oEPA
United State*
Environmental Protection
Agency
Off ice of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9433.05(84)
TITLE: Teat Methods and Standards to Evaluate Cyanide
Levels In Inorganic Wastes
APPROVAL DATE: ia-li-84
EFFECTIVE DATE: 12-11-84
ORIGINATING OFFICE: osw
Q FINAL
D DRAFT
LEVEL OF DRAFT
DA — Signed by AA or DAA
D B — Signed by Office Director
DC — Review & Comment
REFERENCE (other documents):
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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PART 260 SUBPART C - RULEMAKING PETITIONS
DOC: 9433.05(84)
Key Words:
Regulations:
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Test Methods, Cyanide
40 CFR 260.22
Test Methods and Standards to Evaluate Cyanide Levels in Inorganic
Wastes
Dave Rudder, Vice President, Environmental/Process Control, Seigel-
Robert, Inc., 8645 South Broadway, St. Louis, MO 63111
Myles E. Morse, Environmental Protection Specialist, Delisting
Program
#9433.05(84)
12-11-84
Four forms of cyanide [total, free (amenable to chlorination), leachable,
and photodegradable] must be evaluated for petitioning to del.ist an electro-
plating sludge. Total and free cyanide in the waste are determined using Method
No. 9010, "Total and Amenable Cyanide," in Test Methods for Evaluating Solid
Waste. Leachable cyanide is- determined in the EP Toxicity Test with no acid
adjustment. Method 9011, "Method for the Determination of Photodegradable
Cyanide," is used in the determination of photodegradable cyanide.
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9433.05 (84)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
DEC
,C.Q*
OFFICE OF
SOLID WASTE ANO EMERGENCY RESPONSE
Mr. Dave Rudder
Vice President - Environmental/Process Control
Seigel-Robert, Inc.
8645 South Broadway
St. Louis, Missouri 63111
Dear Mr. Rudder:
The purpose of this letter is to describe the test methods '
and standards used in evaluating cyanide levels in inorganic wastes
petitioned for exclusion under S260.22 of the RCRA regulations.
As explained in our telephone conversation on December 5, 1984, the
Agency requires four forms of cyanide to be evaluated for the
purposes of petitioning to delist an electroplating sludge. These_
include total, free (amenable to chlorination) , leachable, and
photodegradable cyanide.
Total and free cyanide in the waste is determined using Method
No. 9010 "Total and Amenable Cyanide" in Test Methods for
Evaluating Solid Waste. The delisting program imposes no
limitations on the amount of total cyanide present in the
waste other than the requirement of running the photodegradable
cyanide test if total cyanide in the waste exceeds 10 ppm. Free
cyanide in the waste however, is considered hazardous at
levels at or above 10 ppm. The 10 ppm limitation is derived
from the workroom air threshold standard of 10 ppm set by the
American Conference of Governmental Industrial Hygienists
(ACGIH).
Leachable cyanide is the only cyanide parameter evaluated in
the extract rather than in the waste. The test method used for this
determination is the EP Toxicity Test with no acetic acid adjustment.
Therefore this is a distilled water extraction. The delisting
program looks at all cyanide showing up in the extract as being
leachable cyanide, therefore cyanide in the extract is measured as
total cyanide. This total cyanide concentration in the extract is
evaluated using a generalized ground water dispersion model which
predicts a receptor well concentration 500 feet from the disposal
site. The receptor well concentration is then compared to a health
based standard - the U.S. Public Health Services' suggested drinking
water standard of 0.2 ppm. If the receptor well concentration exceeds
0.2 ppra then the waste is considered hazardous. The model uses
the maximum extract level reported as well as the volume of waste
generated on an annual basis. The model automatically yields
a ten fold dilution of the maximum extract value, therefore a waste
exhibiting a maximum extract concentration at or below 2.0 ppm
would be deliscable while a decision on higher extract levels
would depend on the volume of waste generated.
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As indicated above, a determination of photodegradable cyanide
is required when total cyanide concentrations in the waste exceeds
10 ppm. The test used for this determination is Method 9011
"Method for the Determination of Photodegradable Cyanides"
in Proposed Sampling and Analytical Methodologies for Addition
to Test Methods for Evaluating Solid Waste. This test measures
any hydrogen cyanide gas that might be generated after irradiating'
the waste with a UV lamp. The concentration of hydrogen cyanide
generated in this test is again compared directly to the ACGIH
threshold of 10 ppm as cited above. A concentration of less than
10 ppm would be considered non-hazardous.
In wastes exhibiting high concentrations of total cyanide
it is possible that artificially high free cyanide levels can
be recorded. This is due to positive interferences attributable
to the complexed iron cyanides in the waste. In these instances
the Agency has a number of alternate test methodologies that
are less prone to interferences. The most frequently used is
"Test Method for the Determination of Cyanide and Sulfide
Containing Wastes" (copy attached). This test measures the
generation of hydrogen cyanide gas which is then evaluated
in terms of the 10 ppm ACGIH threshold previously discussed.
Again, a concentration of less than 10 ppm would be considered
non-hazardous..
I have enclosed a background article on the ground water
model now being used by the Agency in petiton evaluation. A
detailed appendix explaining the assumptions used in the model
will appear in the Federal Register as a part of the next
group of proposed delistings (hopefully in February of 1985)..
If you have any questions regarding any of the tests or
standards described in this letter do not hesitate to call
me at (202)-382--4782.
Sincerely,
Myles E. Morse
Environmental Protection Specialist
Delisting Program
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