BACKGROUND DOCUMENT
RESOURCE CONSERVATION AND RECOVERY ACT
SUBTITLE C - IDENTIFICATION AND LISTING OF
HAZARDOUS WASTE,'
§261.21 - Characteristic of Ignitability
May 2, 1980
U.S.'ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF SOLID WASTE
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ABBREVIATIONS
ASTM
CFR
CPSC
FR
DOT
EPA
IMCO
IOTTSG
NFPA
RCRA
°C
°F
FP
Z
psia
(n)
Udj)
m
s
jnin
in
kpa
American Society of Testing Materials
Code of.Federal Regulations
U.S. Consumer Product Safety Commission
Federal Register
U.S. Department of Transportation
U.S. Environmental Protection Agency
Inter—Government Maritime Consultative Organization
International Oil Tanker Terminal Safety Guide
National Fire Protection Agency
Resource Conservation and Recovery Act
degrees Celcious
degrees Fahrenheit
-_.!_A -.
less than or equal to
greater than or equal to
greater than
flash point
percent
pounds per square inch absolute
noun
adjective
meters
seconds
minute
inch
kilo Pascal
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Ignitability Characterization Background Document
I. Introduction
Subtitle C of the Solid Waste Disposal Act, as amended
by the Resource Conservation and Recovery Act of 1976 creates
a comprehensive "cradle-to-grave" management control system
for the disposal of hazardous waste designed to protect the
public health and the environment from the improper disposal
of such waste. Section 3001 of that Subtitle requires EPA to
identify the characteristics of and list hazardous waste.
Wastes identified or listed as hazardous will be included in
the management control system created by Sections 3002-3006
and 3010. Wastes not identified or listed will be subject to
the requirements for non-hazardous waste imposed by the
States under Subtitle D. The Agency has determined that
ignitability is a hazardous characteristic because improperly
managed ignitable wastes pose a substantial present or
potential danger to human health and the environment. The
purpose of this document is to explain the Agency's definition
of ignitable waste, to discuss the comments received on the
proposed definition of ignitability (43 FR 58955-58956,
December 18, 1978) and the changes subsequently made.
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II. Proposed Regulation
Ignitable Waste.
(1) Definition - A solid waste is a hazardous waste if
a representative sample of the waste:
(i) Is a liquid and has a flash point less than
60°C (140°F) determined by the method cited
below or an equivalent method, or
(ii) Is not a liquid and is liable to cause fires
through friction, absorption of moisture,
spontaneous chemical changes, or retained heat
from manufacturing or processing, or when
ignited burns so vigorously and persistently
as to create a hazard during its management,
or
(iii) Is an ignitable compressed gas as defined in
49 CFR 173.300(b), or
(iv) Is an oxidizer as defined in 49 CFR 173.151.
(2) Identification method
(i) Flash point of liquids shall be determined by a
Pensky-Martens Closed Cup Tester, using the
protocol specified in ASTM standard D-93-72, or
the Setaflash Closed Tester using the protocol
specified in ASTM standard D-3278-73 or any other
equivalent method as defined in this Subpart.
(ii) Ignitable gases shall be determined by the methods
described in 49 CFR 173.300.
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III. RATIONALE FOR THE PROPOSED REGULATION
A. Rationale for Proposing an Ignitable Characteristic
Ignitability* was chosen as a characteristic of
hazardous waste because ignitable wastes pose a substantial
present or potential danger to human health and the environ-
ment if improperly managed. Such wastes can cause fires
which directly damage the environment by heat and smoke pro-
duction or indirectly damage the environment by providing a
vector through which other hazardous vastes can be dispersed.
An example of the latter would be the creation of convection
currents that transport toxic particulates. Ignitable wastes
may also result in fires which cause otherwise benign wastes
to become hazardous* An example of this would be the pro-
duction of noxious fumes from the burning of plastic waste.
Fast routine management of ignitable vastes has resulted in
death and injury to persons and damage to property. Appendix
I lists and discusses some of these damage incidents.
In acknowledgment of the dangers associated with ignitable
wastes, Congress designated flammability (ignitability) as a
potential hazardous characteristic. At page 25 of the
House Report**, the House Committee stated as follows:
* EPA has used the term "ignitability" to avoid confusion
with DOT's use of the term "flammability" in its regulations.
EPA's definition of ignitability is synonymous with ASTM's
definition of flammability. ASTM defines flammability as the
capability of a substance/waste to undergo a rapid exothermic
•oxidation process accompanied by continuous evolution of
heat and usually light under normal ambient conditions.
**Report of. the Committee on Interstate and Foreign Commerce,
U.S. House of Representatives (H.R. 14496)
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". . ., the Committee's Intention is
that EPA, in the development of the
characteristics of a hazardous waste
take into consideration the toxicity
of the waste, its persistence and
degrability in nature, its potential
for accumulation into tissue and
other related factors, such as
flammability, corrosiveness or other
hazardous characteristics." (emphasis added).
In further acknowledgment of the dangers posed by ignitable
wastes, several States regulate or set guidelines for the
management of ignitable wastes and public or private
organizations often publish suggestions for their safe
management. Appendix II lists some of these regulations,
guidelines and suggestions. For a detailed discussion on the
criteria for determining characteristics,- see appropriate
background document.
B. Rationale for proposed definition
In formulating the ignitability characteristic, the
Agency has sought to identify and employ an indicator or
measure of ignitability which best models the hazards associ-
ated with ignitable wastes. Unfortunately, no single indicator
adequately models the hazards presented by all of the physical
states (gas, liquid, semi-solid, or solid) in which ignitable
'wastes occur. Consequently, the Agency has had to treat the
different physical states of ignitable wastes separately in
-constructing its definition of ignitability. This separate
treatment is discussed below.
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1. Ignitable Liquids
There are several established measures or indicators
of the ignitability of a liquid waste*; for example, flash point,
fire point, autoignition, etc. These measures and other terms
related to fire phenomenon measurement are presented and
defined in Appendix III. The most attractive of these
indicators of ignitability is the flash point of the waste.
