitroso-)
N-Nltrososarcosine (Sarcosine, N-nltroso-)
5-Nitro-o-toluldine (Benzenamine, 2-methyl-
  5-nitro-)
Octamethylpyrophosphoramide    (Diphos-
  phoramlde, octamethyl-)
Osmium tetroxide (Osmium (VIII) oxide)
7-OxabicycloC2.2.11heptane-2,3-dlcarboxyUc
  acid (Endothal)
Pmraldehyde   (1,3,5-Trloxane,    2,4,8-tri-
  methyl-)
Parathion   (Phosphorothlolc  acid,  O.O-
  dlethyl O-(p-nitrophenyl) ester
Pentachlorobenzene  (Benzene, pentachloro-
  )
Pentachloroethane (Ethane, pentachloro-)
Pentachloronltrobenzene (PCNB) (Benzene,
  pentachloronltro-)
Pentachlorophenol (Phenol, pentachloro-)
Phenacetln   (Acetamide.    N-<4-ethoxy-
  phenyl)-)
Phenol (Benzene, hydroxy-)
Phenylenedlamlne (Benzenediamine)
Phenylmercury acetate (Mercury, acetato-
  phenyl-)
N-Phenylthiourea (Thiourea, phenyl-)
Phosgene (Carbonyl chloride)
Phosphine (Hydrogen phosphide)
Phosphorodithioic  acid,   O.O-diethyl   S-
  [(ethylthio)methyll ester (Phorate)
Phosphorothioic acid, O.O-dimethyl  O-tp-
  Udimethylamino)sulfonyl)phenyU   ester
  (Famphur)
Phthalic acid esters, N.O.S.* (Benzene,  1,2-
  dicarboxylic acid, esters. N.O.S.*)
Phthalic anhydride  (1,2-Benzenedicarboxy-
  lic acid anhydride)
2-Picoline (Pyridine, 2-methyl-)
Polychlorlnated biphenyl, N.O.S.'
Potassium cyanide
Potassium silver cyanide (Argentate(l-), di-
  cyano-, potassium)
Pronamide  (3,5-Dichloro-N-< 1,1-dimethy 1-2-
  propyny 1 )benzamide)
1,3-Propane sultone (1,2-Oxathiolane, 2,2-dl-
  oxide)
n-Propylamme (1-Propanamine)
Propy Ithiouracil     (Undecamethylenedia-
  mine.   N,N'-bis(2-chlorobenzyl)-,   dlhy-
  drochloride)
2-Propyn-l-ol (Propargyl alcohol)
Pyridine
Reserpine   (Yohimban-16-carooxylic  acid,
  11.17-dimethoxy-18-[(3.4,5-
  trimethoxybenzoyl>oxy]-, methyl ester)
Resorcinol (1,3-Benzenedlol)
Saccharin and salts U,2-Benzoisothiazolin-3-
  one, 1,1-dloxide. and salts)
Saf role (Benzene, 1.2-methylenedloxy-4-
  allyl-)
Selenious acid (Selenium dioxide)
Selenium and compounds. N.O.S.*
Selenium sulfide (Sulfur selenide)
Selenourea (Carbamimldoselenoic acid)
Silver and compounds, N.O.S.'
Silver cyanide
Sodium cyanide
Streptozotocln  (D-Glucopyranose, 2-deoxy-
  2-( 3-methy 1-3-nitrosoureido)-)
Strontium sulfide
Strychnine  and salts (Strychnldln-10-one.
  and salts)
1,2,4,5-Tetrachlorobenzene       (Benzene,
  1.2.4.5-tetrachloro-)
2,3,7.8-Tetrachlorodibenzo-p-dioxln (TCDD)
  (Dlbenzo-p-dloxin, 2,3,7,a-tetrachloro-)
Tetrachloroethane, N.O.S.* (Ethane, tetra-
  chloro-. N.O.S.*)
1,1,1.2-Tetrachlorethane  (Ethane.   1.1,1.2-
  tetrachloro-)
1,1.2,2-Tetrachlorethane  (Ethane.   1.1,2,2-
  tetrachloro-)
Tetrachloroethane   (Ethene,  1.1.2,2-tetra-
  chloro-)
Tetrachloromethane (Carbon tetrachloride)
2,3,4,8,-Tetrachlorophenol  (Phenol,  2,3,4.6-
  tetrachloro-)
Tetraethyldithiopyrophosphate  (Dithiopyr-
  ophosphoric acid, tetraethyl-ester)
                                       F-7

-------
Part 261, App. VIII
   Title 40—Protection of Environment
Tetraethyl lead (Plumbane, tetraethyl-)
Tetraethylpyrophosphate (Pyrophosphoric
  acide, tetraethyl ester)
Tetranitromethane (Methane, tetranitro-)
Thallium and compounds. N.O.S.*
Thallic oxide (Thallium (III) oxide)
Thallium (I) acetate (Acetic acid, thallium
  (I) salt)
Thallium (I) carbonate (Carbonic acid, dith-
  allium (I) salt)
Thallium (I) chloride
Thallium (I) nitrate (Nitric add. thallium
  (I) salt)
Thallium selenite
Thallium (I) sulfate (Sulfuric acid, thallium
  (I) salt)
Thloacetamide (Ethanethioamide)
Thiosemlcarbazide   (Hydrazinecarbothioa-
  mide)
Thlourea (Carbamide thio-)
Thiuram  (Bis(dimethylthiocarbamoyl)  di-
  sulfide)
Toluene (Benzene, methyl-)
Toluenediamine (Oiaminotoiuene)
o-Toluidine  hydrochloride (Benzenamine. 2-
  methyl-. hydrochloride)
Tolylene diisocyanate (Benzene. 1,3-diiso-
  cyanatomethyl-)
Toxaphene (Camphene. octachloro-)
Tribromomethane (Bromoform)
1,2,4-Trichlorooenzene (Benzene, 1.2.4-trich-
  loro-)
1.1,1-Trichloroethane (Methyl chloroform)
1.1,2-Trichloroethane  (Ethane,  1,1,2-trich-
  loro-)
Trichloroethene (Trichloroethylene)
Trichloromethanethiol      (Methanethiol.
  trichloro-)
Trichloromonofluoromethane    (Methane,
  trichlorofluoro-)
2,4.5-Trichlorophenol  (Phenol.  2.4,5-trtch-
  loro-)
2.4.6-Trichlorophenol  (Phenol,  2,4.6-trtch-
  loro-)
2,4,5-Trichlorophenoxyacetlc  acid (2.4.5-T)
  (Acetic acid. 2.4,5-trichlorophenoxy-)
2,4,5-Trichlorophenoxyproplonic acid (2,4,5-
  TP)  (Silvex) (Propionoic  acid, 2-(2,4,5-
  trichlorophenoxy)-)
Trichloropropane, N.O.S.*  (Propane, trich-
  loro-, N.O.S.*>
1.2.3-Trichloropropane (Propane, 1,2,3-trich-
  loro-)
O.O.O-Triethyl   phosphorothioate   (Phoo-
  phorothioic acid. O.O.O-trlethyl ester)
sym-Trinitrobenzene  (Benzene,  1,3.5-trinl-
  tro-)
Tris(l-azridinyl)  phosphine sulflde  (Phos-
  phine sulfIde, triad-aziridinyl-)
Tris(2.3-dibromopropyl)  phosphate (1-Pro-
  panol, 2,3-dibromo-, phosphate)
Trypan   blue   (2.7-Naphthalenedisulfonic
  acid,    S.S'-CO.S'-dimethyK l.r-biphenyl)-
  4.4<-diyl)bis(azo)]bis(S-amino-4-hydroxy-.
  tetrasodium salt)
Uracil    mustard    (Uracil    5-Cbis(2-
  chloroethyDamino]-)
Vanadic  acid, ammonium salt (ammonium
  vanadate)
Vanadium pentoxide (Vanadium (V) oxide)
Vinyl chloride (Ethene, chloro-)
Zinc cyanide
Zinc phosphide

[46 PR 27477. May  20. 1981;  46 PR 29708.
June 3,1981; 49 PR 5312. Feb. 10.1984]
  EFFECTIVE DATE NOTE At 49 PR 5312. Feb.
10, 1984. the entries for 2-Chloro-l, 3-butadi-
ene  (cnloroprene),  and  3-Chloropropene
(allyl chloride), were added to the table in
Part  261. App.  VTII, effective August  10.
1984.
                                      F-8

-------
            APPENDIX G




HOW TO USE  A  RANDOM NUMBER TABLE

-------
                 How to Use a Random Number  Table
     The sampling procedure  for  contained wastes  that  is .described
in Section 7 of the Manual requires you  to select sampling points
using a random number  table.  This  Appendix gives the general
procedure for using such a table, which can be found in almost any
statistical text or handbook.

     The general problem  is to select a sample of n members (such
as grid points to be  sampled)  from a population  of N members  (such
as the total number of points  in the grid).  Below we  present a
"single-stage" method  of drawing  such a  sample.   Other methods
provide somewhat greater assurance of randomness, but  at the cost
of additional complexity.  The method is as  follows:

     1. Decide upon an arbitrary rule for selecting entries from
        the table.   You might  want to choose the  second row in the
        first column,  the  third  row in  the second column, and so
        on,  or every kth number.

     2. Number your unive'rse from 1 to  N.  If N has three digits,
        the first number in your universe would be 001, and so
        forth.

     3. The number of digits in  each random  number in the table
        may exceed the number  of  digits  in N.   If so,  decide upon
        an arbitrary  rule  to select from each  random number in the
        table another number with the correct  number of digits.
        For example,  if the  table is made up of  five-digit numbers
        and N has three digits, you could use  the first three of
        each random number,  or digits 1-3-5, or  2-3-4, or any
        three-digit set.

     4. Construct a list of  n  random numbers using the rules  in Steps
        1 and 3 above.  This list will then constitute a random
        sample of the  set  N.

     5. If you exhaust the table before  n random numbers have been
        drawn, start at a  new place near the beginning of the
        table and continue as  before.

     An alternative to the manual process described above is to
use the random number function RANDOM that  is  contained in the
BASIC software on most microcomputers.
                              G-3

-------
                    APPENDIX  H




TYPICAL PRICES FOR HAZARDOUS  WASTE TEST PROCEDURES

-------
        TYPICAL PRICES FOR HAZARDOUS WASTE TEST PROCEDURES
     The prices given below are based chiefly on a survey of
testing laboratories that was conducted by Industrial Economics,
Inc.  (lEc)  in  the  course  of  its  work  for  the  Office  of Solid
Waste.   The prices are current as of the spring of 1984.   In two
cases (Ignitability and Corrosivity), figures missing from the lEc
survey were supplied by telephone calls to laboratories  in the New
England region.  The figures are indicative of unit prices charged
for small numbers of samples.  Runs involving large numbers of
samples would  receive price discounts.
                                                      Pr ice
Test Method                               	    ($ per sample)
Ignitability                                         25 - 60

Corrosivity

     pH   '                                              5
     Steel corrosion test                            75 - 200

EP Toxicity

     Extraction procedure                        .   100 - 150

     8 SDWA metals                                  145 - 475
     Pesticides analysis                            125 - 215
     Herbicides analysis                            150 - 270
     Cyanide  (with separate extraction procedure)      100

Oily Waste EP Toxicity

     Extraction procedure plus 8 SDWA metals           750

Total Organic Carbon

     Non-standard matrix  (solid, sludge)             20 - 65
     Standard matrix (wastewater)                    20 - 60

Total Oil and Grease

     Non-standard matrix                             16 - 75
     Standard matrix                                 16 - 70
                              H-3

-------
Test Method
($  per  sample)
Total Metals

     Digestion

          Non-standard matrix
          Standard matrix

     Metals analysis

          As:  furnace
          3a:  furnace
          Cd:  furnace
          Hex  Cr:  colorimetric
          Cr :  furnace
          Pb:  furnace
          Hg :  cold-vapor
          Ag :  furnace
          Ni:  furnace

     8 SDWA metals
     13 priority pollutant metals
    10  -  25
     0-15
    10
    10
    10
    15
    10
    10
    15
    10
    10
20
20
20
30
20
20
30
20
20
      200
   200  -  250
Organic Analyses

     Sample preparation

          Solid, sludge

     Extraord inary preparation/cleanup

          Refinery organics in sludge
          Appendix VIII consituents in sludge
     0-40
   100
   100
500
1500
Gas Chromatography

     Halogenated volatile organics                   80 - 120
     Non-halogenated volatile organics               80 - 120
     Aromatic volatile organics                      80 - 120
     Polychlorinated biphenyls                      150 - 180
     Pesticides and PCBs, including fractionation   175 - 200
Gas Chromatogfaphy/Mass Spectrometry

     Volatile organics

          Priority pollutants
          Appendix VIII constituents
   170  - 240
      450
                              H-4

-------
Test Method                             	  ($ per sample)
     Acid extractables

          Priority pollutants                       200 - 250
          Appendix VIII constituents                   500

     Base/neutral extractables

          Priority pollutants                       250 - 400
          Appendix VIII constituents                   650
                              H-5

-------
                  APPENDIX I

        EXAMPLES OF DELISTING PETITIONS


The following types of wastes are represented:

         •  Inorganic wastes
         •  Organic wastes

A complete petition is presented for the former;
excerpts are given for the latter.  For the other
two major types of facilities — petroleum
refineries and multiple waste treatment facilities
— there is too much variability from petition to
petition to construct representative examples.

The information contained in the Inorganics exam-
ple is based on an actual petition submitted by
Texas Instruments, Inc. of Dallas, TX.   Names of
people have been altered, and some of the content
has been changed for the purpose of providing a
more general illustration.

-------
                INORGANIC WASTESTREAM



                    OPTIONAL FORM:

         DELISTING PETITION FOR WASTE STREAM

F006: Wastewater treatment sludges from electroplating
      processes
                    Submitted by:

                 ABC INDUSTRIES, INC.
                 120 Smith Lane
                 Dallas, TX  75266
                        Date:

                  December 12, 1982
                        1-3

-------
           SECTION A:  Administrative Data and Summary
1.
2.
3.
Name [260.20(b)(1)]

   a.  Name of firm:
                             ABC Industries, Inc.
       b.   Address of firm:  Street:

                             City:

                             State:

       c.   RCRA Generator ID Number:
                                    120 Smith Lane
                                    Dallas
                                    Texas
Zip:
75226
                                    TXD000567890
Facility Location [260.20(b)(1)]

   a.  Name of facility:    Long Horn Avenue Site
       b.   Location of facility:  Street:

                                  City:

                                  State:
                                        5 Long Horn Avenue
                                        Dallas
                                        TX
   Zip:  75266
Name(s) of personnel to be contacted for additional informa-
tion pertaining to this petition:
          Name
    Frederick Lewis

    Susan Smith
    Thomas Roberts
    Joseph Kale
                            Title


                      Mgr, Process Eng.

                      Process Engineer

                      Engineering Analyst

                      Mgr, Anal. Svcs Div
                      Green Laboratories
       Telephone


(214) 555-5555

(214) 555-5555

(214) 555-5555
(214) 555-5555
                              1-5

-------
4.  Description and Justification for the Proposed Action

    Please describe briefly the proposed delisting action,  why it
    is needed,  and how it will affect your operation.  Describe
    why you believe that the waste stream of concern (a) is not
    hazardous for the reasons it was originally listed and (b)
    contains no other constituents or characteristics that render
    it hazardous as defined in 40 CFR 261. [260.20(b)(2), (3) and
    (4)]

     This petition seeks to exclude from regulation under Subpart D of
40 CFR Part 261 a waste stream that is generated at a metal finishing
shop at the ABC Industries Manufacturing Facility at Long Horn Avenue in
Dallas, TX.  The waste stream is EPA HW Code F006, Wastewater Treatment
Sludges from Electroplating Operations.  This action is needed because
the disposal of these materials as a hazardous waste imposes an unneces-
sary burden on the petitioner, if indeed these materials are non-hazar-
dous as defined by  40 CFR 261.  Thif action will affect only the waste
stream generated at the metal finishing shop of the above-mentioned
facility.

