PA
United States
Environmental Protection
Agency
OH.ce of
Solid Waste ana
Emergency Response
DIRECTIVE NUMBER: 9443.01(81)
TITLE: Sufficient Agitation for the Extraction Procedure
Toxicity Test
APPROVAL DATE: 6-17-81
EFFECTIVE DATE: 6-17-81
ORIGINATING OFFICE: office of solid waste
E FINAL
D DRAFT
LEVEL OF DRAFT
DA — Signed by AA or OAA
D B — Signed by Office Director
C3 C — Review & Comment
REFERENCE (other documents):
OS WER OS WER OS WER
VE DIRECTIVE DIRECTIVE Dl
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PART 261 SUBPART C - CHARACTERISTICS
DOC: 9443.01(81)
Key Words:
Regulations:
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
EP Toxicity Test Procedure
40 CFR 261.24
Sufficient Agitation for the Extraction Procedure Toxicity Test
M.J. Boris, American Steel Foundries
David Friedman, Manager, Waste Analysis Program,
Hazardous and Industrial Waste Division
#9443.01(81)
6-17-81
To meet the definition of acceptable agitation, the extraction must impart
sufficient agitation to the mixture to not only prevent stratification of the
sample and extraction fluid, but also to insure that all sample surfaces are
continuously brought into contact with well mixed extraction fluid. A test
procedure in which the container is handshaken twice daily by inverting it 15
times is not an acceptable agitation. This method is deficient in that during
the 12 hours or more that the sample remains undisturbed, stratification is
likely to take place. A magnetic stirrer method may be used if, after the
application of the Structural Integrity Procedure, the waste material is a
manolithic piece. By suspending the sample in a continuously .stirred bath of
extraction fluid, the objectives described above will be met.
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UNITED STATE' ENVIROf.'.IENTA. PROJECTION AGENC'
VVASHIN ~~cr, z .z 2046:
n
OFFICE o«- WATEF
AND V/ASTE MANAGEMENT
Mr. M. J/ Boris
American Steel Foundries
3761 Canal' Street
East Chicago/ IN 46312
Dear Mr. Boris:
I am writing in response to yor letter of May 11, 1981
requesting a ruling on whether the American Foundrymen's
Society (AFS) Standard Test Procedure in which the container
is handshaken twice daily by inverting it 15 times is an
acceptable agitation procedure to employ when conducting the
Extraction Procedure toxicity test (40 CFR 261.24].
The AFS method is not acceptable since it does not
meet the definition of acceptable agitation; "...an
acceptable extractor is one which will impart sufficient
•agitation to the mixture to not only prevent stratification
of the sample and extraction fluid but also insure that all
sample surfaces are continuously brought into contact with
well mixed extraction fluid". Specifically the AFS method is
deficient in that during the 12 hours or more that the sample
remains undisturbed, stratification is likely to take place.
The magnetic stirrer method you also asked about may
however be used if, after application of the Structural
Integrity Procedure, the waste material is a monolithic
piece. By suspending the sample in a continuously stirred
bath of extraction fluid, the objectives described in the
aforementioned specification will be met.
I hope that this answers you question. If you have any
additional questions, please feel free to give me a call at
(202) 755-9187.
Sincerely,
David Friedman
Manager, Waste Analysis Program
Hazardous and Industrial Waste Division (WH-565)
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