Environment*! Protection Agoncy ONiccof Solid WM» and Emergency Response dEPA DIRECTIVE NUMBER: 9444.02(81) TITLE: Hazardous Waste Listing P120 APPROVAL DATE: 5-19-81 EFFECTIVE DATE: 5-19-81 ORIGINATING OFFICE: office of solid waste m FINAL O DRAFT LEVEL OF DRAFT D A — Signed by AA or DAA O 8 — Signed by Office Director O C — Review & Comment REFERENCE (ottor documents): OSWER OSWER OSWER VE DIRECTIVE DIRECTIVE Dl ------- 261 SUBPART D - LISTS DOC: 9444.02(81) Key Words: P120, Listed Wastes Regulations: 40 CFR 261.33(e) Subject: Hazardous Waste Listing P120 Addressee: R.E. McNeill, Occidental Chemical Company Originator: David Friedman, Manager, Waste Analysis Program, Hazardous and Industrial Waste Division Source Doc: Date: Summary: #9444.02(81) 5-19-81 The hazardous waste listing P120 in §261.33(e) relates to all of the oxides of vanadium's + 5 oxidation state. If a catalyst employed in the pro- duction of sulfuric acid does not have such an oxide as its sole active ingre- dient, then the catalyst is not regulated under §261. However, the Part 261 test for other characteristics of hazardousness must be carried out. ------- 9444.02 (81) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON. D.C 2046C OFFICE OF SOLID WASTE 1 S 193, OFFICE OF WATER AND WASTE MANAGEMENT Mr. R. E. McNeill Occidental Chemical Company P.O. Box 300 White Springs, FL 32096 Dear Mr. McNeill: I am writing in response to your letter of June 9, 1981 to Mr. Alan Corson requesting clarification of the section 261.33 regulations with respect to a sulfuric acid catalyst you use. The hazardous waste listing P120 in section 261.33(e) relates to all the oxides of vanadium's +5 oxidation state. If the Monsanto Catalyst that you employ in the production of sulfuric acid does not have such an oxide as its sole active ingredient, then the catalyst is not regulated under section 261. One must keep in mind however that, even if it is not regulated under section 261.33, the waste must still be evaluated to determine if it exhibits any of the characteristic of a hazardous waste (i.e., ignitability, reactivity, corrosivity, EP toxicity). I trust the above answers your questions. If _ I can be of further assistance please give me a call at (202)' 755-9187. David Friedman Manager Waste Analysis Program Hazardous and Industrial Waste Division (WH-565) cc: Hotline ------- |