     Testing of the sludges in question indicates that:  (a) the leachate
from the sludge does not exceed the EP Toxicity Limits shown in Table 1,
Section 261.24; (b) it does not contain appreciable amounts of the
constituents for which it was listed as hazardous (as given in Part 263,
Appendix VII); and (c) it contains no other constituents that would
render it hazardous as defined in 40 CFR 261.

5.  Certification of Accuracy and Responsibility  [260.22(i)(12) ]

    I certify under penalty of law that I have personally examined
    and am familiar with the information submitted in this  demon-
    stration  and  all attached documents,  and that based  on  my
    inquiry  of those individuals immediately responsible for  ob-
    taining the information, I believe that the submitted informa-
    tion is true,  accurate,  and complete.  I am aware  that there
    are  significant  penalties for submitting false   information,
    including the possibility of fine and imprisonment.
                  Frederick Lewis         ~L»i At  J  I
                  VP for Operations        1/ILKJ*^L*  (~~4^L*-^
                                         Waste Generator, Title or
                                         Authorized Representative*
                                         of Waste Generator, Title
      *Note:  An  "authorized representative" is a person   respon-
       sible  for  the  overall operation of a facility or an opera-
       tional uni:E^H4pr  example,  a plant manager, superintendent,
       or  person  of equivalent  responsibility).  Consultants  or
       other  outside  parties may  not  sign the  certification state-
       ment.
                               1-6

-------
                 SECTION B:   Production Processes
1.   Description of Manufacturing  Processes  and  Other  Operations
    L260.22(i)(5)].

    a.   Please provide a brief description of the on-site
        manufacturing/generating  process(es)  that produce  the
        waste stream.   Include descriptions of  major  equipment
        items and production lines.   Also,  describe the stages of
        the typical operating cycle on a daily,  weekly, or other
        basis as  appropriate.


     The on-site processes that produce the waste stream are from  metal
finishing operations that are outlined in (b) below.
    b.  Please provide a description of all surface and equipment
        preparation,  cleaning, degreasing,  coating or painting
        processes used in your facility that you have not de-
        scribed in (a) above.  (See Attachment I)

1.  Chromate conversion coating of aluminum / MIL-C-5541
2.  Passivation of corrosion resistant steels / QQ-P-35 Types II,IV,V
3.  Anodizing of aluminum alloy parts / MIL-A-8625
4.  Phosphatizing, light, iron
5.  Cadmium plate*
6.  Cyanide copper plate*
7.  Sulfamate nickel
8.  Electroless nickel plate
9.  Woods nickel strike
10. Tin plate*
11. Various cleaning of oils and coolants from machinery

*NOTES:

All of the above process solutions are followed by one or more water
rinse tanks which also pass through the treatment facility.

All pretreatments  for plating operations use the same cleaning steps
as alodine, anodize, or passivate, and are therefore not listed
separately.


    c.  Attach a schematic diagram of all manufacturing processes,
        surface~~p^eparation, cleaning, and other operations that
        may provide influent  into the waste  stream.

                   (See Attachment I)


                              1-7

-------
                       ATTACHMENT I


                       Process Flow
                 TEXAS INSTRUMENTS/LEMMON AVENUE
                            RECEIVE
                         RAW MATERIAL
MACHINING

MILL
GRIND
LATHE
TAPPING
     HEAT TREATING •*-
CLEAN/SURFACE PREP*

SANDBLAST
PARTS WASH
PAINT
INSPECT/
  SHIPMENT
METAL JOINING

  DIP BRAZE
  BONDING
                                               PLATING/CHEMICAL FINISH*
                                               SYMBOLIZATION
* WATER USED IN THESE TWO OPERATIONS IS THE ONLY WATER PROCESSED THROUGH
  WASTE TREATMENT.
                               1-8

-------
2.   Materials  Used  or  Produced

        You may comply with  the requirements for additional
        information in either of two ways; see Section 4 of the
        Guidance Manual for  a detailed description of the two
        approaches.
    Approach  A;

    a.   List  all materials used or produced in the manufacturing
        or other process  generating the waste stream(s) of con-
        cern.  Use the correct chemical name wherever possible.
        Include  materials such  as:

                    Raw materials
                    Intermediate products
                    By-products
                    Products
                    Oils  and hydraulic fluids
                    Surface preparation materials
                      (solvents, acids, cleaners, surface
                     preparation  agents, paints, etc.)
        Also:

        •  For each  material on the list, indicate whether it is
           discharged to or likely to be present in the waste, and
           the estimated  amount entering the waste stream annual-
           ly.  (Specify  kilograms, pounds, or similar  units.)
           Describe  your  estimation method.
           For each material on the list that you do not expect to
           be  present  in the  waste, give supporting reasons for
           this  expectation.  Supporting reasons may include mass
           balance  and process  information.  gEE
           Attach Materials  Safety Data Sheets (MSDS)  for  all
           materials  that  are  identified by trade or generic name
           only and that are discharged into or likely to be
           present  in the  waste  stream.
                                             Estimated Amount
                       Material             Entering the Waste
                                             Stream Annually

          Sodium Hydroxide _       6 kg _

          Sodium cyanide _      .5  " _
          Sodium dichromate                      .5
          Sodium carbonate                       none
            (Continue on additional sheets as necessary.)


                             1-9

-------
    Item (d) continued:
                                          Estimated Amount
                    Material             Entering the Waste
                                          Stream Annually


          Potassium dichrornate                   .5 kg
          Nickel metal                           40 "
          Nickel sulfamate                       32 "
          Liquid nickel chloride                 .6 "
          Nickel acetate                         .8 "
          Stannous sulfate                       .5 "
          Rochelle salt                         none
          Black dye                             none
          Acid phosphate salts                   20 "
          Cadmium oxide                          60 "
          Copper cyanide                         25
          Chromic acid                           12
          Hydrochloric acid                      30
          Boric acid                             12
          Oxalic acid                             8
          Nitric acid                            -5
          Sulfuric acid                          .5 "
          Chromic acid, flake                    .2 "
          Potassium  sulfate                      none
          SAE  90 gear lube                       none
          White grease                           none
          SAE  10W light oil   "                  none

              (MSDS's attached  for  the  following:)

          Ebonol C Special                      200  "
          Enbond US-35                          375  "
          Luster-on Utility  15                  436  "
          Oakite  190                             56  "
          Shipley Catalyst 9F                    43  "
          Niposit R  Nickel Replenisher            7  "
          Niposit Electroless Nickel 65M         8  "


NOTES:  1. Estimates of amounts of  each substance in the waste
           stream have been  calculated using mass balances.   The
           calculations are available  to EPA upon request.

        2. Supporting calculations for why we believe  certain of
           these materials  to be absent from the waste are
           available to EPA  upon request.


[Note to the reader;  The Agency would request  the  supporting
calculations  referred to above; proper procedure would be to
submit  them with the original petition.]
                              1-10

-------
 Material Safety Data Sheet
        c«r USOL Safety and H«a«n Regulations
 (O/ S1'CY«'<3 employment (29 CFR 1915)
U.S. Department of Ljbcr
Occupational Safety and Heaim Admmwration
                                                                                           OM8 NO 1218-0074
                                                                                        Expiration Oat* OS/31 /36
lection I
 Manufacturer J Name
                 Shipley  Company  Inc.
                                Emergency Taieonone Numoer
                             (617)  969-5500
Aaaresa (Mumper. Slreet. Oly. sala. tnd ZIPCocel
	2300 Washington  Street
CnermcaiNeme
anoSynonym*  n.a.
                 Newton.  MA   02162
TratM Nam*
andSynonym* NIPOSIT® NICKEL  REPLENISHER 65S
                                                    Cnacnical
                                                                                Formua,
                                                               n.a.
                                  Proprietary
Section II - H
                                             TLV (Un«s) A«oy« and M«U«e
                                          *  TT.V (Un»ts|
Pigm«ms
n.a.
Catalyst
n.a.
V«OK3»
n.a.
SoNvnta
n.a.
AOOltlvM
n.a.
n.a.












BaMMatai
n.a.
Alloy*
n.a.
Metallic Coatinqa
n.a.
F««r M«iai
Pius Coating or Cor* Flux n.a.
Otrwrs
n.a.













                                                                                               %  TUV (Umtsi
Sodiiim Hypophosphite
Ammonium Carbonate
Lead, soluble compounds" (as Pb) less than
25
18
.01
unknown
unknown
0.15
mg/m3
Section III • Ptnrtfcai Oat*
Soiling Poir* («F)


212
n.a.
n.a.
Specific Gravity (H,O-1 )
Porcant Voiaul* oy voium* (H)
Evaporatnh Ral*
•')
1 .18
n.a.
n.a.
                 Complete
Appearance and Ooor
                 Water-white liquid  ammoniacal odor
Section IV - Fir* and Kiytrmten Hoard Omtm
Non-Flammable
Flammaot* Um«s

Lai
n.a.

U«t
n.a.

	Water,  C02,  Dry  Chemical
Spec* Fir* Figrmng Procaourea
                   None
Unusual Fir* and Expwaon Haimrta
	Dried residues may be  ignited  or decomposed  by excessive heat,
                                                   1-11

-------
                                               2A-8b
                                                                NIPOSIT  NICKEL REPLENISHER
Section V • Healtn Hasard Oau
Thresnoid t-'<™ value
                  0.1  mg/m3  - based on  nickel
       verexocsure
                  As  for nickel
Emergency nrsl AXI Proceouies
 Swallowing:  Contact physician  immeiately;   Eye  Contact:   Flush with copious  amounts of

 water;   Inhalation:  Move to fresh  air.
Section VI • Reectfvtty Oeta
Staouity
Unsiaoie
Suwe

X
Conanons to Avoid

inccrrpaiaoiiity tMaianais to Avoid)
              Strong  oxidants
Hazarcous Oecomoosmon Products
              Unknown
Haiaroous
Polymerization
Mey Occur
Will Not Occur

X
Conations to Avoid

Section VII - Spin or Ue* Proceduree
Siecs to oe Tanen m Case Material is Released or Swuea
                                      Flush with cold  water
Waste Oooosai Meinod
                   Contact  Shipley Product Services  Department
Section VIN • i«
                   :tion Information
fl«so»aiory Protecuon (Specify Type)
                          n.a.
Ventilation
Local Exneost
Local Exhaust Recommended
Mecnanical (General)
Protective Gloves
Yes
Soeoal
Otter
Eye Protection
Yes
Otner Protective Eaucmem
                     Suitable protective  clothing
Section IX • Special Precautions
Precautions to oe Taxed in Handling ana Storing
 Treat  as an  acidic solution of  nickel salts.  Store in a dry area,  away  from  strong

 oxidants, at 50-90°F.   Do not  store  in direct sunlight.   Keep sealed when not in use.
Otner Precautions               ~~"~~~~~~~~""~^~~~~~~~~~'"~~^~^~~~~~~~~~~~~^^~
                                                  1-12
                                                                                             farm CSHA-20

-------
    b.   Please give your assessment of  the  likelihood  that the
        processes,  operations, or feed materials described above
        might produce a waste stream that is not included in this
        petition.

      It is unlikely that the manufacturing process or the waste treat-
ment, process described  could produce a  waste that  is not  covered by
this petition.   The flow diagram of the waste  water treatment system
(Attachment II)  shows that chromium,  cyanide,  and  cadmium, are treated
prior to metal filtration.   This system produces  a sludge of uniform
composition with little variation from week to week or month to month.


    Approach B:

    You need not furnish any other  information regarding  your
    facility's processes and materials.   You must,  however, test
    your waste for additional constituents  as  described in Chap-
    ters 4 and 6 of the Guidance Manual.
                              1-13

-------
      CADMIUM  RECOVERY SYSTEM  LOCATED  IN PLATING  SHOP.

        TREATMENT TANK IS  CLOSED LOOP  FLOW TO REACTOR  -  ALSO LOCATED  IN  SHOP.
        FLOW FROM SECOND RINSE IS PLUMBED FROM TANK  INTO CYANIDE  SYSTEM.
                                                                                           Flow to
                     CADMIUM
                     PLATING
    TREATMENT
      TANK
                                                                                           Cyanide Treatment
                                                                                                Tank
RINSE
TANK
                                                                           (Cd   10 ppm)
                                                        Dragout from Plating Bath to Reactor
                                                Treated Water from Reactor back to Treatment
Attachment II
Page 1  of 5
                     (Closed-Loop Flow)

CADMIUM RECOVERY SYSTEM

-------
                                     25% Sodium
                                           Hydroxide
             Waste Cyanide
                Effluent
I
M
Ul
                           Concentrated
                            Sulfuric
Calcium
  Hyperchlorite
    & Water
      Slurry
                                   Both
                                     pH & ORP Probes
                                      Used in this
                                             Stage

                                       STAGE I
                                      pH 9 - 11
                                                                                 Calcium
                                                                                   Hyperchlorite
                                                                                     & Water
                                                                                       Slurry
                                                                                            Treated
                                                                                                Cyanide
                      Both
                        pH & ORP Probes
                         Used  in this
                                Stage

                          STAGE II
                           pH  8.5
          Attachment II
          Page 2 of 5
                                                   CYANIDE DESTRUCTION

-------
                           Waste or Concentrated
                           Sulfuric Acid
                                                   Sodium
                                                   Metabisulphate & Water Slurry
       Waste Chromate
         Effluent
                      STAGE I
                     pH 2.0 - 2.5
                                                                                        Treated Chromate
                                                STAGE II
                                                                                             Stream
 STAGE III
pH 8.0 - 9.0
                                          CHROMATE REDUCTION
Attachment II
Page 3 of 5

-------
I
M
-J


Heavy Metals Sump

Treated Cyanide
Treated Chrome











r
' '


Final pH Adjust
Tank
pH 8.0 - 9.0*
















1




ADMIX
TANK
(DE & Water)





Metal
Precipitate






PRECOAT
TANK


i


I




	 ^
Precipitated Metals
and Admix to Filters




         Attachment  II
         Page 4 of 5
                                              HEAVY METALS PRECIPITATION
                                  * pH Adjusted using Caustic or  Acid  as  Required.

-------
         Precipitated Metals
           and  Admix
 I
i--
00
                                            Filter*
                                             No. 2
                                            Filter*
                                             No.  1
                                                                                                                Treated
Filtered
                                                                         Water
                                                                                                Final
                                                                                               Holding
                                                                                                Tank
                                      Waste  to
                                        City
                                        Automatic
                                         Sampler
                *  Only one filter is operational at a time.  While filter #1
                    is being cleaned, flow is directed to filter #2.
                                                         FILTER OPERATION
          Attachment II
          Page  5  of  5

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                   SECTION C:   The Waste Stream
1.   EPA hazardous waste number and description  of  waste  stream
    (from 261.31 or 261.32):
    No.  F006   Description  Wastewater treatment sludge  from elec-

    troplating operations	

    Form of the waste (e.g., aqueous  solution,  sludge, dry solids):

       Sludge	^


    If the waste is a sludge,  give the percent  solids:    55	%
2.   Estimated average and maximum monthly and  annual  quantities
    generated:   (Please use consistent units of measurement.)

                                    Average              Maximum

          Monthly                 22 cu yd             60  cu yd*

          Annually               264 cu yd	        335  cu yd

*This number is atypically high; it represents the firs.t month
that, we were required to ship our wastes.
3.   This waste stream:  (check all  that apply)

            X    Is currently being generated.

            X    Will be generated in the future.

            X    Has been generated in the past and is currently
                 being  treated/stored on site.