Flash point is defined as t"he lowest temperature, corrected
to a pressure of 101.3 K Fa (1013 millibars), of a substance
at which application of an ignition source causes the vapor
above the substance to ignite under specified conditions of
test-*-. The Agency believes that flash point best models
the hazards associated with the disposal of ignitable liquid
waste streams. Vapor/ai-r mixtures above the liquid waste
can be readily ignited by ignition sources that typically
are encountered in the transportation, storage, and disposal
of such wastes. Such ignition sources include the hot
exhaust systems of compaction equipment and trucks used in
landfills and for hauling wastes; electrical sparks from the
ignition systems of such equipment; electrical sparks from
pump motors and other electrical devices; and sparks from
friction and lighted cigarettes. Internal temperatures can
elevate the temperatures of wastes past ambient temperatures.
Such internal heat sources include thermal energy resulting
"from such things as the heat of decomposition of organic
waste or the absorbed heat of the sun on the sometimes dark
^Liquids are defined by the limitation of test standards
proposed later in this document.
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and broken surface of the landfill. Once ignited, liquid
wastes with low flash points can cause fires which result in
the damage outlined above. All government agencies and
professional associations contacted by the Agency during
the early development of these regulations recognized flash
point as the primary indicator of the fire hazard of liquids.
The primary reasons given for this recommendation were the
general industrial acceptance of flash point test standards,
the inexpensiveriess of flash point testing, and the many years
of data compilation. As Appendix II discloses, states and
public and private organizations which have promulgated
regulations and guidelines regarding ignitable liquids have
almost invariably used flash point as the barometer of ignita-
bility.
Another possible indicator of ignitability is the fire
point of the waste. Fire point is defined as the minimum
temperature to which a material must be heated in an open
vessel before the substance will sustain combustion for a
specified period of time after ignition by an external source-'--
Fire point differs from flash point largely in that it measures
the capacity of a substance to sustain combustion when ignited
by an external source rather than just the capacity of a
substance to flash. The two are thus closely related and
the fire point of a substance is generally only a few degrees
higher than the flash point. Although fire point models
the hazards which accompany the ignition of ignitable liquid
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waste streams, the Agency has determined that flash point is
the better indicator of ignitability- This is because of
the small difference between flash point and fire point, the
widespread acceptance of flash point by the regulated commun-
ity, and the dangers associated with liquids that flash.
Another possible indicator of ignitability is the
autoignition temperature of the waste. Autoignition is the
spontaneous ignition of a material which occurs not as a
result of an external ignition source, but as a result of
heat liberation from an exothermic reaction occurring in the
material^. Autoignition temperature is the temperature
at which this spontaneous ignition takes place. Auto-"
ignition temperatures tend to be much higher than flash point
temperatures--generally"several hundred degrees higher, as
Table 1 illustrates. Consequently, it is very unlikely that
wastes would be exposed during their management to energy
sources of the magnitude necessary to heat them to their
autoignition point. The Agency has rejected autoignition
temperatures as a suitable indicator of ignitability because
autoignition temperature fails to model the particular hazard
the Agency wishes to minimize — i.e. the external ignition
of volatilized liquid wastes. To the extent the autoignition
of liquid wastes does pose a hazard, this hazard is likely
to be taken care of by the flash point limits.
While most States, agencies, and organizations that define
ignitability use flash point as their criterion, there exists
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Table 1
Comparison of Flash Point and Autoignition Temperatures
Substance Flash Point* of Autoignition* of
°F (°C) °F CC)
Acetaldehyde
36 (2
Acetic Acid (Glacial) 109 (42
Allyl Alcohol
Camphor
Ethyl Alcohol
Fuel Oil #1
70 (21
150 (65
55 (12
100 (37
.2)
.8)
.1)
.6)
.8)
.8)
365 (18
800 (426.
713 (378.
871 (466.
793 (422.
444 (228.
5)
7)
3)
1)
8)
9)
*NFPA, Fire Protection Handbook, 12th Edition, Chapter IX,
Fire Hazard Properties of Flammable Licuids, Gases and Volatile
Solids, Table 6-126.
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no consensus on what the limit should be. For example, the
Department of Transportation (DOT) defines substances with flash
points below 37.9°C (100°F) as flammable and flash points at
or above 37.8°C but less than 93.3°C(200°F) as combustible2. A
number of organizations, responding to the Department of
Transportation's effort to standardize its flash point limits,
have followed suit. See Appendix II. Ohio, on the other hand,
defines liquids with flash points less than 79.4eC (175eF) as
flammable and does not recognize the combustible category at
all^ . Similiarly, the National Fire Protection Association
(NFPA) has erected a classification system which defines
liquids with flash points below 37.8°C (100°F) as Class I
(flammable) liquids, liquids with flash points at or above
37.8eC and below 60°C(140°F) as Class II (combustible)
liquids and liquids with flash points above 60°C as Class
III liquids.
There are persuasive reasons for concluding that these
various flash point limits and classification schemes either
do not adequately take into account the hazards accompanying
the transportation, storage, and disposal of ignitable
liquid wastes or are inappropriate for other reasons. For
•instance, the Department of Transportation's flash point limit
of 37.8°C(100°F) for flammable substances appears to have
-been chosen for the purpose of keeping all of the fuel oils
regulated by DOT in the combustible category (i.e., to avoid
classifying some fuel oils as flammable and others as combus-
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tible). This flash point limit was apparently not designed
to take into account all of the heat sources to which ignitable
liquids are exposed during transit, storage, and ultimate
disposal. J. M. Kuchta, et al., in an early DOT study4
recommended as follows:
It is recommended that a flammable liquid
be defined as one with a flash point below
140°F, as determined in a Tag Closed Cup,
and having a vapor pressure not exceeding
40 psia at 100°F. The 140° break point is
suggested because ambient temperatures of
this order can be encountered during ship-
ment, particularly in hot climates, this
break point is also consistent with the
NFPA and IMCO classification systems and
that proposed by IOTTSG.
