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). * ------- 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. ------- |