          	  Has been generated in the past and is currently
                 being  treated/stored off-site.
                              1-19

-------
4.  Present methods of on-site storage,  and  amounts  being  stored:

                                       Amount

          Surface impoundment,           NA	

          Evaporation pond          	NA	
          Percolation bed               HA
          Waste pile(s)                  NA
          Tank(s)                       NA
          Containers                One 30 cu yd hopper

          Landfill                      NA	

          Drums                     	NA	

          Other (please specify)     	
5.  Waste Management Methods:

    Briefly describe:

          (a)  how the waste is currently managed;

          (b)  how it was managed before November 19,  1980;  and

          (c)  how it will be managed if this petition is approved.

    As appropriate,  provide names and locations of off-site treat-
    ment, storage or disposal facilities, and names and addresses
    of waste transportation firms.

    If the waste is  treated prior to disposal, please attach a
    schematic flow diagram of your present waste treatment system,
    showing the processes and equipment  used.

(a)   The petitioner treats waste water from its Long  Horn Avenue metal
finishing shop with a treatment facility that is designed to totally
reduce hexavalent chromium, destroy cyanide, and precipitate metal
oxides.  In addition, the facility has recently installed a Cadmium
Recovery System which recovers cadmium oxide from the rinse tank prior
to the waste treatment process.  Metal ions produced in the process
include  chromium, cadmium, copper, and nickel.  Cyanide is present, but
is reduced completely during the  treatment process to carbon dioxide
and nitrogen gas.  Precipitated metal hydroxides are filtered through a
filter precoated with diatomaceous earth (DE) and additional DE is
added during filtration to improve filterability; this process occurs
during treatment.  The sludge is thus composed of DE primarily, and
0.04 to  1.0 percent metal  oxides.  (See  Attachment  II.)
                              1-20

-------
     The current disposal method used for the  sludge employs the
following offsite Subtitle C facility:

               Rolling Haulers
               2300 Fieldcrest Road
               Deer Crossing,  TX  77556

(b)  Prior to November 19,  1980,  the waste sludge was disposed  of  at:

               Dallas Municipal Landfill
               Walnut Hill Road
               Dallas, TX  75266

(c)  Upon reclassification,  the sludge will once again be disposed of
at the Dallas Municipal Landfill.
                              1-21

-------
        SECTION D:  Selection of Constituents for Testing
    The procedures described below apply to all types of wastes
    other than those from petroleum refineries and multiple waste
    treatment facilities.   Petitioners for these facilities should
    refer to Section 4 of the Guidance Manual and adapt this
    section of the petition appropriately.


1.   If you have followed Approach A in Section B above, please
    submit test results on representative samples for the follow-
    ing:

          •  The specific hazardous constituents for which the
             waste was listed (i.e.,  total concentration of each
             listed constituent found in Appendix VII of Part
             261);

          •  The four hazardous waste characteristics (but see the
             Note immediately below);

          •  Appropriate leachate tests for the EP toxic metals,
             nickel, and cyanide;

          •  Total concentrations of the EP toxic metals and
             nickel;

          •  Total organic carbon (TOC); and

          •  Total oil and grease.

    Note;  If you can explain why the waste cannot exhibit one or
    more of the four hazardous waste characteristics, you may
    submit your rationale in lieu of test results for those char-
    acteristics.  For example, if the waste is composed exclusive-
    ly of organic solvents and there is no chance (on the basis of
    process considerations) that it contains any of the EP toxi-
    cants, you need not test for the EP Toxicity characteristic.

    You may omit the rest of this section and go to Part E.


2.   If you have opted for Approach B in Section B above, then you
    must perform the tests specified in the above paragraph, and
    you should test for all hazardous constituents that may "rea-
    sonably be expected" to be in the waste, whether or not they
    were used as a basis for listing.

    The remainder of this section is to be used to support your
    decision regarding which constituents to test for.


                              1-22

-------
    a.  List the constituents (from Appendix VIII to Part 261)
        that may reasonably be expected to be in the waste.  De-
        scribe the engineering,  chemical, or other considerations
        that support your choice.


        Constituent:    None	

        Reasons for Selection:

     Although several Appendix VI11 constituents are included in
our materials listings, we believe that mass balance considera-
tions render these substances absent from the waste stream.
Therefore, it is unreasonable to expect their occurrence in the
waste.

                      (Repeat as necessary.)
[Mote to the reader;  The Agency would request the supporting
calculations referred to above; proper procedure would be to
submit them with the original petition.]
    b.  For each of the remaining hazardous constituents (or
        groups of constituents) in Appendix VIII of Part 261,
        specify why it may not reasonably be expected to occur in
        the waste stream.

        Constituent (or group of constituents):    See above	

        Reasons for non-occurence:  See above
                     (Repeat as necessary.)
                              1-23

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            SECTION E:  Sampling and Testing  the Waste
The purpose of the data requested below is to demonstrate  that
representative samples of the waste stream:

    a.  Do not exhibit any of the criteria (e.g., hazardous waste
        characteristics or constituents) for  which the waste was
        listed,  and

    b.  Do not exhibit any other criteria that could cause it to
        be listed.

Additional information is also requested as a check  on the test
results.  Refer  to the accompanying Guidance  Manual  for  instruc-
tions on developing a sampling plan (Chapter  7),  selecting proper
test methods,  (Chapter 8)  and  presenting the  test results  (Chapter
9).


1.   General Information


    a.  Name and address of the laboratory facility  performing the
        sampling [260.22(1)(1)]:

        Name  	

        Street
        City    	  State   	  Zip  	

        Telephone:  (	)	-	


        If sampling was done by in-house staff,  check here:


        For each individual person who (a)  designed the sampling
        plan or (B~)collected samples, please provide the follow-
        ing information and attach a resume or  other  statement  of
        qualifications [260.22(i) (2) ].

        Name    Susan Smith	

        Affiliation   ABC  Industries,  Inc.
        Title    Process Engineer
               (resume attached)

                         (Repeat  as necessary.)


                              1-24

-------
Susan Smith
24 Green Street
Dallas, Texas  75206
Education
     August 1975 - May 1979
University of Missouri - Columbia,

B.S. Chemical Engineering
G.P.A.  2.75/4.0
Work Experience

     June 1979 - May 1980
     May 1980 - June 1981
     June 1981 - Present
ABC Amalgamated Industries, Inc.

  Optics Department - set up process
   documentation and process control
   procedures for optics fabrication.

ABC Amalgamated Industries, Inc.

  Process Engineering - provide pro-
   cess support for organic coating
   area.  Evaluate new coating mate-
   rials, procedures.

ABC Amalgamated Industries, Inc.

 Process Engineering - support waste
  treatment/chemical finishing, plat-
  ing operations.  Maintain data on
  waste treat system, documents for
  solid waste disposal, and applicable
  permits.  Technical support for
  plating shop and waste treatment.
  Perform troubleshooting and new sys-
  tem evaluations.
                                      1-25

-------
b.  Name and address of the laboratory facility performing the
    testing, if different from the  sampling laboratory
    [260.22(1)(1)]:

    Name	

    Street  	

    City    	  State  	  Zip  	

    Telephone: (	)	-	


    If testing was done by in-house staff,  check here:    X
    For each individual person who (a) designed the testing
    plan or (b)  performed  tests, please provide the following
    information and attach a resume or other statement of
    qualifications [260.22(1) (2) ].

    Name   Thomas Roberts	

    Affiliation   ABC Indus-tries,  Inc.
    Title   Engineering Analyst
           (resume attached)


                  (Repeat as necessary.)
                          1-26

-------
Thomas Roberts
29 Turner Street
Lewisville, Texas  75067
Education
     1972 - 1974
St. Louis University - St. Louis/ MO

 Courses taken included, but were not limited
  to, Chemistry 101 and 102, Quantitative
  Analysis (with emphasis on atomic absorption
  analysis), Organic Chemistry, Physical
  Chemistry and Biology 101 and 102.
     1982
Lancerette Laboratories

 Received Certification for both flame and
  flameless atomic absorption spectrophotometry
  on the Instrumentation laboratory 551 video
  spectrophotometer.
Work History

     1972 - 1974
U.S. Army Corps of Engineers, Water Quality
  Lab, Foot of Arsenal Street - St. Louis, MO

 Work included sampling and analysisi of Corps
  controlled bodies of water in the Missouri
  and Illinois districts.  Analysis included
  wet chemistries as well as atomic absorption
  and biological testing.
     1974 - 1978
     1978 - 1980
Washington University, Department of Pediatrics
  - St. Louis, MO

 Hematology and Oncology research and routing
  clinical testing of cancer patients on drug
  therapy.

Enreglory Engineering, Inc.

 Analysis Laboratory - work on the effluent
  guidelines project 1434 and 1444 and RCRA for
  the EPA.

  Duties included metals analysis by atomic
  absorption, phenolics, cyanides and pesti-
  cides and other analysis.
                                      1-27

-------
Tom Roberts
Page 2
Work History - (Continued)

     1980 - Present            ABC Amalgamated Industries,  Inc.
                                Process Engineering Lab - Senior  Technician in
                                 research, routine evaluations,  plating,
                                 wastewater,  sludge analysis and  training of
                                 technical personnel in the use  of atomic
                                 absorption spectrophotometry.
                                      1-28

-------
    c.  Describe the sampling strategy you followed to insure that
        the samples were representative [260.22(i) (9)].   Please
        address specifically:


          •  the variation of the waste stream over time; and

          •  the variation of the waste stream in space.


        All waste stream outflows or storage locations to which
        this petition applies must be sampled.  The Delisting
        Petition Guidance Manual (see Instructions to this form)
        gives directions for developing a sampling plan.

    Time-composite sampling was used, with an interval that coin-
cided with each dumping of the filter cake from the filter press.
This averaged three times per week.

     Each time that a filter was dumped into the small (1.5 cu yd)
hopper (see Attachment III) the waste treatment operator notified
the Process Engineer*.  The Process Engineer then put on a neoprene
glove and collected four samples from the hopper using a trier.
Sample locations were selected by dividing the hopper horizontally
into quadrants and taking one sample from the centroid of each
quadrant.  The samples, approximately twenty grams each, were then
stored in heavy-walled plastic bags and sealed to main-tain fresh-
ness.  At the end of each week, equal weight samples were taken
from the individual bags to compile the composite 100 gram sample,
which was then used for the leachate test.

     The small hopper is emptied into the larger (30 cu yd) hopper
following each filter dump.
     d. State whether the Chain of Custody procedures in Section
        1.3 of SW-846 were followed.  Please describe any devia-
        tions from those procedures and the reasons for them.

     All chain-of-custody procedures as outlined in Section 1.3 of
SW-846 were followed.
                              1-29

-------
                NOTE:   After each  filter was dumped  into  the
                       hopper,  four  samples were obtained,  the
                       waste was then  emptied into a larger
                       30  yd-* hopper,  and  the process repeated
                       3 to  4 times  per week.
                                                                           1 .5  CUBIC YARD CAPACITY
I
u>
o
          Tilts 40  Below  Horizontal
                              Safety Latch
                                                                                                                     36'
                                                                                                  Fork Lift
                                                                                                  Insert Here
        Restraining Bar
         Attachment III
Skid or Caster Assembly to be
  Mounted for Increased Mobility under Filters

-------
2.   Sample-Specific Information


     For each individual sample, please furnish the information
     requested in the form  on the  following  page.   The  notes  below
     refer to those items on the form that are  not  self-explana-
     tory.  The Guidance Manual contains additional instructions.
                              Notes


Item f,  "Parameter/Constituent Tested For":   Enter the hazardous
        waste characteristic or constituent that was the subject
        of the test.

Item i,  "Test Method and Source":   See Chapter 8 of the Guidance
        Manual for a listing of applicable test methods.  Sources
        for test methods may be designated by number,  as follows:

             1. "Test Methods for  Evaluating Solid Waste:
                Physical/Chemical Methods," EPA SW-846 (second
                edition),  July,  1982, and supplements.

             2. "Methods for the Evaluation of Water and
                Wastewater,"  EPA 600  14-79-020,  March, 1979.

             3. "Standard Methods for the Examination of Water
                and Wastewater," (14th Edition).

             4. Appendix J of the Guidance Manual

Item j,  "Sample Workup or Preparation Method": See Section Four
        of Reference 1 above.

Item 1,  "Test Results":   Enter concentrations in mg/1, ppm, etc.
        as appropriate.
                              1-31

-------
                       Sample Number:
Sampling Information;


 a.  Sampling location:    The 1.5 cu yd hopper

 b.  Person(s) who drew the sample:  Susan Smith
 c.  Equipment used for drawing the sample:   Trier
                                                Daily at 9:00  a.m.
 d.  Date and time when the sample was drawn:  10/4 /82,  	PTHH-
                                          to  10/8/82
 e.  Handling, containerization, and preservation techniques used:

      Daily samples were combined & mixed to get a weekly composite.

      Composites were stored in sealed, heavy-weight plastic bags.



Test Procedures and Results;   (Repeat for each test conducted)


 f.  Parameter/Constituent Tested For:  All EP metals.  Hi, Cu, Zn,
                                             Total cyanide
 g.  Date Test Performed:   10/12 /82

 h.  Person(s) who performed the test:  Thomas Roberts	

 i.  Test Method  (or Number) and Source:  see Summary Table	

 j.  Sample Workup or Preparation Method:  see Summary Table	

 k.  Equipment:      Name                      Model Number

          Perkin-Elmer                        603            	
          Perkin-Elmer                        406
          Bausch & Lomb Sectronic         	23
          Perkin-Elmer                         54B
          Instrumentation Laboratories        251
         Atomic Absorption Spectrophotometer


  1.  Test Results:   see Attachment IV	



                               1-32

-------
                       Sample Number:
Sampling Information;


 a.  Sampling location:    The 1.5 cu yd hopper

 b.  Person(s) who drew the sample:   Susan Smith
 c.  Equipment used for drawing the sample:    Trier
                                                Daily at 9:00  a.m.
 d.   Date and time when the sample was drawn:  10/11/82,
                                          to  10/15/82
 e.   Handling, containerization,  and preservation techniques used:

      Daily samples were combined & mixed to get a weekly composite.

      Composites were stored in sealed, heavy-weight plastic bags.



Test Procedures and Results;  (Repeat for each test conducted)


 f.   Parameter/Constituent Tested For:  All EP metals, Ni, Cuf Zn,
                                             Total cyanide
 g.   Date Test Performed:   10/19 /82

 h.   Person(s) who performed the test:  Thomas Roberts	

 i.   Test Method  (or Number) and Source:  see Summary Table	

 j.   Sample Workup or Preparation Method:  see Summary Table	

 k.   Equipment:      Name                      Model Number

          Perkin-Elmer                        603           	
          Perkin-Elmer                        406
          Bausch & Lomb Sectronic              23
          Perkin-Elmer                         54B
          Instrumentation Laboratories        251
         Atomic Absorption Spectrophotometer


 1.  Test Results:   see Attachment  V	



                              1-33

-------
                       Sample Number:
Sampling Information;


 a.  Sampling location:    The 1.5 cu yd hopper

 b.  Person(s)  who drew the sample:   Susan Smith
 c.  Equipment used for drawing the sample:    Trier
                                                Daily at 9:00  a.m.
 d.   Date and time when the sample was drawn:  10/18/82, 	PTHH-
                                          to  10/22/82
 e.   Handling, containerization,  and preservation techniques used:

      Daily samples were combined & mixed to get a weekly composite.

      Composites were stored in sealed, heavy-weight plastic bags.



