&EPA
Unnvd SUIM
£nvironm«nui Pro(*ction
Agency
Off.c* of
Solid W»»IB «nd
Emerge:.;y P«»pon»«
DIRECTIVE NUMBER:
•''Lc: Evaluating the Ignitability of Physical Solids
APPROVAL DATE: April 21, 1986
EFFECTIVE DATE: April n 1986
ORIGINATING OFFICE: QSW/SMB
3 FINAL
D DRAFT
STATUS:
REFERENCE (other document*):
'E DIRECTIVE DIRECTIVE D
-------
t I
xvEPA
. . _.. .
Wasnmgton. OC 2G4bO
OSWER Directive Initiation Reauest
9443.00-1A
Or-qmator informal
Name of Contact Person
David Friedman
Mail Cooe -
WH-562B
Branch
SMB
Teieonone-Numoer
' 382-4770
ead 0«.et
D OERR
E OSW
Q
D OWPE
n AA-OSWER
Signature of 0"ice Director
i Date
,t!e
Evaluating the Ignitability of Physical Solids
Summary ot Directive
Letter explaning that the flash point tests specified in 40 CFR 261.21 only apply
to liquid wastes.
Key Words:
Ignitability, Hazardous Waste, Solids
Type of Directive iManutt. Policy Directive. Announcement, etc.i
Clarification Memorandum
Status
D Draft
GD Final
| 131 Now
i LJ Revision
Doe»tnis Directive Supersede Previous Directive**;' j_j Yes
if "Ye*" to Either Question. What Directive /number, title/
No Does it Supplement Previous Directives)' bc_l Y«« | ) NO
Review Plan
D AA-OSWER Q OUST
1-1 — - D OWPE
G OERR
[E] OSW
I—I Regions
D OECM
D OGC
D OPPE
D
Otner iSpecityl
This Request Meets OSWER Directives System format
Sigrature of Lead Office Directives Officer
' Date
Signature of OSWER Directives Officer
'• Date
-------
\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
2
r> WASHINGTON. D.C. 20460
.-?
APR 2 I 1955
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
1'j.lbL f-C-i. u.Vj L-llZa:.l|-vt ff 9
SUBJECT: Evaluating the Ignitability of Phyaical Solids
FROM: Marcia E. Williams, Director
Office of Solid Waste (WH-562)
TO: Robert L. Duprey, Director
Waste Management Division (8HWM)
In response to your March 25th memorandum on Amoco's questions
about the application of a flash point test to solid wastes, the
use of flash point as a determinant of hazard is restricted to
liquid wastes only. As we have stated previously, in OSW's
Quality Assurance Notes #5, while some States are requiring
generators to use the Pensky-Martens or Setaflash test to determine
if non-liquid wastes are hazardous by reason of ignitability, OSW
cannot support this position. ASTM, who was responsible for the
development of these tests, states that the Setaflash method is
applicable only to liquids with a viscosity below 150 st at
25°C, while the Pensky-Martens test can also be used for liquids
that contain suspended solids. Neither test, however, is approved
by ASTM for use in evaluating the flash point of solids or sludges.
The OSW has been conducting research to develop techniques
for measuring the ignitability of solids and sludges. These
tests are currently undergoing interlaboratory collaborative
testing prior to formal proposal. Until we can complete develop-
ment of the test procedure, and accompanying regulatory thresholds
for non-liquid wastes, we will have to continue to rely on the
definition in §261.21(2).
If you have any additional questions concerning any of the
characteristics, please contact David Friedman at FTS 382-4770.
------- |