Similiarly, the classification schemes adopted by NFFA and
DOT are inappropriate because they would force EPA to
adopt a degree of hazar
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has discovered that liquid wastes are exposed to temperatures
of up to 140° in the routine handling of such wastes. As
noted by J. M. Kuchta in the DOT study referenced above^ ,
this upper temperature can occur inside storage tanks, storage
containers and transportation tank trailers on hot sunny
days. As indicated by the studies referenced in Table 2,
this temperature is also frequently encountered in landfill
environments. Accordingly, the Agency has elected to use a
flash point of 60"C (140"F) as the regulatory limit for
defining whether a liquid waste is an ignitable hazardous
waste. To use a lower flash point limit would exclude from
regulatory coverage many liquid wastes which could, in fact,
present a hazard under typical conditions encountered in
liquid waste management, that is fires that result from the
ignition of these wastes. This flash point limit will include
all those liquid wastes which would fall within Class I and
Class II of NFPA's classification scheme.
2. Ignitable Solids
Solid materials typically do not volatilize as liquid
materials since most solids have lower vapor pressures than do
liquids. Consequently, solid wastes rarely have low flash •
points, that is those less than 60°C (140°F). The hazards that
attend the management of liquid wastes and that are modeled
by flash point thus do not attend solid wastes. Even if
this were not the case, it would be difficult to construct a
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Table 2
Typical Landfill Teoperatures
Study/References
Temperature/Conditions
Remarks
Survival of Fecal
Coliforms and
Fecal Strepto-
cocci in a sani-
tary landfill6.
120°F (48.8*C) to 140°F
during the first week in
the middle-section of the
landfill at 2 to 6 foot
depths (temperatures were
10 to 15 degrees lower in
the periphery.
Landfilling conditJ
models nicely the
of many sanitary 1;
disposal sites.
Boone County Field
Site Interim
Report, Test Cells
2A, 2C and 2D7.
Peak temperature recorded
was 51.1°C (124°F)
Highest readings w<
4 to 6 days after
refuse placement.
Sonoma County
Solid Waste
Stabilization
Study8 .
Peak temperature recorded
was 43.9CC (111°F)
The season tempera
variations for thi
study shown an amb
range of almost 20
(78°F) over the am
cycle. In general
there is an appare
temperature respon
of the upper sever
feet of the landfii
Management of Gas
and Leachate in
Landfills9.
Ambient temperatures
during test cell studies
peaked at 35eC (95°F) for
air and 59°C (138.2°F)
for refuse.
Decomposition of
Landfills10
(1) 71°C (159.8°F) at
0.9m deep.
(2) 40°C (104'F) at
3.3m deep.
(1) Aerobic condi
near the surf;
of landfills
suiting in re]
tively high t
eratures. '
(2) Anaerobic con<
tions prevail
at deeper lay
of the landfi
thus lower tei
eratures.
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Table 2 (coat.)
Study/Reference
Temperature/Conditions
Remarks
6. Water Pollution
Potential of
Spent Oil Shale
Residues20.
Surface temperatures of
77°C (170.6°F) have
been measured in small
experimental plots due
to absorption of solar
energy.
Case spent shales
were studies in these
plots.
7. Evaluation of
Emission Control
Criteria for
Hazardous Waste
Management
Facilities26.
Study recommends that
materials with flash
points below 62.5eC
(150°F) need special
disposal considera-
tions .
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reproducible flash point testing procedure for solids. Solids
are usually poorer conductors of heat than liquids, and vary
widely in thermal transport properties. When a. solid is heated,
heat build-up is intense at the energy source, due to poor
conductance. The flash point of a given solid will therefore
depend on the duration of heating and the rate of change of
heating. For example, if a solid were heated slowly it
would register a lower flash point than if it were heated
quickly, due to the inability of solids to quickly reach
thermal equilibrium. In light of the above, EPA has concluded
that flash point is not an appropriate indicator of the
hazardousness of solid ignitable wastes.
While solid wastes generally do not present a hazard by
virtue of their ability to volatize, seme solid wastes do
present a hazard by virtue of their capacity to ignite and
burn as a result of friction, moisture absorption, or
spontaneous reaction under normal temperatures and pressures
encountered in waste management. Such wastes, which are
closely akin to reactive wastes, can cause direct injury to
workers or other persons as a result of fire, induced
explosions, or induced generation of toxic gases at almost
any point in the waste management process: transportation,
storage, treatment or disposal. EPA knows of no available,
standardized test methods for measuring the hazards associa-
•
ted with friction, moisture absorption^or spontaneous
reaction of solid wastes. J.M. Kuchta and A.F. Smith of the
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Bureau of Mines in a report that was done for the Department
of Transportation*^ established test methods for use in
classifying flammable solids. However two independent
contractors assigned the work of evaluating the proposed
test protocols determined that these test methods were not
reproducible 12,13,14. These test methods are furthermore
quite complex, require special equipment, and are not widely
used. In the absence of available test methods which can be
used to quantitatively define the ignitability hazard presented
by waste, EPA proposed a narrative definition similar to the
one used by DOT in its Hazardous Materials Regulation (49
CFR 173.150; see Appendix VII). The proposed narrative
definition was as follows:
a solid waste ..is. a hazardous waste if a re-
presentative sample of the waste .... is
liable to cause fires through friction,
absorption of moisture, spontaneous chemical
change or retained heat from manufacturing
or processing, or when ignited burns so
vigorously and persistently as to create a
hazard during its management.
EPA believes that this definition (as amended in accordance
with the discussion below), will be sufficiently specific to
enable generators to determine, through their knowledge about
the waste or its constituents or through their prior observa-
tions of and experience with similar types of wastes, whether
their solid waste is ignitable. The waste property defined
by this definition is that of thermal instability. Solid
wastes having this property will, like reactive wastes, be
easily detectable by the generator because experiences with
handling the waste or similar wastes will most likely have
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revealed this instability. Therefore, until the Agency,
DOT, or others are able to develop a nore quantified definition
of ignitable solids, with associated test methods, EPA believes
it is justified in using this narrative definition.