Test Procedures and Results;  (Repeat for each test conducted)


 f.   Parameter/Constituent Tested For:  All EP metals, Hi, Cu, Zn,
                                             Total cyanide
 g.   Date Test Performed:   10/26 /82

 h.   Person(s) who performed the test:  Thomas Roberts	

 i.   Test Method (or Number) and Source:  see Summary Table	

 j.   Sample Workup or Preparation Method;  see S'i"""ary Table	

 k.   Equipment:      Name                      Model Number

          Perkin-Elmer                        603
          Perkin-Elmer                        406
          Bausch & Lomb Sectronic              23
          Perkin-Elmer                         54B
          Instrumentation Laboratories        251
         Atomic Absorption Spectrophotometer
 1.  Test Results:   see Attachment  VI
                              1-34

-------
                       Sample Number:
Sampling Information;


 a.  Sampling location:   The 1.5 cu yd hopper

 b.  Person(s) who drew the sample:  Susan Smith
 c.  Equipment used for drawing the sample:   Trier
                                                Daily at 9:00  a.m.
 d.   Date and time when the sample was drawn:  10/25/82,  	p-r»r
                                          to  10/29/82
 e.   Handling, containerization, and preservation techniques used:

      Daily samples were combined & mixed to get a weekly composite.

      Composites were stored in sealed, heavy-weight plastic bags.
Test Procedures and Results;  (Repeat for each test conducted)


 f.  Parameter/Constituent Tested For:  All EP metals. Hi, Cu, Zn,
                                             Total cyanide
 g.  Date Test Performed:   ll/ 2 /82

 h.  Person(s)  who performed the test:  Thomas Roberts	

 i.  Test Method (or Number) and Source:  see Summary Table	

 j.  Sample Workup or Preparation Method:  see Summary Table	

 k.  Equipment:      Name                      Model Number

          Perkin-Elmer                        603      	
          Perkin-Elmer                        406
          Bausch & Lomb Sectronic              23
          Perkin-Elmer                         54B
          Instrumentation Laboratories        251
         Atomic Absorption Spectrophotometer


 1.  Test Results:   see Attachment  VII	



                              1-35

-------
3.  Summary Table of Analytical Results
     For each sample, please enter the Test Results from Item 2
     above onto the form contained in the following pages.
4.  Analytical Discussion
     Please furnish explanations or additional information on the
     following topics as necessary:

     a.   Inconsistencies or deviations in the analytical  results
         presented above.

     b.   Additional  reasons as  to why the waste  stream  should be
         delisted.
                              1-36

-------
                          Summary Table
Analytical Methods Used;








     Arsenic



     Barium



     Cadmium




     Chromium (tot..)




     Lead



     Mercury



     Selenium



     Silver



     Nickel




     Cyanide (tot.)



     TOC



     Oil & Grease
Workup



1310



1310



1310




1310




1310



1310




1310



1310



1310
Analysis




 7060



 7080




 7130




 7190




 7420




 7470




 7740




 7760




 7520




 9010




 502D




 415.1
                               1-37

-------
                                                            SUMMARY OF TEST RESULTS
I
u>
00
Sample Number:
Sampling Location:
Date Sample Taken:
1 . Ignitability
Liquids Flash point
Non- liquids Spontaneous
combustion
Compressed Flammability
Gas
Oxidizer Oxygen yield
2. Corrosivity pH
Corrosivity
towards steel
3. Reactivity Violent chemical
change
Reacts violently
with water
Water-reactive;
explosive
1
1.5 cu yd
hopper
Oct 4-8 '62










2
I . 5 cu yd
hopper
Oct 11-15










3
1 . b cu yd
hopper
Oct 18-22










4
1.5 cu yd
hopper
Oct 25-29
























-------
                                                     SUMMARY OP TEST RESULTS  (Continued)
I
u>
vo
Sample Number:
3. Reactivity Water-reactive;
(Cont.) toxic gases,
vapors , fumes
Cyanide or sulfur-
bearing wastes
which, when exposed
to acidic/basic
conditions, gen-
erate toxic gases,
vapors, or fumes
Explosive when
subjected to
force or heat
Explosive at stan-
dard temperature
and pressure
DOT explosive
4. Total Arsenic
Metals
(Complete Barium
Acid
Digestion) Cadmium
Chromium

























































































































-------
SUMMARY OF TEST RESULTS (Continued)
Sample Number :
4 . Total Lead
Metals
(cont.) Mercury
Selenium
Silver
Nickel
5. EP Toxicity Arsenic
— Metals
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Nickel
1




.11 ug/l
.01
.06
.05*
.05*
.05
.01
.01*
2.00
2




1.0
0.3
0.12
.05*
.01*
.05
.02
.01*
1.00
3




1.0
0.3
0.12
.05*
.01*
.05
.02
.01*
0.11
4




1.0
0.2
0.18
.05*
.01*
.05
.02
.01*
0.58













   *Less  than

-------
                               SUMMARY OF TEST RESULTS (Continued)
Sample Number:
6 . EP Toxicity Arsenic
— Metals;
Oily Waste Barium
Methods*
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Nickel
7. EP Toxicity Endrin
— Pesticides
Lindane
Methoxychlor
Toxaphene
8. EP Toxicity 2,4-D
— Herbicides
2,4,5-TP (Silvex)




































































































*For wastes containing greater than 1% total oil and grease,

-------
                                                    SUMMARY OF TEST RESULTS  (Continued)
I
^
to

9. EP Toxicity
— Organics
Sample Number:

10. Total Organ-
ic Carbon

11. Oi 1 and
Grease

12. Cyanide
13. Other



Total
Free
Extraction
procedure
Photodegradable
Appendix VIII
constituents
(Add sheets as
necessary)
1


0.8 ppm
0.01 ppm

2


1.0
0.18

3


0.9
0.07

4


0.9
0.18








-------
Quality Assurance and Quality Control

a.  For inorganic substances, describe the procedures used for
    Standard Additions Analysis.   Provide the following for
    each substance tested:
                             SEE ATTACHED SHEETS

                  Spike          Recovery          Percent
Substance     Concentration    Concentration       Recovery
     For organic substances, describe the procedures used for
     analysis of spiked samples.  For each substance tested,
     provide the information requested in the following table.
     Also, describe in writing the procedures used to cali-
     brate the analytical equipment.
  Substance         Surrogate,      Spike   Recovery  Percent
 Tested For           if any        Cone.     Cone.   Recovery
     Describe any other QA/QC measures followed in regard to
     the sampling and analysis procedures.
                          1-43

-------
                          STANDARD ADDITION ANALYSIS FOR WEEK 1
                                   Attachment IV  (cont.)
           Concentration
                      Cr
           0.00 mg/1
                             Concentration
                                        Cd
                                =0.06 mg/1
 3

 2


 1

 0

-1

-2

-3
  ABS
0.0000
0.0040
0.0080
0.0160
            .005
       .01
 CONG
0.000
0.500
1.000
2.000
 .015
       3

       2


       1

       0

      -1


      -2

      -3
  ABS
0.0060
0.0350
0.0650
0.1270
 CONC
0.000
0.500
1 .000
2.000
                                           .02
                                                            .06
                                                       .12
                                                                                 .18
            Concentration =0.05 mg/1
                       Pb
                                            Concentration
                                                       Ni
                                             2.00 mg/1
.3

 2
 0

.1


.2

.3
  ABS
0.0040
0.0160
0.0220
            .006
      .012
 CONC
0.000
0.100
0.200
 .018
       6

       4

       2


       0


      -2

      -4 _


      -6 _

.024      0
	 > — l*^ '
^^ ABS
0.0140
0.0210
0.0350
0.0490

CONC
0.000
1 .000
3.000
5.00
                                                            .015
                                                      .03
                                                .045
                                       1-44

-------
  6

  4


  2  .

  0

 -2


 -4


 -6  L
                          STANDARD ADDITION ANALYSIS FOR WEEK 1  (cent.)

                                      Attachment IV (cont.)
              Concentration = 0.00 mg/1
                         Cu
 ABS
0.000
0.020
0.040
0.050
              .02
      .04
 CONG
0.000
1 .000
2.000
3.000


 .06
                               -2  ,.
     -.8  _

    -1.2
                                           Concentration
                                                      Zn
                                           =0.38 mg/1
 ABS
0.0220
0.0430
0.0530
0.0830
 .08
                                                            .025
                                                     .05
 CONC
0.000
0.300
0.500
1.000


 .075
1.5

1.0

 .5
             Concentration = 0.00 mg/1
                         Ag
-.5


1.0


1 .5

0
0

0
0
.
ABS
.0000
.0090

.0200
.0290

CONC
0.000
0.500

1 .000
1.500

            .008
     .016
 .024
.032
                                          1-45

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                 ORGANIC WASTESTREAM
                    OPTIONAL FORM:

         DELISTING PETITION FOR WASTE STREAM

K027 — Centrifuge and Distillation Residues from Toluene
               Diisocyanate Production
                    Submitted by:

             Nayblor Chemical Corporation
                  Ardmore Boulevard
                 Pittsburgh, PA 15208
                        Date:

                    April 15, 1982
                        1-47

-------
4.  Description and Justification for the Proposed Action

    Please describe briefly the proposed delisting action, why it
    is needed, and how it will affect your operation.  Describe
    why you believe that the waste stream of concern (a) is not
    hazardous for the reasons it was originally listed and (b)
    contains no other constituents or characteristics that render
    it hazardous as defined in 40 CFR 261. [260 . 20(b) ( 2 ) ,  (3) and
    (4)]

Mayblor Chemical Corporation proposes to exclude EPA Hazardous Waste No.
K027, Centrifuge and distillation residues from toluene diisocyanate
production, from Subpart D, 40 CFR 261.32.  This residue was listed by
EPA as a hazardous waste from a specific source because the residue was
considered reactive (R) and toxic (T).  Mayblor 's process currently
produces this residue in such a manner that it eliminates the residue ' s
characteristics of reactivity and toxicity.  Additional testing by May-
blor indicates that the residue contains no other constituents or charac-
teristics that render it hazardous as defined in 40 CFR 261.

The need for the proposed action is to relieve Mayblor of the burden and
cost of disposing of this residue.  The proposed action will affect
Mayblor 's operations by allowing for the marketing of the processed
residue as a supplemental fuel for steam and/or electrical generating
plants.  In addition to these benefits, scarce landfill capacity will not
be utilized by a material with definite resource recovery potential.

5.  Certification of Accuracy and Responsibility  [260. 22 (i) (12) ]

    I certify under penalty of law that I have personally examined
    and am familiar with the information submitted in this  demon-
    stration  and  all attached documents,  and that based  on  my
    inquiry  of those individuals immediately responsible  for  ob-
    taining the information, I believe that the submitted  informa-
    tion is true,   accurate,  and complete.  I am aware that there
    are  significant  penalties for submitting false  information,
    including the possibility of fine and imprisonment.
                                         Signed,
                                         Waste Generator,  Title or
                                         Authorized Representative*
                                         of Waste Generator,  Title
     *Hote:   An "authorized representative"  is a person  respon-
      sible  for the overall operation of a facility or an opera-
      tional unit (for example,  a plant manager, superintendent,
      or person of equivalent responsibility).  Consultants or
      other  outside parties may  not sign the certification state-
      ment.
                              1-49

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               SECTION B:   Production Processes
1.  Description of Manufacturing Processes  and Other Operations
    [260.22(i)(5)].

    a.  Please provide a brief description of the on-site
        manufacturing/generating process(es)  that produce the
        waste stream.   Include descriptions of major equipment
        items and production lines.   Also,  describe the stages of
        the typical operating cycle  (e.g.,  startup,  steady-state
        operation, cleaning and maintenance)  on a daily,  weekly,
        or other basis as appropriate.

     Toluene diisocyanate (TDI)  distillation residues are isolated
during the distillation of TDI from the by-product higher-molecular-
weight polymers that are formed during  the  reaction of toluene diamine
(TDA) with phosgene.  This reaction produces the product TDI.

     Mayblor Chemical's process as described above is generally
represented by the schematic and process  description given in EPA's
"Listing Background Document:  Toluene  Diisocyanate Production."

     A more detailed explanation of the process and associated equipment
has been supplied to EPA.  Because of its confidential nature this
description is not included in the public record file.


    b.  Please provide a description of all surface and equipment
        preparation, cleaning, degreasing,  coating or painting
        processes used in your facility that  you have not
        described in (a) above.

     See above.
        Attach a schematic diagram of all manufacturing processes,
        surface preparation,  cleaning,  and other operations that
        may provide influent into the waste stream.
     See above.
                              1-50

-------
2.   Materials Used or Produced

        You may comply with the requirements for additional
        information in either of two ways;  see Section 4 of the
        Guidance Manual for a detailed description of the two
        approaches.
    Approach A;

    a.   List all materials used or produced in the manufacturing
        or, other process generating the waste stream(s)  of con-
        cern.  Use the correct chemical name wherever possible.
        Include materials such as:

                    Raw materials
                    Intermediate products
                    By-products
                    Products
                    Oils and hydraulic fluids
                    Surface preparation materials
                      (solvents, acids, cleaners, surface
                      preparation agents, paints, etc.)

        Also:

        o  For each material on the list, indicate whether it is
           discharged to or likely to be present in the  waste,  and
           the estimated amount entering the waste stream annual-
           ly.  (Specify kilograms, pounds,  or similar units.)

        o  For each material on the list that you do not expect to
           be present in the waste, give supporting reasons for
           this expectation.  Supporting reasons may include mass
           balance and process information.   OWR NOTES
           Attach Materials Safety Data Sheets (MSDS)  for all
           materials that are identified by trade or generic name
           only and that are discharged into or likely to be
           present in the waste stream.

                                              Estimated Amount
                        Material             Entering the Waste
                                              Stream Annually

            Tolaene-2 , 4-diaau.ne                  none
            2,6-Toluene-diamine                  none
            o-Dichlorobenz ene                    none
                                                     1
             gaseous phosgene	                 none
                                                     2
             Toluene diisocyanate                none
                              1-51

-------
                     NOTES TO MATERIALS LIST
1.  These materials are completely consumed in the TDI production
    process,  and therefore do not appear in the waste stream.

2.  TDI is the process end-product.   Analytical tests indicate
    that it is undetectable in the waste (see Section E below).
                              1-52

-------
    b.  Please give your assessment of the likelihood that the
        processes, operations, or feed materials described above
        might produce a waste stream that is not included in this
        petition.


     The waste-generating operation is carried out in a completely
closed process.  All inputs and outputs nave been identified.  There-
fore, it is highly unlikely that a waste stream not included in this
petition would be produced from the processes, operations and feed
materials described above.
    Approach B;

    You need not furnish any other information regarding your
    facility's processes and materials.  You must, however, test
    your waste for additional constituents as described in Chap-
    ters 4 and 6 of the Guidance Manual.
                              1-53

-------
                   SECTION C:   The Waste Stream
1.   EPA hazardous waste number and description of waste stream
    (from 261.31 or 261.32):


    No. K027 Description   Centrifuge and distillation residues

     from toluene diisocyanate production	

    Form of the waste (e.g.,  aqueous solution,  sludge, dry solids)

      Sludge	


    If the waste is a sludge,  give the percent solids: 	80  %



2.   Estimated average and maximum monthly and annual quantities
    generated:   (Please use consistent units of measurement.)

                                    Average             Maximum

          Monthly                  300 tons            550 tons

          Annually                3600 tons           6600 tons



3.   This waste stream: (check all that apply)

            X    Is currently being generated.

            X    Will be generated in the future.

            X    Has been generated in the past and is currently
                 being treated/stored on-site.

          	  Has been generated in the past and is currently
                 being treated/stored off-site.
                              1-54

-------
4.  Present methods of on-site storage, and amounts being stored:

                                       Amount

          Surface impoundment,

          Evaporation pond

          Percolation bed

          Waste pile(s)

          Tank(s)

          Containers

          Landfill

          Drums
  NA	

  NA	

  NA	

  NA	

  NA	

Less than or equal to 550 tons

  NA
  NA
          Other (please specify)
5.   Waste Management Methods:

    Briefly describe:

          (a)  how the waste is currently managed;

          (b)  how it was managed before November 19, 1980; and

          (c)  how it will be managed if this petition is approved.

    As appropriate, provide names and locations of off-site treat-
    ment, storage or disposal facilities, and names and addresses
    of waste transportation firms.

