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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
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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.
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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
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