3. Ignitable Compressed Cases
Containers of ignitable compressed gases are occasionally,
but not frequently, discarded as wastes. The containers are
subject to mechanical rupture during transportation, storage
and disposal. In addition, they are subject to corrosion and
eventual leaking in long-term storage and land disposal. If
ruptured or corroded, the escaping gas could be ignited by
electrical sparks or other ignition sources, in the same
fashion as ignitable liquids. The fires resulting from such
ignitions threaten injury to workers, firemen, and other
exposed persons. DOT has defined cocpressed gases in its
Hazardous Materials Regulations (49 CFS. 173.300). This
definition sufficiently embraces the compressed gases which
are likely to be hazardous under conditions normally
encountered in the management of such wastes. Consequently,
EPA has adopted the DOT definition.
4. Ignitable Oxidlzers
EPA considered including in its ignitability character-
istic wastes which were not easily ignited but which, once
ignited, would burn and contribute to an ongoing fire. The
•
Agency has declined to classify such combustible wastes as
ignitable in recognition of the fact that virtually all non-
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metallic wastes, including paper, waste wood products and
other organic wastes might display this particular feature.
EPA believes that the waste management requirements imposed
under both Subtitle C and D of the Act, (which control open
burning and other conditions resulting in strong ignition
sources) will be sufficient to protect against any hazards
associated with such combustible wastes.
Notwithstanding the foregoing, EPA has determined that
strong oxidizing wastes should be classified as hazardous
wastes. Once combustion is initiated, these wastes would
promote and sustain very aggressive burning or fuming and,
therefore, would significantly increase the peril to workers,
firemen, and other exposed persons. EPA knows of no widely
available, simple, standardized test methods for measuring
and defining strong oxidizing wastes. In a DOT funded
study to develop a suitable test method,15 the Bureau of
Mines proposed an apparatus for testing oxidizers which
is based on the burning rate of a red oak sawdust/oxidizer
mixture. In three later studies 12,13,14j two independent
contractors were assigned the task of evaluating separately
the Bureau of Mines apparatus and classification system.
These contractors concluded that the reproducibility of the
test protocol was very poor. Consequently, EPA proposed
using the same narrative definition used by DOT in its
Hazardous Materials Regulations (49 CFR 173.151). EPA believes
this definition is sufficiently descriptive to enable waste
generators to ascertain whether they have an oxidizing waste.
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C. Rationale for Proposed Test Methods
1. Ignitable Liquid Test Protocols
There are two basic methods used for testing the
flash point of liquids: open and closed cup testers. Both
methods require that the sample he placed in a sample cup
and heated at a slow and constant rate. In a closed cup
tester, the test flame is inserted into a vapor/air mixture
within the closed cup and over the liquid, whereas in an
open cup, the test flame is passed over the vapor/air mixture
just above the liquid. While liquids will flash at the
same concentration of vapor and air in both cups they will
flash at a lower temperature in a closed cup. This is because,
in the open cup, the temperature must be raised to a greater
degree to achieve the same concentration of vapor and air as
in the closed cup since the vapor above the liquid is confined
in a closed cup but is allowed to diffuse into the atmosphere
in an open cup.
The Agency considers the closed cup tester to be more
suitable for testing the flash points of liquids. This is
because the closed cup tester better replicates the most
dangerous type of ignitable liquid waste situation — that
.is, the situation where vapor from ignitable wastes collects
in a closed space, such as in a storage drum, warehouse, etc.
A recent EPA report which lists a large number of accidents
involving landfill gas shows that volatile gases emanating
from landfills can accumulate in buildings, pipes, excavations,
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manholes and soil up to 1000 feet from the fill
In one such accident, gas emerging from a landfill collected
in a barn and caused injury when it exploded^". The
closed cup tester is a more conservative representation of
the hazard presented by such confinement of the vapor from
volatilized liquids. In addition, the closed cup tester is
not as subject to interference from air currents and gives
more reproducible results.
Closed cup testers come equipped with different features.
There are two types of temperature baths available. (A tempera-
ture bath is the heat transport media between the cup of the
tester and the heating element). Since the purpose of these
temperature baths is to insure uniform temperature around
the entire sample, a liquid bath is superior to an air bath
because liquids transport heat better than air. Also, there
are two types of heating elements; electric and gas. It
makes little difference in the test results whether the
apparatus has a gas or electric burner. Both are equally
accurate at the low temperatures of concern. An optional
feature for closed cup testers is a mixing device or stirrer.
The stirrer can prevent interference in the operation of
the test which results when test samples are very viscous,
tend to skin over, tend to stratify, or contain suspended
solids. If, for instance, a sludge is stratified, the upper
layers will inhibit the volatilation of the lower layers. The
evaporation of the lower layers will occur at the normal rate
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only when the lower layers are in direct contact with the
atmosphere. A mixing device cures this problem. Since the
most prevalent forms of waste streams destined for land
disposal are sludges and semi-solids, EPA believes that
closed cup testers should be equipped with a mixing device.
The closed cup tester which satisfies the above require-
ments is the Pensky-Martens Closed Cup Tester. Table 3
compares this tester with the Tag Closed Cup tester and
demonstrates available options. Table 4-ASTM Specifications
and Measured Performance for Several Flash Point Testers -
compares data on repeatability and reproducibility^. As
shown in this table, there are two testers that are fairly
reproducible, The Taliague and the Pensky-Martens Closed Cup
Testers.
J. Kuchta in his report to DOT^ made the following
recommendations:
According to the available data in the
literature, the Tag closed cup is suit-
able for determining flash points of
liquids over a temperature range from
about 220°F down to at least 0°F.
Although it is currently recommended
for determinations up to only 174°F,
ASTM Committee (D-2 and E-27) are
presently proposing that the maximum
temperature be increased to 200° or
220 °F for use with liquids having
a viscosity of 4 centipoise (100°F)
or less. For liquids of higher
viscosity or higher flash points,
the Pensky-Martens closed cup
is recommended. However, one can
also extend the use of the Tag tester
to the higher viscosity liquids by
employing a lower heating rate than
presently specified. A heating rate
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Table 3 - Comparison of Flash Point Tester Types
Type
Pensky-Martens (Fisher)
Pensky-Martens (Fisher)
Tagllague (Fisher)
Pensky-Martens (Fisher)
Pensky-Mnrtens (Fisher)
Sample Cup
Closed
Closed
Closed
Closed
Closed
S tlrrer
No
Yes
No
No
Yes
Bath
Air
Air
Liquid
Air
Air
Type of
Temperature Control
Electric
Electric
Electric
Gas
Gas
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TABLE 4 - ASTM Specifications and Measured
Performance for Several Flash Point Testers
Tester ASTM Designation Temp. Range °F Heating Rate °F/mln
Tagllaque D 56-64 55 2
Closed Cup 15-175 2
Pensky-Martens D 93-66 <220* 9-11
Closed Cup >220* 9-11
Repeatability** "F Reproduclblllty
2 6
2 4
4 6
10 15
^Kuehta, J.M. and D. Burgess. Recommendations of Flash Point Method for Evaluation of Flamraabil-
ity Hazard in the Transportation of Flammable Liquids, Safety Research Center, Bureau of Mines,
Report 054131, April 20, 1970.