    If the waste is treated prior to disposal, please attach a
    schematic flow diagram of your present waste treatment system,
    showing the processes and equipment used.

a)   The waste is currently held on-site in large, covered containers
    until our contracted hauler arrives on the twentieth of each month.
    The hauler then delivers the residue to either a fuel burning
    facility (with interim storage and staging) or, more often, to a
    properly permitted landfill.
    Hauler:  ABC Trucking & Hauling
             22 Dalean Avenue
             Thurston, PA
   Landfill:  XYZ Landfill
              102 Lancer Street
              Sewickley, PA
    Fuel burners:  Steam Generators, Inc.
                   2 Tavern Lane
                   Thurston, PA
                              1-55

-------
b)  Prior to November 19, 1980, the treated residue was shipped solely
    to Steam Generators, Inc.  for resource recovery.

c)  If this petition is approved, we shall employ resource recovery to
    the largest extent possible to manage the residue.


Attachment I:  Toluene Diisocyanate Production Schematic — includes
               diagram of present waste system, showing processes and
               equipment used. A more detailed explanation of the process
               and associated equipment has been supplied to EPA.  Be-
               cause of its confidential nature, this description is not
               included in the public record file.
                               1-56

-------
                               Attachment I

                TOLUENE DIISOCYANATE PRODUCTION SCHEMATIC
        Toluene
        Diamine
    Phosgenation
                       Crude
                        TDI
                                                     Product Toluene Diisocyanate
   Primary
Distillation
                                                  TDI
 Secondary
Distallation
        Phosgene
                                       Residue
Resource
Recovery
Disposal



Deactivation
Polishing
Step
(2)


Residue
Deactivation
^

                                     1-57

-------
        SECTION D:   Selection of Constituents for Testing
    The procedures described below apply to all  types of wastes
    other than those from petroleum refineries and multiple waste
    treatment facilities.  Petitioners for these facilities should
    refer to Section 4 of the Guidance Manual and adapt this
    section of the petition appropriately.


1.   If you have followed Approach A in Section B above, please
    submit test results on representative samples for the follow-
    ing:

          •  The specific hazardous constituents for which the
             waste was listed (i.e.,  total concentration of each
             listed constituent found in Appendix VII of Part
             261);

          •  The four hazardous waste characteristics (but see the
             Note immediately below);

          •  Appropriate leachate tests for the EP toxic metals,
             nickel, and cyanide;

          •  Total concentrations of the EP toxic metals and
             nickel;

          •  Total organic carbon (TOG); and

          •  Total oil and grease.

    Note;  If you can explain why the waste cannot exhibit one or
    more of the four hazardous waste characteristics, you may
    submit your rationale in lieu of test results for those char-
    acteristics.  For example, if the waste is composed exclusive-
    ly of organic solvents and there is no chance (on the basis of
    process considerations) that it contains any of the EP toxi-
    cants, you need not  test for the EP Toxicity characteristic.

    You may omit the rest of this section and go to Part E.


2.  If you have opted for Approach B in Section B above, then you
    must perform the tests specified in the above paragraph, and
    you  should test for  all hazardous constituents that may "rea-
    sonably be expected" to be in the waste, whether or not they
    were used as a basis for listing.

    The  remainder of this section is to be used to support your
    decision  regarding which constituents  to test for.


                              1-58

-------
    List the constituents (from Appendix VIII to Part 261)
    that may reasonably be expected to be in the waste.  De-
    scribe the engineering,  chemical, or other considerations
    that support your choice.
    Constituent:    Toluene diisocyanate	

    Reasons for Selection:

     . This is the only Appendix VIII constituent that is not
       totally consumed in the production process.


                    (Repeat as necessary.)
b.  For each of the remaining hazardous constituents (or
    groups of constituents) in Appendix VIII of Part 261,
    specify why it may not reasonably be expected to occur in
    the waste stream.

    Constituent (or group of constituents):     All others	

    Reasons for non-occurence:

       All Appendix VIII constituents except for TDI are completely
       consumed in the closed production process.

                   (Repeat as necesssary.)
                          1-59

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                       Sample Number:
Sampling Information;


 a.  Sampling location:  Reaction container
 b.  Person(s) who drew the sample:  T. Hugent
 c.  Equipment used for drawing the sample:   grain sampler
                                                               a.m.
 d.  Date and time when the sample was drawn: 3 / 1/82,    7
 e.  Handling, containerization,  and preservation techniques used:

      Sampling container was immediately capped, labelled and _

      sealed.   Sample was then immediately delivered to the _

      laboratory .

Test Procedures and Results ;  (Repeat for each test conducted)


 f .  Parameter/Constituent Tested Fors  Toluene diisocyanate _

 g.  Date Test Performed:   3/5 /82

 h.  Person(s) who performed the test:  Barney Kessel _

 i.  Test Method (or Number) and Source:  9O10, SW-846 _

 j.  Sample Workup or Preparation Methods  As in (i) above _

 k.  Equipment:      Name                      Model Number

          Perfcin Elmer                      Model 5000
 1.  Test Results:   Not detectable
                              1-60

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3.   Summary Table of Analytical Results


     For each sample, please enter the Test Results from Item 2
     above onto the form contained in the following pages.
4.   Analytical Discussion


     Please furnish explanations or additional information on the
     following topics as necessary:

     a.  Inconsistencies or deviations in the analytical results
         presented above.

     b.  Additional reasons as to why the waste stream should be
         delisted.


The attached material from the International Isocyanate Institute, Inc.
comprises our additional reasons for delisting this waste.
                              1-61

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                   INTERNATIONAL SSOCYANATE SNSTITUTE. INC.
                               P.O. ec* !268
                               71 ELM Srntrr
                            NCW C'XAAW, COMM.
    CABLE
ISOC'f AN».TI-NCW CANAAN. CONN.                                            (2O3i 966-73SS
                                    July  16,  1930
Docket Clerk  (Docket No. 3000)
Office of Solid Waste  (WH-562)
United States Environmental Protection Agency
401 M Street, S.W.
Washington, D. C.  20460

Dear Sir;

The following comments have been  prepared by the  International  Isocyanat
Institute (III) regarding  the Hazardous Waste Management  System Part 251
Indentification and Listing of Hazardous Waste, Subpart D -  List of
Hazardous Waste as published in the May 19, 1980  Federal  Register
(Vol. 45 No. 98).  Specifically the III would like  to  offer  comments on
the listing of centrifuge  residue from toluene diisocyanate  production
(Section 261.32 EPA Hazardous Waste No. K-027) and  on  the listing of
Urethane (Section 261.33 of EPA Hazardous Waste No.  U-238)."

The International Isocyanate Institute, Inc., was four.ded August 18. IS",
as a non-profit Corporation.  It  is organized under the laws of the
United States and is registered in the State of New York. As presently
constituted, the Institute has 22 members who are located in tne Americ;
Europe and Japan.  To  qualify for Membership, a company ccust be engaged
in the manufacture of  Isocyanates.  A list  cf the present Member Compan
will be found on the last  page of thi^ submission.
           /
Centrifuge/residue from toluene tliisocyanata production has been designa
as hazardous waste No. K-027 in Section 261.32 of the  May 19th,  1980
Federal Register Regulations.  The EPA listed both  toxicity  and raactiv
as the properties that allegedly  qualify this material for inclusion or
the list.Examination of the  listing background docunent  (Document #11
pp 431-432) produces several questions relative to  the accuracy of this
data, and therefore, the validity of the hazardous  waste  designation,.

The following comments are offered for the  Agency's consideration rela;
to the listing of TDI  centrifuge  residue as a hazardous waste:
                                 1-62

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 I.   The EPA  characterizes  the waste from TDI production as centrifuge
 residues in the  Federal  Register  while the background document makes
 reference  to  "Evaporator residue  processing centrifuge or vacuum dis-
 tillation."   It  is  unclear  if the Agency  intends  to limit the scope of
 the  listed material to only the wastes generated  via a centrifuge
 unit operation.

 1.   In general,  each TDI producer  deactiv/ac-33 T13I residue differently
 am!  each firm does  employ some foria of aging or  ?ther means ~f ca-
 activation after  generation ot" t'~;e  final  cist:".!lotion cr centrifuge
 bottoms.   The III believes  <':he lire ing cf TI?I residue n^eds furtner
 clirifi. sf'.on that  it is limited  ".c, cnce.-icuiv/ar.eJ c;at^.rial a* it is
 directly discharged from the 'Jistillatirr-  cr centrifuge unir. operation
 and not de-activated materials..
      If  a TDI  producer  ciec":-'  to  include  additional  processing  steps
(i. 2. hydrolysis,  additional  JistiJ.lar.ior,,  aging,  etc.)  tc  render  the
material less  reactive  or  non-reactive  the;-  the  resultant  material
should be evaluated  again3"  tha criteria  found  in Sub-part C-
Characteristics of Hazardous Warr.'i  261.20  -  £bl./M.

3.    The background  document indicates  -he centrifuge  residue  (contains
toxic organic  substances,  mutagenic  substances  and substances  that  are
probably carcinogenic".  It' further  states that  toluene diisocyanate,
toluene diamine and  polymeric  tars  ara  "suspected carcinogens".
These statements  raise  several questions:

      (a)  It has  not  been  documented  that  all centrifuge residue  contains
toluene diamine.  In  general,  companies indicate   that  either TDA is not
present or if  present it is  only  in  low ppm  concentrations.  The  analytical
techniques used to conduct  this determination are subject  to variability
and are currently being evaluated by  industry.
      (b)  Although the  Federal Register (Appendix VII  of the Hay_ 19,  1980
publication -  basis  for. listing hazardous  wastes) sites benzidimidazapone  as
the principal  compound  in  tars, we  are not aware  cf  the-existence of  this
substance and  any data'that  exists  tc substantiate the  claim  that it  is
mutagenic or carcinogenic.

      (c)  TDI  has not been  declared  a suspect carcinogen.   In  che illOSII
Criteria for a Recommended  Staadar-i...Occupational Exposure tc  Diisocyanates
published in September  1978., there  is the  statement  "Nc  reports were
found to indicate that TDI, MDI, HDI, JDI, or otrer  ciisocyanates produce
carcinogenic,  teratogenic,  or raproductive effects in  hucans or animals."
The Isocyanates as a  class of compounds are  net  listed  in  the 03HA
proposed carcinogen regulations.
                                1-63

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     (d)  Only the meta-isomer of TDA is a suspect carcinogen.

4.   Disposition of raw centrifuge residue in drum quantities in a'
landfill is- generally not practiced as a "known management method
for'this waste."

Therefore, on the basis of apparent inaccuracies in che background
document, the III respectfully requests the EPA to review and
clarify its data and information based on the items enumerated in
this correspondence.

On another matter, the EPA designates urethane as a commercial chemical
product or manufacturing intermediate (Section 261.33f) that will be
subjected to the Hazardous Waste Regulations. (An examination of the
"Urethane" terminology reveals that this term was improperly applied
in 1960.)

It is most imperative that this gross misnomer be corrected.  Twenty
years ago Hueper published a paper (W.C. Hueper. Experimental Productici
of Cancer by Means of Implanted Polyurathane Plastic,  Ar.er .Jour. Clin. ?a
34:  p.334-337, October I960) -   Hueper's work and subsequent work by the
National Cancer Institute was  with etnyl carbaniate (urethan* which he
erroneously thought was synonymous with "urethane".  In spite of con-
siderable effort on the part of some of us to correct  this misnomer
(wnich is even perpetuated by the 1973 Toxic Substances List, No.5015),
polyurethanes continue to be associated with the known human carcinogen
ethyl carbamate or "urethan".

In view of the name  similarity of. urethan (ethyl carbamate) and
polyurethane plastics, it is important to point out the differences
in chemical structure of both compositions in order to avoid
confusion.

It is readily apparent that urethan (ethyl carbamate)  is not a precurso1
of the polyurethanes.  Thus there is no basis for assuming  that any tox
city    characteristics associated with ethyl carbamate in  any way appl;
to the polyurethanes.

The III respectfully requests that to clarify this ambiguity, the EPA
replace urethane (hazardous waste No. U-238 with the proper chemical
terminology - ethyl carbamate.

We would welcome an opportunity to discuss this matter further with you
or other appropriate EPA personnel.  If  you have any questions or comm
regarding this issue, please do not hesitate to call me.
                                   Sincerely,
                                   Arthur B. Chivvis
                                   Managing Director
ABC:vor

                                  1-64

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                  APPENDIX J

     TEST METHODS NOT AVAILABLE IN SW-846

     Extraction Procedure for Oily Wastes
             Total Organic Carbon
             Total Oil and Grease
Determination of Reactive Cyanide and Sulfide
   Determination of Photodegradable Cyanide
               -Explosive Hazard

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                       EP TOXICITY TEST FOR OILY WASTE

                     (Proposed as Method 1330  in SW-846)

1.    Separate the sample (minimum 100 gm)  into its  solid and liquid compo-
     nents.   The  liquid component is  defined as  that  portion of  the sample
     which passes through a 0.45  urn filter media under a pressure  differen-
     tial of 75 psi.

2.    Determine the quantity of liquid (ml) and the  concentration of the
     toxicants of concern in the liquid phase (mg/1).

3.    Place the solid phase into a Soxhlet extractor,  charge the  concentration
     flask with tetrahydrofuran,  and extract for 3  hours.

4.    Remove the flask containing tetrahydrofuran and replace it with one
     containing toluene.

5.    Extract the solid for a second time,  for 3 hours, with the toluene.

6.    Combine the tetrahydrofuran and  toluene extracts.

7.    Analyze the combined extracts for  the  toxicants of concern.

8.    Determine the quantity of liquid (ml) and the  concentration of the
     toxicants of concern in the combined  extracts (mg/1).

9.    Take the solid material remaining in  the  Soxhlet thimble and  dry it at
     100°C for 30 minutes.

10.  Run the EP on the dried solid.

11.  Calculate the mobile metal concentration (MMC) using the following
     formula:

        MMC = 1000  ([Q1 + Q2 -t- Q31/[L1 + L2])

     Q- = Amount of  toxicant  in initial liquid phase  of sample (amount of
              liquid X concentration  of toxicant) (mg)

     Qj = Amount of toxicant in combined organic extracts of sample (amount  of
              liquid X concentration  of toxicant) (mg)

     Q3 = Amount of toxicant in EP extract of  solid (amount of extract X
              concentration of toxicant)  (mg)

     LI = Amount of initial liquid (ml)

     L2 = Amount of liquid in EP = weight of dried  solid from step 9 X 20 (ml)
                                    J-3

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                            TOTAL  ORGANIC CARBON
                    Method 415.1  (Combustion  or Oxidation)
                    (Proposed as  Method  9060  in SW-846)
1.    Scope and Application

     1.1    This method includes the measurement of organic  carbon  in  drinking,
           surface and saline waters,  domestic  and industrial  wastes.  Exclu-
           sions are noted under Definitions and Interferences.

     1 .2    The method is most applicable  to  measurement of  organic carbon
           above 1 mg/1.

2 .    Summary of Method

     2.1    Organic carbon  in a  sample  is  converted to carbon dioxide  (CO-) by
           catalytic combustion or wet chemical oxidation.   The C02 formed can
           be measured directly by an  infrared  detector or  converted  to me-
           thane (CH4) and measured by a flame  ionization detector.   The
           amount of C02 or  CH, is directly proportional  to the concentration
           of carbonaceous material in the sample.

3.    Definitions

     3.1    The carbonaceous  analyzer measures all of the carbon in a  sample.
           Because of various  properties  of  carbon-containing  compounds in
           liquid samples, preliminary treatment of the sample prior  to analy-
           sis dictates the  definition of  the carbon as it  is  measured.  Forms
           of carbon that  are measured by the method are:

           A)    soluble, nonvolatile organic carbon;  for  instance, natural
                sugars.

           B)    soluble, volatile  organic  carbon;  for instance, mercaptans.

           C)    insoluble, partially volatile carbon; for instance, oils.

