PART 261  SUBPART A - GENERAL
                                                 DOC:   9441.18(84)
Key Words:

Regulations:

Subject:


Addressee:

Originator:
Container, Pesticides

40 CFR 261.7, 261.33

Response to Questions from State Pesticide Personnel:
Triple Rinsing

N/A

John H. Skinner, Director, and Amy E. Schaffer, Program Analyst,
Office of Solid Waste and Emergency Response
Source Doc:   See Miscellaneous [9560.07(84) Question //3]
Date:

Summary:
8-8-84
     If a disposed empty container contained hazardous waste as listed in
§261*33, the container is subject to the requirements of §261.7:  residues of •
hazardous waste in empty containers.  Residues of hazardous waste in "empty''
containers are not subject to regulation if that container's waste was removed
using the practices commonly employed to remove materials from that type of   .
container (i.e., triple rinsing or another acceptable method).                *

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   Response  to Questions  frora state Pesticides Cont-rol Officers

   John H. Skinner
   Director
   Office of Solid waste  and toer^ency Response  (*H-562)

   Amy E. Schaffer
   Proyra/n Analyst
  Office of Solid Waste  and Emergency Response  (WH-527)

     The following responses are presented for  the questions and
issues -fcosed by the State Pesticides Control Officers concerning
RCRA.  Some of tha questions were quite difficult to interpret
and were answered to the best of our ability.   If additional
information or clarification is required, please contact
Francine Jacoff at 475-8551.

(1)  NEW MIXING, LOADING AND TEMPORARY STORAGE  STANDARDS -
     Currently no standards exist which indicate acceptance
     methods.  Society must lay out its level of accepta-
     bility if actions taken today are not to result in
     similar concerns to the old sites issue.

          RCRA does have existing standards that apply to
          temporary storage, that is, for less  than 90 days.

(.2)  Are there reasons which would justify the  "economically and
     technically feasible" standards for some pesticide disposal?

          The question is taken out of context and is difficult ,
          to answer.  None of the RCRA disposal standards are
          based on economics but instead are based on a "protect
          human health and the environment" study.  They may be
          referring to tailored standards for particular pesticides.
          RCRA either requires compliance with Subtitle C standards
          for listed hazardous wastes or excludes them- for specitied
          reasons.
                                                            .
(3)   Container disposal, particularly ULV products and in
     impregnated fertilizer situations.  What if triple rinsing
     is impossible?

          Section 261.7 is pertinent only if the product is
          listed in 5261.33.  Section 261.7, Residues of
          hazardous waste in empty containers, is explicit.

(4*)   Bulk pesticide storage standards - are they needed?   ^ff'fl ,i.(jf

          RCRA is concerned with waste storage, not product
          storage.  OPP should answer this question.

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