vvEPA
               United States
               Environmental Protection
               Agency
            Office of
            Solid Waste and
            Emergency Response
DIRECTIVE NUMBER:  9443.04(85)
TITLE: Clarification of the Sulfide Reactivity Characteristics

APPROVAL DATE: J-ie-ss
EFFECTIVE DATE: 7-16-35
ORIGINATING OFFICE: Office of Solid Waste
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PART 261  SUBPART C - CHARACTERISTICS
                                                DOC:  9443.04(85)
Key Words:    Reactive Wastes, Ground-Water Monitoring, Test Methods

Regulations:  40 CFR Part 261, Subpart C 265.90(e)

Subject:      Clarification of the Sulfide Reactivity Characteristics

Addressee:    Terry L. Thoera, Manager, Environmental Conservation,
              Conoco Inc., P. 0. Box 2197, Houston, Texas 77252

Originator:   John H. Skinner, Director, Office of Solid Waste

Source Doc:   ?/9443.04(85)
Date:

Summary:
7-16-85
     The letter discusses test methods for determining whether a waste exhibits
the characteristic of reactivity.  It also discusses ground-water monitoring
for units containing only reactive wastes.

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                                                             9443.04 (85)
                           JUL16B8S
Mr. Terry L. The
Manager, environmental Conservation
Conoco Incorporated
P. O. Box 2197
Houston, Texas  77252

Dear Mr. Thoesu

     I am writing to clarify several aspects of the sulfide
reactivity characteristic that you asked about in your letter of
June 24, 1985.

     At present, there is no approved test method for determining
whether a waste exhibits the characteristic of reactivity.  I
have enclosed a draft of a test method for determining Total
Available Sulfide.  Work currently being done on the agitation
and waste introduction steps may result in significant changee in
the subsequent proposed test.  However, pending the conclusion of
our investigations, we recommend, and will accept, use of this
draft procedure.  While threshold concentrations have not yet
been promulgated by the Agency, we have adopted 500 mg/Kg Total
Available Sulfide as an interim action level.  We consider any
waste that yields sulfide valuee at or above the action level,
using the draft procedure, to be hazardous.

     The 500 mg/Kg action threshold was arrived at by considering
a scenario in which a truckload of waste is discharged into a pit
containing (non-hasardous) acidic waste.  As a result of the
reaction of the waste with the acid, a rapid, high level release
of toxie g*ft ensues.  The objective of the characteristic is to
identify tfhme wastss which, if such an activity were to take
place, pose a hazard to those persons in the general vicinity of
the disposal sits.  While we have considered dispersion in arriving
at the action threshold, the specific dispersion model that will
be used in the upcoming proposal is still under development.

     Qround water monitoring of all wastewater treatment lagoons
containing hazardous wastes, is required including those containing
only reactive wastes.  The only exemption from ground water
monitoring that is defined by the RCRA regulations is in the
case of neutralization ponds receiving wastes hazardous only by
reason of corrosivity (265.90(e)).

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                     is necessary because the Agency  is not
                    Lsa which can assure that such wastes will
                 'toatic chemical* which pose a hazard  to ground
                      a vast* is not  listed or does not exhibit
     	         tc of Extraction Procedure Toxicity doea not
 insure the absence of leachable toxic cpeciee in the  waate.

     If you have further question* concerning the reactivity
 characteristic please contact David Friedman (202/382-4770) of
 the Methods Prograau  For information on the regulatory
 requirementa pertaining to ground water Monitoring, contact
 Robert April (202/475-8860) in the Ground Water Program.

                         Sincerely yours,
                         John H. SXinner
                         Director
                         Office of Solid Waste
bcc:  Claussen
      Lehman
      Weddle
      Coraon
      Shuater
      Friedman
      April
      Hotline
      Region VI
WH-562B/DPRIBDMAN/margaret/rm SE248/382-4770/7-3-85
CONTROL OSW-118 Due Date 7/8/85 Disk: DFB:48

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