           D)    insoluble, particulate carbonaceous materials;  for instance,
                cellulose  fibers.

           E)    soluble or insoluble carbonaceous materials adsorbed  or
                entrapped  on insoluble inorganic suspended  matter; for in-
                stance, oily matter adsorbed on silt particles.

     3.2    The final usefulness of the carbon measurement is in assessing the
           potential oxygen-demanding  load of organic material on a receiving
           stream.   This statement applies whether the carbon  measurement is
           made on a sewage  plant  effluent,  industrial waste,  or on water
           taken directly  from the stream.  In  this  light,  carbonate  and
           bicarbonate carbon  are  not  a part of the  oxygen  demand in  the
           stream and therefore should be  discounted  in the  final calculation
                                    J-5

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           or removed prior to analysis.  The manner of preliminary treatment
           of the sample and instrument settings  defines  the  types  of  carbon
           which are measured.   Instrument manufacturer's instructions should
           be followed.

4.   Sample Handling and Preservation

     4.1    Sampling and storage of samples in glass bottles is preferable.
           Sampling and storage in plastic bottles  such as conventional poly-
           ethylene and cubitainers is permissible if it  is established that
           the containers do not  contribute  contaminating organics  to  the
           samples.

           NOTE  1:  A brief study performed in the EPA Laboratory indicated
           that distilled water stored in new,  one  quart  cubitainers did not
           show any increase in organic carbon after two  weeks exposure.

     4.2    Because of  the possibility of oxidation  or bacterial  decomposition
           of some components  of  aqueous samples,  the lapse of time between
           collection of samples and start of analysis should be kept  to a
           minimum.  Also,  samples  should be kept cool  (4°C)  and protected
           from sunlight and atmospheric oxygen.

     4.3    In instances  where  analysis cannot be  performed  within two  hours (2
           hours) from  the time of  sampling,  the  sample is  acidified (pH<2)
           with HCl or H2SO4.

5.   Interferences

     5.1    Carbonate and bicarbonate carbon  represent an  interference  under
           the terms of  this  test and must be  removed or  accounted  for in the
           final calculation.

     5.2    This procedure is applicable only to homogeneous samples which can
           be injected  into the apparatus  reproducibly by means  of  a micro-
           liter type syringe or  pipette.  The openings of  the syringe or
           pipette limit the maximum size of particles which may be  included
           in the sample.

6.   Apparatus

     6.1    Apparatus for blending or homogenizing samples:  Generally  a
           Waring-type  blender is satisfactory.

     6.2    Apparatus for total and  dissolved organic carbon:

           6.2.1   A number of  companies manufacture systems for  measuring
                  carbonaceous material in liquid samples.  Considerations
                  should be made  as  to the types of samples to be analyzed,
                  the  expected concentration range,  and forms  of carbon to  be
                  measured.

           6.2.2  No specific  analyzer is recommended as  superior.
                                    J-6

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 Reagents

 7.1    Distilled water used in preparation of standards  and for dilution
       of samples should be ultra pure to reduce  the  carbon concentration
       of the blank.   Carbon dioxide-free, double distilled water  is
       recommended.   Ion exchanged waters are not recommended because  of
       the possibilities of contamination with organic materials from  the
       resins.

 7.2    Potassium hydrogen phthalate stock solution,  1000 mg carbon/liter:
       Dissolve 0.21 28 g of potassium hydrogen phthalate (Primary  Standard
       Grade)  in distilled water and dilute  to 100.0  ml.

       NOTE 2:  Sodium oxalate and acetic acid are not recommended as
       stock solutions.

 7.3    Potassium hydrogen phthalate,  standard solutions:  Prepare  standard
       solutions from the stock solution by dilution  with distilled water.

 7.4    Carbonate-bicarbonate stock solution,  1000 mg  carbon/liter:  Weigh
       0.3500  g  of sodium bicarbonate and 0.4418 g of sodium carbonate and
       transfer both  to the  same 100 ml  volumetric flask.  Dissolve with
       distilled water.

 7.5    Carbonate-bicarbonate,  standard solution:  Prepare a series of
       standards similar to step  7.3.

       NOTE 3:  This  standard  is not required by  some instruments.

 7.6    Blank solution:  Use the same distilled water  (or similar quality
       water)  used  for the preparation of the standard  solutions.

 Procedure

 8.1    Follow instrument manufacturer's instructions  for calibration,
       procedure,  and calculations.

 8.2    For calibration of the instrument, it is recommended that a series
       of standards  encompassing the expected concentration range  of the
       samples be used.

 Precision and Accuracy

 9.1    Twenty-eight analysts in twenty-one  laboratories  analyzed distilled
       water solutions containing exact increments of oxidizable organic
       compounds, with the  following results:

Increment as           Precision as                  Accuracy as
   TOC           Standard Deviation         Bias,                 Bias,
  mg/liter            TOC,  mg/liter            %_                mg/liter

   4.9                    3.93               +15.27                +0.75
    107                    8.32               + 1.01                +1.08

               (FWPCA Method Study 3, Demand Analyses)
                                J-7

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                                 Bibliography

1.   Annual  Book of ASTM Standards,  Part 31,  "Water", Standard D 2547-79, p  469
    (1976).
2.   Standard  Methods  for the  Examination  of  Water  and Wastewater,  14th  Edi-
    tion, p 532,  Method 505,  (1975).
                                    J-8

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                  EXTRACTION  METHOD  FOR  TOTAL OIL AND GREASE

       (Proposed as  Methods 9070  (liquids)  and  9071  (solids) in SW-846)


1.   General Discussion

      a.   Principle:  Drying  acidified sludge by heating leads to low results.
          Magnesium sulfate monohydrate is  capable  of combining with  75% of
          its own weight in water forming the heptahydrate  and is  used  to dry
          sludge. After drying,  the oil and grease can  be  extracted  with
          freon.

      b.   Interference:   See  502C.1b.

2.   Apparatus

      a.   Extraction apparatus,  Soxhlet.

      b.   Vacuum pump or other source of vacuum.

      c.   Extraction thimble, paper.

3.   Reagents

      a.   Hydrochloric acid,  HCl, cone.

      b.   Magnesium sulfate monohydrate. Prepare MgS04  H20 by overnight
          drying of a thin layer of MgSO4'7H20 in an oven at  103°C.

      c.   Freon  (1,1,2-trichloro-1,2,2-trifluoroethane),   boiling  point 47°C.
          The solvents should leave no  measurable  residue on evaporation.
          Distill if  necessar-y.

      d'.   Grease-free cotton:  Extract  non-absorbent cotton with freon.

4.  Procedure

    In a 150 ml  beaker weigh a sample of wet sludge 20+0.5 g,  of  which the
    dry-solids  content is known.  Acidify to pH 2.0 (generally 0.3 ml cone.
    HCl is  sufficient).  Add 25 g MgS04*H20.  Stir  to a  smooth paste  and
    spread on the sides of the beaker to facilitate subequent  removal.  Allow
    to stand until  solidified, 15 to 30 min.  Remove the solids and grind in a
    porcelain mortar.  Add the powder to a  paper extraction thimble.   Wipe  the
    beaker and mortar with small pieces of  filter paper moistened with freon
    and add to the thimble.  Fill the thimble with  glass  wool  or  small  glass
    beads.  Extract in a Soxhlet apparatus, using freon,  at a  rate of 20
    cycles/hr  for'4 hr.  If any turbidity  or suspended  matter  is  present  in
    the extraction flask, remove by filtering  through grease-free cotton  into
    another weighed flask. Rinse flask and cotton  with freon. Distill the
    solvent from the  extraction  flask  in water at  70°C.   Place the flask  on  a
    warm steam bath for 15  min and draw air through the  flask  by  means of an
    applied  vacuum  for  the final 1  min.  Cool  in a desiccator  for exactly 30
    min and  weigh.
                                    J-9

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5.  Calculation


             ...         ,.,       gain  in weight of flask, g X 100
    Grease and oil  as  % solids  =    ~—rr—7	r2—rri	~^	r- ^
                                 weight  of wet solids, g X %dry solids




6.  Precision




    The examinination  of six replicate samples of sludge yielded a standard

    deviation of 4.6%.
Source:   Standard Methods For the  Examination  of Water  and Wastewater, 14th

         edition,  pp.  519-520.
                                    J-10

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                   TEST METHOD FOR THE DETERMINATION OF
              REACTIVE CYANIDE AND SULFIDE CONTAINING WASTES
                               FINAL METHOD

1.  Scope and Application

    1.1  This method is applicable to water, vastevater and industrial wastes.
    1.2  This method provides a fast and simple method to determine if a
         waste is a reactive waste as a result of its tendency to release
         toxic levels of hydrogen cyanide or hydrogen sulfide upon contact
         with acidic medium.  The approach is based on a reasonable "worst
         case" disposal scenario.

    1.3  This method is designed to measure only the hydrogen cyanide and/or
         hydrogen sulfide gas evolved at the test conditions and not to re-
         flect the total concentration of these gases, or their precursors,
         in the sample.  Variations in temperature, ionic strength and total
         volume of the test solution will affect the amount of gas evolved.
         The total volume of solution is kept constant from test to test.
         Temperature and ionic strength are not controlled as they are in-
         herent properties of each waste.

2.  S"™ary of Method
    2.1  An aliquot of the waste is acidified to pH 2 in a closed system.
         The gas generated is swept from the reaction chamber using a pump
         and passed through a calibrated gas detector tube.  The detector
         tube reading is used to calculate the concentration of gas evolved.

3.  Sample Handling and Preservation

    3.1  Samples containing, or suspected of containing sulfide or a com-
         bination of sulfide and cyanide wastes, should be collected with
         a minimum of aeration.  The sample bottle should be filled completely,
         excluding all head space, and stoppered.  Analysis should commence
         as soon as possible and samples should be kept in a cool, dark place
         until analysis begins.
    3.2  Samples containing or suspected of containing cyanide wastes without
         the presence of sulfide compounds, can be preserved if analysis can
         not begin immediately.  Samples are preserved by adjusting to pH 12
         with strong sodium hydroxide solution and storing in a cool, dark
         place.
    3.3  Determination should be performed in a well ventilated hood.

4.  Interferences
    4.1  The analyst should consult manufacturers' literature on the type and
         natur* of potential interferences when using specific detector tubes.

5.  Apparatus
    5.1  Three neck round bottom flask with 24/40 ground glass joints, 250 mL.

    5.2  Magnetic stirrer bar with magnetic stirring apparatus.

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    5.3  Separator? funnel with pressure equalizing line and 24/40 ground
         glass joint, 125 mL.

    5.4  Straight glass adapter tubes with ground glass joint 24/40 and rubber
         adapter sleeve, 2 each.

    5.5  Flexible tubing to make connection from detector tube to pump.

    5.6  Detector tubes:  HCN detector tube with range of 10-120 yL (Draeger
         67 28441 or equivalent).  H2S detector tube with range 5-60 uL
         (Draeger 67 28141 or equivalent).

    5.7  pH meter and pH electrode of sufficient length to reach liquid level
         (approximately 13 cm).

    5.8  Pump capable of pulling 60 mL per minute ± 3 mL per minute (MSA
         Model C-210 or equivalent).

    5.9  Bubble meter for calibrating pump.

    5.10 Stopwatch.

6.  Reagents

    6.1  Sulfuric acid,  H2SOU, 1 U.

    6.2  Cyanide Reference Solution:  Dissolve approximately 2.5 g KOH and
         2.51 g KCN in one liter distilled water.  Concentration approximately
         1 mg/mL.

    6.3  Sulfide Reference Solution:  Prepare from crystals of sodium sulfide
         as described in Method 376,2 (Sulfide, Colorimetric, Methylene Blue)
         Section 5.8 of Methods for Chemical Analysis of Water and Wastes,
         EPA 600/4-79-020, March, 1979.  The solution may be standardized by
         the titrimetric iodine Method 376.1 of the same publication, al-
         though this is not required.

7.  System Check

    7.1  The operation of the system can be checked using the cyanide or
         sulfide reference solutions.  It is difficult to predict a detector
         tube reading from a known amount of reference solution due to vari-
         ations in response of detector tubes of different sources.  Reaction
         flask temperature variations and total volumes also influence the
         amount of gases evolved.  However, the reference solutions can be
         used to verify system operation and replicates can be expected to
         agree to within approximately ± 20%

8.  Procedure

    8.1  Place 10g* of the waste to be tested into a beaker.  Add approximately
         80 mL deionized water and determine the amount of 1 II H2SOU required
         to adjust pH to 2.0.

    8.2  Place a second 10g* aliquot of the waste into the 250 mL round bottom
         flask.  Add deionized water in an amount so that the sum of Che volume
         of water and the volume of 1 jfl H2SOU required for pH adjustment, will
         equal 100 mL.

   *  or 10 mL
                                    J-12

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    8.3  Assemble the apparatus as shovn in Figure 2 using the proper de-
         tection tube or tubes (see Figure 1).
    8.4  Calibrate the pump in line to a flow of 60 mL/min ± 3 mL/min using
         the bubble meter attached to the pump outlet.  The flow can be
         checked during and after the test period.
    8.5  Begin stirring and make sure all connections are tight.
    8.6  Carefully adjust the test solution to pH 2.0 using the 1 N H2SOU.
    8.7  Note the readings of stain length at five minute intervals.  If the
         length of the stain exceeds the capacity of the detector tube, re-
         analyze using a smaller aliquot.  If very little or no stain develops,
         the aliquot size may be increased, depending on the nature of the
         sample.  Solid samples require a certain amount of dilution to reach
         a slurry state so that the acid may contact all portions of the sample
         and so that stirring may take place.

    8.8  Continue to monitor Che pH of the test solution, adjusting if neces-
         sary to maintain at pH 2.0.  Continue the pump operation for 30 min.
         from the time of initial pH adjustment.

    8.9  Stop the pump and record the final reading on the detector tube.

         Note 1:  The chemistry of some detector tubes may permit their
                  use in series to determine both H2S and HCN concurrently.
                  With the use of the Draeger detector tubes mentioned in
                  Section 5.6, the H2S tube must be first tube in the system.
                  Other detector tubes may operate differently.

         Mote 2:  As an optional step to determine a "total" evoluable gas
                  yalue, at the end of 30 minutes, the pH can be lowered to
                  less than pH 1 and a sand bath used to elevate the tempera-
                  ture.  Increased evolution rates may be observed from some
                  samples.

9.  Calculations

    9.1  The concentration of gas evolved may be calculated as follows:
         ppm gas evolved (3CN or 3sS)/g or mL *
                     final detector tube reading (ML)	
                  volume of gas passed through detector tube (L) x aliquot
                                                                   (g or mL)
         and:
                  volume of gas passed through detector tube (L)*
                     pump flov rate (mL/ain) X length of test (min)
                                     1000

    9.2  The time of maximum gas evolution rate can be determined by com-
         paring the rate of change over each five minute period to the
         elapsed time.
                                    J-13

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10. Precision and Accuracy

    10.1  The precision of the method as determined by evaluation on  standards
          can be  expected  to be approximately ± 17%.

    10.2  The accuracy of  the  method cannot be  determined directly due to
          the difficulty of providing a sample  of known gas evolution
          qualities.   Calibration of the detector tubes used in
          method  (see Section  5.6)  with standard  gas mixtures indicate
          the bias of  the  H2S  tubes  to  be approximately + 162 at  20*C
          and the bias of  the  HCK tubes to  be approximately + 35Z at  20°C.
                                FIGURE 2

                            TEST APPARATUS

                            FINAL METHOD
        Class Tub*
                                               Detector Tube
                                                                     •Outlet
                Waste
                Staple
                        Stir
                                     J-14

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                                    MtTHOD  9011

              Method  for the Determination  of Photodegradable  Cyanides


1.0  Scope and Application

     1.1  Method 9011 1s used for the  determination  of  photodegradable  cyanides  in
          wastes under hypothetical  field  conditions.   It  is used  to determine
          whether particular wastes  will  form releasable cyanides  (cyanide  amenable
          to cnionnate) as a result or  exposure to  UV  radiation.