*Less than
^Greater than
& •
** Duplicate results by the same operator
*** Results submitted by each of two laboratories
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of less than 0.5°F/min. or a aaximum
temperature difference of 5°F between
the bath and sample have been found
suitable for extending the applica-
bility of this tester to thicker fuels
and other highly viscous materials.
These recommendations are in order, except that using
the Tag tester for very viscous materials is not standard
practice. .Agitation of the liquid is necessary if the
liquid has a vicosity of 45 S.U.S.* or more at 37.8°C (100°F)*,
or if it contains suspended solids or has a tendency to fora
a surface film during testing. Consequently, the Pensky-Martens
has been recommended as the tester for ignitable liquids because
of the incorporation of a stirring device to handle the
testing procedure of sludges and slurries.
Another possible tester is the Setaflash tester, which
is an electronic apparatus. The Setaflash tester was investi-
gated and found to be a good means of flash point determination,
and thus has also been included in the proposed regulations
as a means for determining the flash point of ignitable
wastes. The Setaflash closed cup tester determines flash
points between 0 and 110°C (32 and 230°F) having a viscosity
lower than 150 stokes at 25°C (77°F)t. For liquids at or
below 45 S.U.S. at 100°F, the average of the duplicate results
obtained by the same operator on different days should be
* S.U.S. means Saybolt Universal Seconds as determined by the
Standard Method for Saybolt Viscosity (ASTM D88-5S and may be
determined by the Use of the S.U.S. conversion tables
specified in ASTM test D2161-66 folloving determination of
viscosity in accordance with the procedures specified in the
Standard Method for Transparent and Opague Liquids (ASTM
D445-65).
t Data on Setaflash available ASIM D3278-73.
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considered suspect if they differ by more than 1.7'C (3°F);
each of two laboratories should not differ by 3.3°C(6'F)t.
For viscous liquids above 45 S.U.S. at 37.8'C (100°F) or
liquids with dispersed solids, duplicate results obtained by
each of two laboratories should not differ by more than 5°C
(9"F)t Because this tester is relatively new, EPA asked one
ASTM Committee for recommendations regarding it. The opinions
were very positive from both government and industrial members
It seems the tester can save a laboratory a substantial
amount of money if repetitive flash point determinations are
needed, although the data for such savings was not attainable.
2. Ignitable Compressed Gas
Since EPA has adopted the DOT definition for
ignitable compressed gasses, the test method specified in
the DOT regulations has also been adopted. The Agency assumes
that this test protocol has undergone the required testing to
determine its accuracy, reproducibility, detection limits, etc,
IV. Comments Received on the Proposed Characteristic and
the Agency's Response to These Comments
The Agency received over one-hundred comment letters
and oral statements* addressing ignitability. Several of the
commenters agreed with the Agency's proposed definition. The
large majority of comments, however, expressed some concern
with the Agency's ignitability characteristic. These comments
* EPA held five public hearings to receive comnent
on the proposed hazardous waste regulations. The hearings
were held in New York City (2/7-9/1979), St. Louis, Mo.
(2/14-16/1979), Washington, D.C. (2/20-22/1979), Denver, Co,
(3/7-9/1979), San Francisco, Cal. (3/12-14/1979).
-24-
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have been categorized by either content or the portion of the
regulation addressed. A discussion of these follows:
A. Comments on Ignitable Liquids
1. A large majority of the coaaents objected to
the Agency's proposed limit for ignitable liquids
(140°F).
0 Many of the comoenters suggested that EPA
amend the proposed regulations and adopt DOT's
limit for flammable liquids (100°F). These
commenters argued as foliovs: (1) the higher
flash point limit chosen by EPA is not justified
since it is doubtful whether higher temperatures
will be encountered during the disposal of
hazardous wastes than during transportation,
(2) past drafts of the ignitability background
document list only two landfill fire incidents
in which the first material ignited was known
and in both incidents the flash point was less
than 100"F, (3) the DOT flash point limit is
based on experience and has provided adequate
protection against ignitable hazards in the
past, (4) there is some question whether the
140°F EPA flash point will capture significantly
more hazardous waste than the 100°F DOT flash
point, (5) EPA's use of s. different flash point
limit from that employed by DOT will create
-25-
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confusion in complying with DOT's placarding,
containerization and manifest requirements and,
(6) EPA's use of a different flash point goes
against the stated intent of ECRA to integrate
its provisions with those of DOT and other
agencies. In none of these comments was any
supporting data presented for changing the
flash point limit to 100'F.
The Agency disagrees with these comments for
several reasons. As noted above, a number of EFA
studies indicate that landfill temperatures
frequently exceed the linit of 100°F adopted by
DOT. Temperatures of as high as 170.6*F(77°C)
were experienced at or near the surface of test
landfill plots. These recorded temperatures
indicate that a flash point limit higher than
DOT's is justified by the conditions likely to
be encountered during disposal. Furthermore,
DOT's 100°F flash point linit does not appear to
take into account all of the heat sources available
to ignitable materials during transportation
and storage. J.M. Kuchta, et al., in an early
DOT study 1°, recommended "...that a flammable
liquid be defined as one with a flash point
below 140°F ...because temperatures of this
order can be encountered during shipcent ..."
