PA
               United States
               Environmental Protection
               Agency
           OH.ce of
           Solid Waste ana
           Emergency Response
DIRECTIVE NUMBER:  9443.01(80)

TITLE: Corrosivity as It Applies to Solid Waste



APPROVAL DATE: 9-15-80

EFFECTIVE DATE: 9-is-so

ORIGINATING OFFICE: office of solid waste

2 FINAL

H DRAFT

 LEVEL OF DRAFT

   DA — Signed by AA or DAA
   D 8 — Signed by Office Director
   D C — Review & Comment

REFERENCE (other documents):
  OS WER      OS WER      OS WER
VE   DIRECTIVE    DIRECTIVE    Di

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-PART  261   SUBPART  C  - CHARACTERISTICS
                                                DOC:  9443.01(80)
 Key  Words:     Corrosive Wastes,  Characteristics  of Hazardous Waste

 Regulations:   40  CFR  261.22

 Subject:       Corrosivity  as  It  Applies  to  Solid Waste
 Addressee:


 Originator:

 Source  Doc:

 Date:

 Summary:
Richard Northrup, Environmental Affairs Department,
Appalachia Power Company

James Poppiti, Chemist, Hazardous & Industrial Waste Division

#9443.01(80)

9-15-80
      Pursuant  to  §261.22  a  solid  waste  is  hazardous  if  it meets  either  of  the
 following  two  criteria:

      (a)   Its  pH  is  less  than  2 or greater than  12.5, and

      (b)   It corrodes  SAE 1020 steel  at  a  rate greater  than  .25  in.  per year.

      The examination of both corrosivity criteria would ensure a waste  is  not
 hazardous, however,  testing with  only one  criteria may  be adequate.   It is the
 responsibility of the  generator to determine which criteria  to use.   Such
 testing does not  relieve  the generator  of  liability  if  it is later determined
 that  the waste is hazardous.

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                                                              9443.02 (80)
Mr. Jack L. Cooper, Director
Environmental Affairs
vational Food Processors Association
1123 2Cth St. K.w.
:«r'jshinnton, D.C.  20036

T;ear «H would equal or exceed  12.5.   You  further  indicated
that this waste is always neutralised to well  below a  pH of 12.5
^p«*
it appears that sone Diodification to the regulations B«T.be
warranted.  The Agency disagrees, however, that the
approach is to declare caustic food processing waste non-hazardous.
To c!o so would be inconsistent with SPA's  May  1*», 1980 regulations
woich identify highly corrosive wastes (pH above 12.^  or below
2.5) as hazardous wastes*  Such wastes can cause serious burns
or seriously .pollute surface waters.  In the case of your industry,
overflows and leaks resulting  from  improper operation  could
result in injuries to persona  who night have  access to the area.
Improper a&na^ecient could also result  in the  release of toxic
&ists and f

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      In 3U«,  w«  uor.'t  thinX it »r-r.ro»-)ciate to **err.t  e «-».^tc  .as
non-r.azar ^ous because  It is usually a-*o<:?uately ;-.9naied.   I uch
ar.  irtotr rotation  woul<' r;c -rounter to cho intent an--1  structure
c£  t.v*»  ';cc«   The atcuct'Jra of .-CPA. involves .•> .•*ctorr»in«jtlon  first
ti'at  A  .-/ftjit«»  -*&)' *^e  hissat'Joui* if iep
-ap:>rorriatc regulations , the Agency la -?ir*ct«tj tc assure the
tnat  n«no.-7cr>pnt  is saf«»  L'nlesn r»nulationa r«?quirinc? ; roper
hanJiim  are  XK^oacd,  the Agency an.l the public nave  no
tnat  j;rop«r aar.aqcwent is b«lna achieved,

      To nafec  this  3ara« point *noth«r v*y, an interpretation  such
as  the one you are requesting would allow a cr«?«t -ralcrity of
waste ^reducers  to aeefc exclusion fron the pro« to establish a special  set of
standards applicable  to  neutralization units only*  w« are currently
considering amending  the regulations tb ii*ple
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