2.U  Summary ot Method

     2.1  Four representative waste  samples are  tested, tach  sample is split  into
          two equal  portions.  One portion is suojected to UV  irradiation oy a  low
          pressure mercury  arc lamp  to test for  pnotodegradation.   During irradation,
          any HCN evolved is trapped in  the gas  absorber.   After photolysis is
          completed,  each portion is analyzed according to method  9010.  The presence
          of photodegradable cyanides  is determined  by  the differences  in results.

3.U  Interferences

     3.1  Refer to Method 9010

4.U  Apparatus and Materials

     4.1  Quartz tube, (1.26 cm I.D. x 15 cm, "Vycor"  brand from corning, or 11-
          Jb9E in Fisher catalogue)  witn provision for air inlet and  vacuum outlet,
          transparent to UV frequencies greater than 220nm.

     4.2  Low pressure mercury lamp (G15T3 lamp, General  Electric or  equivalent
          capable of emitting UV radiation at a frequency  Deiow JUOnm).

     4.3  Microburet; refer to Method 9U1U.

     4.4  Flasks, condenser, and tubing are needed as shown in Figure 1.   Ine
          boiling flasn should be of 1-liter size witn inlet tune and provision for
          a condenser.  The gas absorber may oe a Fisher-Mi I Iigan scrubber.  Assemoie
          as shown in Figure 1.

b.U  Keagents

     b.l  Refer to Method 9010.

6.0  Sample Collection, Preservation and Handling

     6.1  Refer to Method 9010.

7.U  Procedure

     /.I  fest  for interferencs according to the procedure in Method yuiu.

     7.2  Take  a 20  gram sample of waste and split into two 10 gram portions.

     7.3  Analyze one portion  (A) for total and amenaoie cyanide according  to Method
          9uio.


                                      J-15

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     7.4  Take the second 10 gram portion (8) of the sample and place in a quartz
          tube.
          7.4.1     Connect quartz tube inlet to an air source and the tuoe outlet
                    to tne adsorber as specified in procedure 7.3 in Method yuiu.
          7.4.2     Using the mercury arc lamp at a distance of twelve inches from
                    tne quartz tube, irradiate for tnirty minutes wniie drawing air
                    through the system.
                    Caution:  Low pressure mercury arc lamps emit high energy ultra-
                    violet radiation,  use caution to avoid exposing eyes or skin.
          7.4.3     Determine the presence or total and amenable cyanide according
                    to procedures 7.J - 7.5 in Method yulO on tne sample in the
                    quartz tube.
          7.4.4     [Determine the amount or (JN in the scruooer.
     /.b  Keport results for the rive measurements from each sample.
          hXAMPLE:                   Cw m Pf1^
                            lotal             Cn Amenable               Scrubber
          Sample 1A         82.5                 10.4
          Sample 18         63.1                 21.8                     5.7
          This example would result from a sample which converted complexed
          cyanide to amenable.
     7.6  Spiked standards and check standards should be routinely analyzed.
a.O  Quality Control
     8.1  All quality control data should be maintained and available for easy
          reference and inspection.
     8.2  Employ a minimum of one blank per sample batch to determine if contamination
          or any memory effects are-occurring.
     8.J  Analyze check standards after approximately every Ib samples.
     8.4  Run one duplicate sample for every iO samples.  A duplicate sample is  a
          sample brought through the whole sample preparation process.
     8.b  Spiked samples or standard reference materials snail be periodically
          employed to ensure that correct procedures are being followed and that
          ail equipment is operating properly.
     a.b  The method of standard additions shall be used for the analysis of aii
          samples tnat surfer from matrix interferences.
                                       J-16

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Air Inlec Tube
           Quartz  Tube
                                     Connecting Tube
                                            \\\
                                           I II
           fr
                              Gas  Absorber
¥
                                                             Suction
            Figure  1.   Apparatus  for  Cyanide  Distillation
                                 J-17

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                                          EXPLOSIVE REACTIVITY

                (From  "Department  of  Defense Explosives Hazard  Classification
                 Procedures,"  Army Technical Bulletin  700-2,  September  1982)
 5-1.  General,   a.  This chapter prescribes tests
 that are required by Title 49 Code of Federal Regula-
 tions for transport purposes and by STANAG No. 4123
 and  DOD  for  the establishment of  storage  hazard
 classification.
   b.   Lethal and  incapacitating  chemical  munitions
 will  be  tested  under criteria which  are unique  to
 chemical weapons.
   c.   Binary chemical munitions will be classed in ac-
 cordance with their industrial chemical hazards until the
 essential components are combined with their explosive
 components at which time paragraph b above applies.

 5-2.   Transport    Testing     Require-
 ments,  a. These tests must be conducted prior to
 shipment in commerce of any explosive or propellant
 composition except liquid explosives and are intended to
 develop  data on stability and sensitivity of  new com-
 positions of bulk explosives and  solid  propellants to
 determine if they are safe to handle, transport and store.
 Laboratory samples are used, with weights and dimen-
 sions limited to  the minimum necessary for drawing
 conclusions. Preliminary testing  with  even smaller
 samples is recommended to provide test personnel with
 an indication of hazards to be encountered.  The tests
 specified in this paragraph generally do not require in-
 strumentation other than that normally associated with
 the equipment involved, e.g., ovens for thermal stability
 tests.
   b.   Recording of data.  The results of tests perform-
 ed under this paragraph are to be recorded in a manner
 simtlar to that shown in figure 5-1. The format shown is
 intended only as a guide and maybe modified as re-
 quired to fit a particular test program.
   c.  Instrumentation.  Due to the limited quantity of
 material  involved in these  tests,  instrumentation to
 record  peak  pressure,  impulse,   and   ambient
 temperature as well as high speed photography may be
 eliminated.
   d.  Equipment.  The  following equipment  is  re-
quired for tests under this paragraph:
    (1)  One Bureau of Explosives impact apparatus.
Drawings are available at the Bureau  of Explosives,
Association  of  American Railroads,  1920 *L' Street,
NW, Washington, DC 20036.
    (2)  One ventilated explosion-proof oven capable
 of maintaining a temperature of 75 °C or above for a
 period of 48 hours. The oven will be equipped to con-
 tinuously record the temperature. Dual thermostats that
 fail safe will be provided for temperature control.
     (3)   Number 8  electric  blasting caps  or caps  of
 equivalent strength as required. A  number 8 blasting
 cap means  a cap which contains 0.4—0.45 grams  of
 PETN base charge pressed into an aluminum shell with
 bottom thickness not to exceed 0.03 inch, to a specific
 gravity of not less than 1.4 grams/cubic centimeter, and
 primed with standard weights of primer, in accordance
 with the manufacturer's specifications.
     (4)   One blasting  machine or equivalent for in-
 itiating electric blasting caps.
     (5)   Kerosene-soaked sawdust sufficient for three
 beds, 1-foot square and Vi-inch thick.
     (6)   Electric match-head igniters as required.
     (7)   Solid lead cylinders  1 Vi -inch diameter by 4 in-
 ches high as required.
     (8) One piece of mild  steel plate SAE 1010 to 1030,
 '/i-inch thick by  12 inches square.
     (9)   Mild steel plates  (SAE 1010 to 1030) 6-inch  x
 6-inch x  3/8-inch as required.
     (10)  Tubing,  steel,   cold  drawn   seamless,
 mechanical, composition  1015,  1-7/8 inch OD,  0.219
 inch wall thickness variations ± 10 percent acceptable
 by 5Vi inches long as required.
     (11)  Cellulose  acetate,  or  equivalent,   cards,
 2-inch diameter by 0.01-inch  thick as required.
     (12)  Wire (demolition cable) as required for con-
 necting blasting machine to electrically initiated items.
     (13)  Engineers  special electric blasting caps (J-2)
 as required.
     (14)  Two inch  diameter by 1-inch  long pressed
 pentolite pellet, National Stock No. 1375-991-8891 as
 required.*
  e.  Test samples.  The following test samples are re-
 quired for this paragraph:
     (1)  Twelve samples 2 ± '/<-inch cubes. (Cardboard
 containers of comparable  size to be used for granule;
 substances.)
     (2)   Ten lOmg (approx) samples suitable for use :ii
the Bureau of Explosives impact apparatus (0.20 in. ±
.02 in. diameter x 0.10  in. ±  .02 in. long).
   •Available from:  Commanding  Officer,  Navy  Ships  Parts
    Control Cnuer, Mtvharucsburg, PA. 17055, ATfN:  Code 370.
                                                 J-19

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                                                 Date
Sponsoring Agency

Contract No.
Explosive or Propellant Identity  (Type  No.)

Spec.  	  Batch
Mfg. Date
Detonation Test


No. 8 Blasting Cap Test 1
                   Test II
                   Test III
                   Test IV
                   Test V

Samples:  Five 2-inch cubes.
    Detonated
    Yes  No
Burned
Yes  No
Fragmented
 Yes  No
    Test:  One blasting cap per  sample4
Ignition & Unconfined Burning Test

One 2-inch cube
One 2-inch cube
Four 2-inch cubes
Samples:  Six 2-inch cubes.
       Exploded
       Yes  No
   Average Burning Time
         Seconds
Test:  48 hours at 75°C in vented  oven.
Card Gap Test
     50% Value
     (No. of Cards)
Impact Sensitivity Test
                        Bureau of Explosives Impact Apparatus
     Ten 3 3/4" (+ 1/16") Drop Test
               lO~Trials
      Ten 10" (+ 1/16") Drop Test
               To Trials
Number of Trials Exhibiting
Explosion
Flame and
Noise
Decomposition
Smoke
No Noise
No 'Reaction
No Smoke
No Noise
Number of Trials Exhibiting
Explosion
Flame and
Noise
Decomposition
Smoke
No Noise
No Reaction
No Smoke
No Noise
Approved:
   Test Director
 Test Department Head
Assigned Classification
DOT Forbidden
DOT Restricted*
DOT Class A
DOT Class B
DOT Class C
UN Number






                                                  DOD Approval  (see  para 3-2)
                                       Signature

                                       Title
                                       Organization
     *Shipping instructions are to be requested from DOT.
                        Figure 3-1. Sample summary data sheet.
                                    J-20

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     (3)  Samples  sufficient to fill 12  each of  item
 5-24(10) above (para 5-2y'(l)(b).
   /. Detonation test.
     (1)  Place one  lead  cylinder  (5-24(7))  upon the
 steel plate (5-24(8)). Place a No. 8 blasting cap (5-24(3))
 perpendicular to and in contact with a flat surface of the
 2-inch cube sample (5-2e(l)) which is then placed on top
 of the lead cylinder. A 2-inch diameter wood block with
 a hole drilled in its center similar to  that shown in figure
 5-2 may be used for positioning the  blasting cap. Defor-
 mation (mushrooming) of the lead cylinder 1/8-inch or
 more will be considered as evidence  of detonation. Con-
 duct this test a minimum of five times, or until detona-
 tion occurs, whichever is  the least number of tests.
     (2)  Data from this test will  be  recorded under
 Detonation Test.
   g.  Ignition and unconfined burning test.
     (1)  Place a 2-inch sample (5-2e(l)) on a bed  of
 kerosene-soaked  sawdust (3-24(5)),  and  ignite the
 sawdust with  an electric match-head igniter (5-24(6)).
 Perform this test twice.
     (2) Place  four 2-inch (5-2e(l))  samples end-to-end
 in a single row in contact with each other on a single bed
 of kerosene-soaked sawdust (5-24(5)) and ignite the
 sawdust with an electric match-head igniter (5-24(6)) at
 one end.
     (3)  Record results under Ignition and Unconfined
 Burning Test.
   h.   Thermal stability test.
     (1)  Place one 2-inch sample (5-2e(l)) in constant
 temperature explosion-proof oven (5-24(2)).  Raise the
 temperature of  the oven to  75°C  and  maintain the
 temperature at 75°C  for a period  of 48 hours.  The
 temperature will be continuously recorded.  Constant
 observation is not required.
     (2)  Record results under Thermal Stability Test.
   /.   Impact sensitivity test.
     (1)  This test need not  be conducted if:
       (a)  The  substance  did  not detonate  in the
 detonation test (para 5.If),  or
       (b)  The substance is in a granular or powder
 form encased into a finished article and is not to be tran-
 ported in bulk containers, or
       (c)  The substance detonated in the detonation
test (para 5.2f) and is to be cast, pressed or extruded in-
to cases.
     (2)  Conduct ten individual tests at each height us-
 ing one sample (5-2e(2)) per test in the Bureau of Ex-
 plosives impact apparatus (5-24(1)).
    (3)  The  sample  (5-2e(2))  is  placed in the  cup
assembly, the  weight is then dropped from the desired
height (from 3-3/4" 10 times). If no explosion occurs,
 repeat the test  dropping the weight from 10-inches.
 Observe results to supply data as required under Impact
 Sensitivity.
     (4)  Use  cleaning  equipment  as  required   to
 thoroughly clean and dry the anvil and cup assemblies
 of the impact apparatus prior to each test. Apparatus
 must be at ambient temperature (room  temperature)
 25°C ± 5° prior to each test.
     (5)  Check that the equipment is properly leveled
 and replace the  tools when worn.
  j. Card gap test.
     (1)  Materials required for each test are as follows:
       (a)  One each tubing (5-24(10))
       (b) Sample  (5-2e(3)) cast  into or  machined  to
 fit into above tubing.
       (c) Two  pentolite pellets 2-inch diameter by 1
 inch long 5-24(14).
       (d)  One Engineers  Special  Blasting Cap J-2
 (5-24(13)).
       (e)  One steel plate 6-inch x 6-inch x 3/8-inch
 (5-24(9)).
       (0  Cellulose acetate,  or   equivalent,   cards
 2-inch diameter x  0.01-inch thick (5-24(11)).
       (g)  Four pieces of plastic material 1/16-inch  x
 '/i-inch  x '/i-inch.
     (2)  Test configuration. The components of the
 test  are arranged in the following manner. The witness
 plate is supported  on two edges parallel to and approx-
 imately 6 inches above the ground surface. Four small
 pieces of plastic material 1/16-inch x '/2-inch are placed
 on the plate to support the pipe containing the test sam-
 ple,  and maintain the 1/16-inch air gap, which should
 not  overlap onto the propellant or explosive. The air
 gap  between  the acceptor and witness plate should be
 free of solid  material. The test sample is to be located
 approximately in the center  of the witness plate. The
 pentolite booster is then placed on top of and in contact
 with the sample at the top of the pipe and  the J-2
 blasting cap attached. The arrangement of components
 for this test is similar to that shown in figure 5-2 except
 the cellulose  acetate cards and the cardboard tube are
 omitted in the first test.  Detonation is indicated when a
 clean hole is cut in the witness plate. The test sample and
 explosives booster are to be at a temperature of approx-
 imately 25°C ±  5° at time of test. Should no detonation
 occur in the first test, it will be repeated two times for a
total of three tests. If detonation occurs, proceed to
paragraph 5-2y(3)).
     (3)  The following tests are to be performed when
the test sample detonates in the above tests (5-2/(2)).
If no detonation of the test sample occurs in the above
tests, this test will not be performed.
                                                   J-21

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ENGINEERS SPECIAL
BLASTING CAP (J-2)
WOOD BLOCK
PENTOLITE BOOSTER


CARD GAP CELLULOSE
ACETATE CARDS
0.01 INCH EACH
PROPELLANT OR
EXPLOSIVES COMPOSITION
SAMPLE
CARDBOARD TUBE
STEEL TUBE
1/16 INCH AIR GAP BETWEEN
STEEL TUBE AND PLATE
3/8 INCH
WITNESS PLATE
WOOD STAND
GROUND
      FIGURE 5-2. SET-UP FOR CARD GAP TEST
                       J-22

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        (a)   The test  samples, high explosive boosters
  and witness plates used in these tests  are as given in
  paragraph 5-2y'(l) above.  The attenuation  cards  used
  are  0.01-inch cellulose  ace^:? sheet  or  equivalent
  (S-2d(l 1)). These tests are to be conducted with :!ie test
  sample and booster at a temperature of approximately
  25°C  ±5° throughout." The test setup is as shown in
  figure 5-2.  The cellulose acetate cards  should be  held
  firmly but not pressed.
        (b)   The first test to be performed will utilize 8
  cards; if a detonation occurs, the number of cards will
  be doubled (i.e., 16 cards) for the second  test. If no
  detonation occurs, reduce the number of cards by  one-
 • half (i.e., 4 cards). Doubling of the number of cards will
  be continued in succeeding tests until no detonation oc-
  curs. When a number of cards is reached that prevents
  detonation, the next  test will  be with  the number of
  cards reduced by half the preceding increment of in-
  crease (i.e., if detonation occurs at  32 cards but not at
  64 cards, the next test will be with 48 cards). If detona-
  tion  occurs at the reduced number of cards (48 cards in
  the example cited above) the number of cards in the  next
  test will be  increased by one-half the preceding incre-
  ment (i.e., from 48 to 56 cards), etc.  This procedure will
  be followed until the point of 50 percent probability of
  detonation is obtained. If the card  gap  sensitivity  of a
  similar  propellant  or explosive composition is known
  testing should begin at approximately that number of
 cards.
        (c)  Detonation is indicated when a clean hole is
 cut in the witness plate. The measure  of charge sensitivity
 is the length of attenuation (gap length) at which there is
 50 percent probability of detonation according to the
 above criterion. The charge sensitivity will be expressed
 in terms of number of 0.01-inch cards necessary for the
 50 percent value between detonation  and  no detonation.
 Normally, a maximum of 12 tests will  be required to
 detemine the 50 percent value.