Indeed, DOT's adoption of a 130° test temperature
in its metal corrosion standard in effect consti-
-26-
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tutes an acknowledgment that temperatures of
greater than 100°F are likely to be encountered
during transportation and storage (49 CFR 173.240)
The Agency disagrees with the statement that
the DOT requirement has in the past provided
adequate protection against fire incidents
during transportation and storage. The Agency
reviewed the NFPA files and found that 18 percent
of the fires in the "storage property" category;
13 percent of the fires in the "transportation
vehicle, structure" category; and 18 percent of
the fires in the "open-field-dump" category were
started by materials or wastes with flash points
greater than 100°F (Table 5 and 6). This data17
tends to demonstrate that liquids with flash
points greater than 100°F present a significant
ignitability hazard.
The Agency acknowledges that its damage
files show only two landfill fires in which the
"first material ignited" was known and that, in
both cases, the flash points were less than 100°F.
However, the Agency considers this irrelevant be-
cause it has never studied landfill fires.
Similarly, industrial and insurance companies
rarely investigate the causes of landfill fires
because such fires rarely result in a "large
loss." The available data from NFPA, indexed in
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Table 3, nevertheless shows that wastes with
flash points over 100eF do present a landfill fire
problem.
The Agency does not believe that its use of
a flash point limit different from that employed
by DOT will cause undue confusion to the regulated
community or interfere with DOT's placarding,
co'nt aineriz at ion and manifest requirements. The
term, "ignitability" was selected to minimize any
confusion to the regulated community since this
community is already familiar with the terms
"flammable" and "combustible." EPA's RCRA regu-
lations impose essentially no' new placarding or
containerization requirements for the trans-
portation and storage of ignitable hazardous
wastes other than those already imposed by DOT.
The most significant new shipping requirement
imposed by the RCRA regulations is that transpor-
ters of ignitable wastes comply with the manifest
requirement but this requirement is capable
of being easily integrated with DOT's own ship-
ping paper requirements. Furthermore, the tests
which generators are required to condmct under
the RCRA regulations are the same tests required
under the DOT regulations.
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TABLE 5
NFPA'a Report Involving Flammable/Combustible Liquids as the First Material Ignited
Fixed Property Use**
Class I ***
Flammable Liquids
Number of Fires
Class II ***
Combustible Liquid
Number of Fires
Class III ***
Combustible Llq<
Number of Fires
Public Assembly
Educational
Institutional
Residential
1&2 Family Dwelling
Apartment House, Hotel, etc
Store/Office
(Unto, liuluntry , Utility,
nitd DofttHtto
51
17
2
202
129
151
10
4
1
48
26
8
7
1
1
"
4
3
2
29
*Thn dntn bnno from which the Incidnntn worn nnloctnd Incl.tidcn principally the mora nerioua firos
which occurs in the United States. Although the sample of incidents Included here is sufficient to idont
and study signlgicant fire problems, it should not be taken as representative of fires of all severities.
The period covered by thLn roport In 1971-1976.
**Deflned by NFPA 901-see standard for further explanation.
***Defined by NFPA 30-see standard for further explanation.
-29-
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TABLE 5 (CONT.)
NFPA's Report Involving Flammable/Combustible Liquids as the First Material Ignited 17*
Fixed Property Use **
Class I ***
Flammable Liquids
Number of Fires
Class II ***
Combustible Liquid
Number of Fires
Class III ***
Combustlbel Llq
Number of Fires
Manufacturing
Food
Beverage, Tobacco, Liquor
Textile
Footwear, Wearing Apparel
(Leather Rubber)
Wood, Wood Product
Chemical, Plastic, &
Petroleum
Metal, Metal Product
Vehicle Assembly
7
6
5
2
30
33
21
12
3
3
2
3
5
15
3
2
1
2
13
12
60
5
Storage Property
Spoctnl Property
Any unoccupied & under
construction
Transporation vehicle,
sturcture
Open field, dump
93
13
277
23
11
28
5
12
*The data base from which the Incidents were selected includes principally the raoro soriouo flroa
which occurs in the United States. Although the sample of incidents included here is sufficient to
identify and study signigicant fire problems, it should not be taken as representative of fires of
all severities. The period covered by this report is 1971-1976.
**Defined by NFPA 901-see standard for further explanation.
by
NFPA 30-see standard for further explanation.
-------
TABLE 6
Percent Class II and Class III Fires as First Material Ignited 17
Fixed Property Use Class II Class III
Combustible Liquids Combustible Liquids
X of Total * % of Total **
Public Assembly 7 2
Educational 6
.Institutional 33
Residential
1&2 Family Dwelling 19 2
Apartment House, Hotel, etc. 16 2
Store/Office 5 1
Basic Industry, Utility,
and Defence 15 63
Manufacturing
Food 25 17
Beverage, Tobacco, Liquor' 33
Textile 25 12
Footwear, Wearing Apparel
(Leather Rubber) 7 50
Wood, Wood Product 28
Chemical, Plastic, «•
Petroleum 10 24
Metal, Metal Product 16 63
Vehicle Assembly 15 25
*% of Total - #of Class II Fires (Table 1.4.l)/(ClasB I + Class II + Class III)
**% of Total - lof Class HI Fires (Table 1.4.1) / (Class I + Class II 4- Class III)
-31-
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TABLE 6 (CONT.)
Percent Class I and Class III Fires as First Material Ignited
Fixed Property Use
Class II
Combustibles Liquids
% of Total *
Class III
Combustible Liquids
% of Total **
Storage Property
Special Property
Any unoccupied & under
construction
Transporatlon vehicle,
structure
Open field, dump
10
8
9
18
* X of Total - 0 of Class II Fires (Table 1.4.1)/(Class I + Class II + Class HI)
** % of Total - # of Class III Fires (Table 1.4.I)/(Class I + Class II + Class III)
-32-
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While the Agency acknowledges that main-
taining consistency between its Section 3001
regulations and those of DOT is a desirable
goal, it does not believe that such consistency
should be achieved at a sacrifice of environmental
protection. Lowering its flash point limit to
100*F would exclude from regulation wastes
which present a real hazard. Congress explicitly
contemplated such disagreement between EPA
and DOT when it provided at Section 3003 of
RCRA that the Administrator "is authorized
to make recommendations to the Secretary of
Transportation respecting the regulation of
...hazardous waste under the Hazardous Materials
Transportation Act and for addition of materials
to be covered by such Act."
