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 0 FINAL D DRAFT STATUS: [ 1 { 1 A- Pending OMB approval B- Pending AA-OSWER approval C- For review &/or comment D- .In development or circulating headquarters REFERENCE (other documents): OS WER OS WER OS WER /£ DIRECTIVE DIRECTIVE Di ------- 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. ------- 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)). ------- 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 ------- |