PART 261 SUBPART C - CHARACTERISTICS
DOC: 9443.06(85)
Key Words: Reactive Wastes, Test Methods
Regulations: 40 CFR 261.23(a)(5)
Subject: Notes on RCRA Methods and QA Activities
Addressee: N/A
Originator: David Friedman, Manager, Methods Program
Source Doc: #9443.06(85)
Date: 7-31-85
Summary:
The memo covers the following topics:
o Interim thresholds for toxic gas generation reactivity
o Test method to determine hydrogen cyanide released from wastes
o Test method to determine hydrogen sulfide released from wastes
o Revised RCRA' Method 8280.
-------
MEMORANDUM *8
L*Vi"ri: July 1985
'Notes on RCRA Methods and QA Activites
David Friedman, Manager
Methods Program (WH-5623)
TO: Addressees
Today's memo will cover the following subjects:
0 Interim Thresholds for Toxic Gas Generation
Reactivity (§261.23{a)(5))
e Test Method to Determine Hydrogen Cyanide
Released from Wastes
0 Test Method to Determine Hydrogen Sulfide
Released from Wastes
0 Revised RCRA Method 8280, Method of Analysis
for Chlorinated Dibenzo-p-dioxins and
Dibanzofurans
Over the past year, we have received many inquiries about
how to evaluate wastes for reactivity (S261.23(a)(5)). We have
initiated a number of studies in this area, and expect to propose
a quantitative threshold for toxic gas generation reactivity in
December of this year. On an interim basis, however, we feel
stongly that wastes releasing more than the following levels of
toxic gas should be regulated as hazardous wastess
-------
Total Available Cyanldei 250 mg HCN/Kg waste
Total Available Sulfidet 500 mg H2S/Rg waste
The available cyanide or sulfide should be measured using the
attached draft testing methods. Work currently being done on the
agitation and waste introduction steps may result in significant
changes in the subsequent proposed test. However, pending the
conclusion of the investigations, we recommend use of this draft
procedure.
I have attached a brief outline of the methodology we have
employed to derive these interim thresholds. Work on estimating
dispersion factors, however, is currently in progress. Any
comments or suggestions you may have with respect to either the
draft test method or the approach to establishing thresholds would
be appreciated.
As a result of single laboratory evaluation of Method 8280
(reported in Memorandum $7), the method has been condensed and
rewritten. The attached revised method is now being familarized
in three laboratories and a three laboratory confirmation study
will be initiated October 1, 1985. In the interim it should be
used in lieu of Method 8280 published in Federal Register, April 4,
1983. The ErtSL-Las Vegas group is concurrently documenting
detection limits in "typical" matrix types.
While you may want to be flexible in your application of
these levels and the attached test method, we believe the levels
should apply in most cases. Should you have any specific questions,
please call me at FTS 382-4770 (202-382-4770).
Attachment
-2-
------- |