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

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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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