0 A number of commenters argued that EPA's
definition of ignitable waste could be made
consistent with DOT's regulations by adopting
both DOT's definition of flaiamables (F.P. 100°F)
and DOT's definition of combustibles (F.P. 100CF
- 200°F) and including both categories within
EPA's ignitable waste classification.
EPA originally considered controlling wastes
with a flash point of up to 200°F. However, the
Agency concluded that, even though such wastes
might present a hazard once ignited, wastes which
are easily ignited under conditions encountered
-33-
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during transportation, storage, and disposal present
the greater danger. Therefore the Agency elected
not to control wastes with a flash point of up to
200°F under Subtitle C of RCRA and believes
that to control such wastes would create an
additional burden and expense to the regulated
community, which is not justified solely by
considerations of consistency.
0 One commenter suggested that the Agency develop
a two-tier system for defining ignitable liquids
by adopting the DOT flammable category for wastes
with flash points less than 100°F and adding a
combustible category for wastes with flash points
from 100°F to 140°F. The primary justification
given for this two-tier system was the assertion
that the 140° temperature specified in the
ignitability flash point limit might be applicable
to the disposal of wastes in landfills but not to
transportation of wastes. No data was presented
in support of this assertion.
The Agency disagrees with this comment for
two reasons. First, as noted above, the DOT
flash point limit of 100°F does not take into
account the full range of temperatures likely
to be encountered during the transportation of
hazardous wastes. J.M. Kuchta, et al., in an
early DOT study, recommended that DOT adopt a
-34-
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flash point limit of 140*F for flammable liquids
because temperatures of this order can be
encountered during transportation. Second,
erecting a two-tier system in which some wastes
were regulated for purposes of disposal but not
for purposes of transportation would not be
compatible with the hazardous waste management
system mandated by the Act and the regulations.
The Act envisions and the regulations require a
comprehensive "cradle-to-grave" management
control system which tracks hazardous waste
from its point of generation to ultimate disposal.
Piecemeal regulation of waste for disposal purposes
would be administratively infeasible and not in
accordance with this system.
Several commenters pointed out that under DOT's
regulations, "combustible" liquids packed in
containers of 110 gallons or less are exempted
from DOT's placarding, containerization, etc.
requirements. These cotmenters argued that since
EFA intends to regulate 110 gallon quantities of
"combustible" liquids with flash points In the
range 100°F - 140°F, confusion will result.
The Agency believes that any confusion
caused by the Agency's regulation of 110 gallon
quantities of DOT defined combustibles will be
minimal. Host generators who ship in less than
110 gallon quantities will probably fit within
-35-
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the Agency's "small generator exemption" and will
thus not be subject to any EPA-imposed shipping
requirements. It should nor cause any undue
confusion to require generators who ship in less
than 110 gallon quantities but do not fit within
the "small generator exemption" to observe DOT
placarding, etc. requirements.
Several commenters proposed that .the Agency
eliminate the inconsistency between its ignitable
standard and DOT's flammable and combustible stan-
dards by petitioning DOT to raise its flash point
limit for flammable liquids to 140°F. The
Agency has requested DOT to change its flash
point limit for flammable liquids to 140°F, but
DOT refused.
Some commenters expressed concern that the
Agency's ignitability definition would include
waste fuel oils which could be burned as fuel
oil and thus put to a beneficial re-use. The
regulations promulgated today will not include
waste oils which are beneficially reused or
reclaimed. Waste fuels which are put to bene-
ficial re-use will thus not be regulated as
hazardous.
One commenter argued that the autoignition
temperature is a better measure of the hazard
presented by liquid waste than the flash point.
-36-
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This comment has been adequately responded to
above and needs no further response here.
2. A number of comments objected to the proposed test
protocols for the ignltability flash point limit (140°F).
Several commenters argued that an open cup flash point
analysis better simulates landfill conditions and is
therefore a better measure of the hazard presented by
liquid ignitables than a closed cup flash point
analysis.
The Agency does not disagree than an open cup
analysis can simulate landfill conditions. However,
as noted above, the closed cup tester was selected
because it simulates the most dangerous type of
hazardous waste situation — that is, the situation
where ignitable liquid vapors collect in a confined
space such as a storage area or a structure adjacent
to a landfill. Another reason the closed cup tester
was selected is that the open cup tester does not
give results which are as reproducible as those of the
closed cup tester.
" Several commenters agreed with the upper flash point
limit of 140°F using the closed cup method but also
urged the Agency to include an optional limit of
100°F using the open cup method. The basis for
this suggestion was that some reference books only
present open cup data.
The Agency disagrees with these commenters on two
counts. First, most reference books list flash points
-37»
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only for pure substances and simple mixtures. Waste
streams are complex mixtures whose flash points can only
be ascertained by testing and not by consulting a
reference book. Secondly, a liquid tested in a closed
cup tester generally flashes at a lower temperature
than the same liquid tested in an open cup. Conse-
quently, if the Agency were to prescribe an optional
open cup flash point limit equivalent to its closed
cup flash point limit, that limit would of necessity
be higher than the closed cup limit. Unfortunately,
the Agency has not discovered an appropriate means
of equating the two types of testers.
3. A number of commenters argued that the ignitability
characteristic improperly includes many liquid wastes
such as wine, latex paint and other water borne coatings
which contain low concentrations of volatile organics
such as alcohol and will consequently exhibit flash points
below 100*? but will not sustain combustion because of
the high percentage of water present. These commenters
urged that the regulations should either specifically
exempt such wastes or that the test for ignitability
should be expanded to include alternative test methods
such as the British Combustibility Test or the ASTM
Wick Test which measure the ability of materials to
sustain combustion. These commenters pointed out that
DOT currently excludes from its flammable category
aqueous solutions containing 24 percent or less alcohol
by volume.