 5-3.    Tests   Required   by  STANAG  4123
 and   Department  of  Defense for  Storage
 Hazard Classification.
  a.   The following tests will be performed  on  end
 items:
    (1)  Single package test — uses internal source of
 ignition or detonation,  respectively,  for  items that  are
 expected to deflagrate or detonate, to cause article(s) to
 function in order to ascertain the violence and extent of
 deflagration or propagation of detonation, and to assess
 the external hazard. Where more than one initiator is
 present,  the  initiator capable of producing  the most
energetic reaction will be functioned.
      (2)   Stack test — uses internal source of ignition or
  detonation, respectively, for items that are expected to
  deflagrate or detonate, to ascertain the violence and ex-
  tent of deflagration or prepigation of detonation, and
  to assess the external hazard when one iicrn or package
  in a stack of five unpackaged items or five packages of
  items is ignited or initiated. In special cases the DODC
  may specify a different number.
      (3)   External fire, stack test — to ascertain the ef-
  fect of fire external to the items or packages and, in the
  event that the  fire causes deflagration, detonation,  or
  explosion, to ascertain the violence and extent of pro-
  pagation and the external hazard.
   b. Test program.
      (1)  The simplest program of tests to prescribe is
  that any new item should be subjected to each of the
  three  types  of  tests, with  appropriate  replication.
  However,  this  would often waste effort  and money
  because it is not  always necessary to perform all the
  tests. Certain types of ammunition and certain results in
  the early  tests  permit short cuts in the program.  The
  flow chart figure 5-3 shows appropriate combinations
  of tests.
     (2)  Replication of tests.  It is usual to perform the
  single package  test three times at least,  to demonstrate
  that the observed effects are  reasonably reproducible.
  Though this limited amount of replication s statistically
  insignificant, it does provide the possibility to detect any
  gross mistakes  in the conduct of the tests and does
  enable a controlling authority to exercise judgment  in
  the interpretation of results.  Furthermore, in those tests
  where it is possible to observe the proportions of the ar-
 ticles that explode rather than a simple go/no-go result,
 limited replication enables  an experienced  worker to
 assess the  reproducibility of the tests and the level of
 confidence.
     (3)  Curtailment of testing. Some of the classifica-
 fion tests are quite costly so that inevitably there must be
 a compromise between the number of tests performed to
 give a reliable, comprehensive picture of the behavior of
 a product and the requirement for economy.  Sometimes,
 it is possible to curtail the testing program in the light of
 the results  of early tests. For example,  there is no point
 in continuing with a second  and third test  with single
 packages or stacks if the first test gives explosion of the
 total contents. Due caution requires that this result be
 accepted at face  value so  that testing  may proceed
 directly to the next stage in the program. Also there is
 always the  option at any stage  of detonation testing to
assume the worst assessment  (risk of mass detonation)
and to proceed directly to the external  fire test.
                                                   J-23

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   c.   Packaging  to be  recorded.   Records  of tests
 should included details of the method and materials of
 packaging used in the tests, so that the need for further
 tests can be properly judged if the method or materials
 of packaging should be changed at a later date.
   d.   Required instrumentation is given under each
 type test.  Details of this instrumentation are given in
 chapter 6.
   e.    Single package test.
     (1) Scope of test. Figure 5-3 indicates the two cir-
 cumstances when this test may be used as a cheaper pre-
 liminary to the expensive test with a stack of packages.
 In the event of certain favorable results, it is then un-
 necessary to perform the stack  test. The first circum-
 stance is an outer package containing more than one ar-
 ticle. The second is a package containing only a single
 article when it is anticipated that the article will present no
 significant hazard and thus qualify for class division 1.4.
     (2)  Test procedure. Place  the package containing
 the product(s) to be tested on the ground. To provide
 the  necessary confinement, surround and  cover the
 package with sacks or  boxes filled with earth or sand
 creating a barrier in every  direction. In  the case of
 packages  exceedng  1m in any  dimension, the  barrier
 should be at  least  1m  in  every  direction.  Another
 method is  to place the package in  a pit of sufficient
 depth  and cover it with  earth or sand-filled sacks or
 boxes  to the  specified  thickness. An article  near the
 center of the package should be caused to function by
 using its own integral detonator  or igniter or a stimulus
 of similar power to the detonator or igniter. For articles
 which  do not function  by an integral detonator or ig-
 niter, a device which simulates  the detonation or igni-
 tion of one article  near  the center, or other appropriate
 stimulus,* is used. Perform the test a minimum of three
 times unless detonation  of the total content occurs first.
 Blast instrumentation as specified in chapter  6 will be
 utilized. Fragment collection is not  required.
  /. Stack test.
    (1)  Scope of test. Figure 5-3  indicates  four cir-
cumstances in which a  test should be performed in a
stack of five packages or five unpackaged articles. The
term "severe effects" refers  to  effects falling short of
explosion of the total contents (in a package containing
more than one item) but being so  severe or so directional
as to raise doubts about their effect  in a stack.
    (2)  Test procedure. Stack a minimum of five pack-
ages or  unpackaged articles to simulate storage or
 stowage conditions. They should be stacked in such a
 manner that their contents are in a position most likely
 to  cause propagation  of explosion. To provide  the
 necessary confinement,  surround and cover the stack
 with, jacks of boxes filled with earth or sand creatiag a
 barrier 1 meter thick in every direction. An article near
 the centered package or an article most nearly centered
 should be caused to function by using its own integral
 detonator or igniter or a stimulus of similar power to the
 detonator or igniter. For articles which do not function
 by an  integral detonator or  ignitor,  a  device  which
 simulates the detonation or ignition of one article near
 the center, or other appropriate stimulus, is used. Per-
 form the test a minimum of three times, unless an explo-
 sion of the total contents occurs  earlier.  Blast  in-
 strumentation  as specified in chapter 6 will be utilized.
 Fragment collection and analysis as specified in chapter
 6 is not mandatory but is encouraged to obtain addi-
 tional  information on this possible hazard.
  g. External fire, stack test.
     (1)  Scope of test. An external fire test on a stack
 of packages or articles is required. Fragment collection
 and analysis will  be made for each test other than those
 of bulk high explosives  packaged in wooden or fiber-
 board containers. Fragment collection,-blast instrumen-
 tation  and analysis of results as specified in chapter 6
 are to  be employed for each test, except that when the
 anticipated reaction is other than mass explosion, blast
 instrumentation need not be employed.
     (2)  Test procedure. Stack a minimum of five pack-
 ages or unpackaged articles on  a wooden  platform
 about  1m above the ground surface. Place a steel band
 around the stack to maintain it during  the test. Pile
 kindling, or other air dried wood not thicker than 30mm
 beneath the platform and around the stack of packages
 to give  at least one half meter in every direction to pro-
 mote uniform  test results. Drench the kindling with
 about  15 gallons of diesel fuel  or kerosene. Ignite the
 pile on two sides by means of an electric squib, an  ig-
 niting  composition, small arms propellant,  or  other
 suitable means. The test is usually performed once only.

 5-4.   Interpretation   of   Results  and
Transport TeStS.  Results of paragraph 5-2 tesis
 will be interpreted as follows:
  a.  DOT  "Forbidden"  if  the  following  occurs:
  Thermal  stability  test (5-2/0  results   in  either a
detonation,  burning,  or  marked decomposition of  the
sample.
  •For bulk granular propellants, an electric squib and 2 oz. of black powder will be placed within 4-inches of the bottom of the container (49CFR
  173.53v).
                                                   J-24

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I
to
in
                                                     SUBSTANCE OR ARTICLE TO BE ASSESSED
                    PACKAGE CONTAINING MORE
                    THAN ONE ARTICLE
                                 PACKAGE CONTAINING A SINGLE
                               ARTICLE.  OR PACKAGE CONTAINING
                              SUBSTANCE  WITHOUT INNER PACKAGING
                                   SIGNIFICANT HAZARD
                                     NOT EXPECTED
                   SINGLE PACKAGE TESTS
  I
NDTC
  I
                                                     DTC
             NO SEVERE EFFECTS
             SEVERE EFFECTS
                   I	
                                                 NDTC
                                                   I
                           EXTERNAL FIRE TESTS
                                1
                 NDTC
                    DTC
                   l_
      NO EFFECT
     EXTERNAL TO
       PACKAGE
                            DIVISION 1.4S
                                                                                                      	1
                                                                                                      UNPACKAGED ARTICLE
LITTLE EFFECT
EXTERNAL TO
  PACKAGE
                           DIVISION 1.4
MAIN EFFECT
  FIRE OR
 MASS-FIRE
                   DIVISION 1.3
                                                                      SIGNIFICANT HAZARD
                                                                          EXPECTED
                                                                                      MULTIPLE ARTICLE/PACKAGE TESTS
                                                                            DTC

                                                                             I
                                                                     EXTERNAL FIRE TEST
MAIN  EFFECT
 FRAGMENTS
                DIVISION 1.2
DETONATION
 OF TOTAL
 CONTENTS
               DIVISION 1.1
                             FIGURE  5-3.  HAZARD  DIVISION  ASSESSMENT
              LEGEND:
              OTC- DETONATION OF TOTAL CONTENTS
              NDTC- NO DETONATION OF TOTAL CONTENTS

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   b. DOT Restricted:  Compositions  with  an explo-
 sive impact  sensitivity  of  less than 4-inches of drop
 height  (5-2/) will  not  be shipped  until instructions
 have been requested  and received from  the Materials
 Transportation Bureau, Department of Transportation.
   c. DOT Class A (DOD Class/Division  1.1) if one
 or more of the following occur:


     (1)  Detonation, test (5-2/) resulted  in  an explo-
 sion.
     (2)  Card gap tests (5-2/) have determind a detona-
 tion sensitivity value of 70 or more cards.
     (3)  Impact sensitivity test (5-2/) produces an ex-
 plosion at 4 inches  or more, but not more than 10-in-
 ches of drop height.
     (4) Ignition and  unconfined burning  test (5-2g)
 produces a detonation of the sample.
   d.  DOT Class B (DOD Class/Division 1.3) if all of
 the following occur:
     (1)  Ignition and  unconfined burning tests (S-2g)
 resulted in burning deflagration.
     (2)  The Thermal stability test (5-2/0  did not result
 in an explosion, burning, or marked decomposition.
     (3)  Test (5-2f) did not result in a detonation, and
 card gap tests (5-2y) have indicated a detonation sen-
 sitivity value of less than 70 cards or no  reaction at zero
 cards.
     (4)  Impact sensitivity test did not result in an ex-
 plosion  at 10 inches or less.
     (5)   The  classifications derived from these tests
 may be  interim only. Final classifications will be based
 on results of tests of packages as stored or transported.
5-5. Interpretation of STANAC and DOO Tests.
Results of  tests given in paragraph 5-3 will be inter-
preted as follows:

  a.  The  ammunition should be classified in the light
of the test  results and of other relevant data in accor-
dance with  the characteristics of the class divisions as in-
dicated hereunder. Sometimes, the observed hazard ef-
fects may vary among replicate tests or may not corres-
pond exactly to the definitions. When this occurs, the
DODC should use its judgment, or arrange for further
testing. It is prudent to err on the side of caution, par-
ticularly  in the crucial decision as to  whether or not a
product is susceptible to mass detonation.
  b.  Division 1.4  (DOT  class Q  comprises items
which are primarily a moderate fire hazard. They will
not contribute excessively to a fire. The effects, are largely
 confined to the package. No fragments of appreciable
 size or range are to be expected. An external fire must
 not cause the simultaneous explosion of the total con-
 tents of a package of such items. The least hazardous of
 these items, namely those which are so designed and/or
 packaged that any hazardous  effect arising  fTom  ac-
 cidental functioning during storage or transport is con-
 fined within the artical or package, are called Safety
 Ammunition and are placed in compatibility  group S
 regardless  of their other  inherent characteristics.  Ar-
 ticles containing about 1 ounce  or less of explosives and
 classified based  on test results as 1.4S may be con-
 sidered as inert for storage  purposes and are not subject
 to part 173 title 49 CFR for transport. Articles contain-
 ing larger quantities of explosives, but also classified as
 1.4S based upon tests may be considered  inert  for
 storage purposes but must be reviewed on an individual
 basis to determine if part 173 title 49 CFR is to be  ap-
 plied for transport.
   c.  Division 1.3 (DOT class B) comprises items which
 are  a mass fire  hazard. Some items burn with  great
 violence and intense heat emitting considerable thermal
 radiation. Others bum sporadically. They may explode,
 but  without the risk of mass detonation. Usually these
 items do not produce dangerous fragments;  however,
 firebrands  and burning containers may be thrown. (See
 paragraph   4-2  and  indicate  minimum separation
 distance when required.)
   d.  Division 1.2 (DOT class  A) comprises items that
 burn or detonate progressively, a few at a time. A con-
siderable number of  fragments,  firebrands and unex-
ploded items may be projected; some of these may  ex-
plode on impact and propagate fire or explosions. Blast
effects are limited  to  the immediate  vicinity.  (See
paragraph   4-2  and  indicate  minimum  separation
distances based upon data collected in accordance with
chapter 6.)
  e.  Division 1.1 (DOT class A) comprises items that
detonate en masse.  The explosion will result  in severe
structural damage, the severity and range being deter-
mined by the amount of high explosives involved. There
may also be a risk of fragmentation from the article or
package in  which the explosion occares. (See paragraph
4-2 and indicate minimum separation distances required
based upon data collected  in accordance with chapter
6.)

  5-6.   Identification   of  the  Hazard
Assessment by  Assignment  of  a Hazard
Classification.  Based  on  results obtained  from
                                                  J-26

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 tests outlined herein, the appropriate Hazard Class/Divi-    Title 49 CFR. Additionally, the appropriate United Na-
sion/Storage Compatibility Group can be assigned. To     tions Serial Number will be determined by referring to
determine the DOT criteria,  it is necessary to refer to     appropriate lists of UN numbers (see paragraph 4—6).
                                                 J-27

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