-38-
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The Agency generally agrees with the concerns
expressed by these commenters. However, problems do
exist in formulating an acceptable solution. The Agency
has at present no data which identifies the relation-
ship between the concentration levels of volatile .organics
in aqueous solutions and the established flash point of
140°F. Consequently, the Agency has opted, for the
time being, to use an exclusion similiar to that
prescribed by DOT and exempt from the ignitability
characteristic aqueous solutions with alcohol concentra-
tions of less than 24 percent by volume. This exclusion
will remove from the ignitability characteristic such
things as wine and latex paint which flash at less than
100'F but will not sustain combustion. The Agency will
undertake additional work to determine whether this
alcohol/water Unit is sufficient or whether another
limit is more appropriate. Once development of the
British Combustibility Test and the ASTM Wick Test is
completed, the Agency will also evaluate these two
proposed supplemental test methods to determine whether
they can be used.
4. One commenter suggested that the Tag Closed-Cup
Tester (ASTM method D-56) be included in the regulations
as an equivalent methods in testing ignitable liquids.
The commenter argued that since this method was allowed
by DOT to test ignitable liquids, EPA should also allow
this method in order to avoid needless duplicate testing.
-39-
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The Agency has not designated the Tag Closed Cup
Tester as an acceptable tester because the Tag Closed
Cup Tester does not incorporate a stirrer and thus is
not suitable for testing wastes which are very viscous,
skin over; tend to stratify or contain suspended solids.
Since most liquid wastes are expected to be in sludge
or semi-solid form, the usefulness of the Tagliague
Closed Cup Tester was judged to be limited. The regula-
ted community is, however, still free to'demonstrate
under the procedures provided in §§260.20 and 260.21 that
the Tag Tester is equivalent to the specified methods.
5. One comraenter argued that an ignitable waste
should simply be defined as a waste that is being
handled at a temperature greater than its flash point.
The Agency disagrees with the commenter. The
commenter's proposed definition would make the hazard-
ousness of a given waste entirely dependent on the
handling that waste was getting at a particular moment.
Such a highly variable definition of hazardous waste
would make identification of ignitable wastes and
enforcement of the regulations impossible.
B. Comments on Ignitable Solids
1. A large number of commenters disagreed with the
proposed definition for solid ignitable wastes. Many
.JV
commenters argued that the definition as proposed could
be construed to include many non-hazardous materials such
as bark, wood chips, wastepaper, corrugated boxes, tires,
grass, etc. and suggested that the definition be revised
-40-
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to make clear that this result was not Intended. Some
of the comnenters suggested that the definition be
clarified by eliminating the phrase "or when ignited
burns so vigorously and persistenly as to cause a
hazard during management." Others suggested changing
"or when ignited burns so vigorously and persistently
as to create a hazard during its management" to "and
when ignited burns so vigorously ..."
As indicated earlier, the Agency has no intention
of designating such things as waste paper, saw dust,
etc. as hazardous. It is only interested in designat-
ing solids which are liable to cause fires through
friction, absorption of moisture, etc as hazardous.
Such solids are thermally unstable and will often fit
within the reactive classification as well as the ignit-
able classification. To reflect this intention, the
Agency has amended its final regulation by changing "or
when ignited burns so vigorously ..." to "and when
ignited burns so vigorously ..." This language makes
clear that the Agency does not consider materials which
simply burn vigorously such as wastepaper to be hazardous
2. Several comnenters argued that the definition as
proposed was too vague and did not provide the generator
with enough guidance for determining whether or not his
waste was ignitable. These comaenters went on to
recommend that a nore specific test be established for
solid ignitables.
-41-
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The Agency considers the prose definition of solid
ignitables to be sufficiently specific to enable the
generator to determine whether or not his waste is
hazardous under the regulations. Most generators whose
solid wastes are dangerous due to their ignitability
will be well aware of this property since ignitable
solid wastes present special problems in handling,
storage and transport. It will oaly be rare instances
that a generator would be unsure of the ignitability
of his solid waste or unable to assess whether the
waste fits the prose defintion. Unfortunately, as
noted above, no test methods have been adequately
developed which adequately measure the ignitability
hazard presented by solid wastes. Therefore until
an adequate test method is developed, the Agency
will continue to use a prose definition for non-liquid
*
ignitables.
3* Several commenters pointed out that the proposed
definition classify slags from refining operations
as hazardous on the basis of their retained heat.
These commenters argued that inclusion of these
slags as ignitable was outside the intent of Congress •
and suggested that the regulation be modified to
exclude slags.
In proposing the non-liquid (solid) ignitability
definition, the Agency was concerned with wastes such
as slags which retain a considerable amount of heat
and which, if placed in a landfill, could present
-42-
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a problem by raising the temperature of other wastes
to their flash points. However, in re-evaluating
this class of wastes, the Agency believes that these
wastes are produced in such high volume that they
would never end up in a sanitary landfill and present
the problem as described in the above scenario.
Therefore, the Agency has amended the regulation by
deleting the following phrase "...or retained heat
from manufacturing or processing."
Comments on Ignitable Gases
1* One commenter suggested that the term "ignitable
compressed gases" be changed to "flammable compressed
gas" as defined by DOT in 49 CFR 173.300 (b).
The term "ignitable" has been used by the Agency
to maintain consistency with the rest of the Agency's
ignitability definition. It should be clear from the
definition that, insofar as compressed gases are
concerned, the Agency's use of "ignitable" a.nd DOT's
use of "flammable" are indistinguishable. Therefore,
there is no need to modify the final regulation as
suggested by the commenter.
2. One commenter recommended that ignitable com-
pressed gases be excluded from the definition of
ignitable waste since the main hazard presented by
gases occurs during transporation.
The Agency disagrees with this commenter. An
ignitable contained gas, with pressure greater than
f
-43-
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40 Ibs. per sq. Inch, could present a danger to
human health and the environment through the leaking
or rupture of the container during handling or
disposal, as well as during transportation.
D. Comments on Ignitable Oxidizers
1. One commenter requested further clarification on
the definition of oxidizer.
49 CFR 173.151 defines an oxidizer as "a
substance such as chlorate, permanangana-te, inorganic
peroxide, nitro carbo nitrate, or a nitrate, that
yields oxygen readily to stimulate the combustion
of organic matter." Section I73.151a goes on to
define the term organic peroxide. This definition
is as good a description of oxidizing conpounds as
has been developed short of using a test method
with a quantitative limit. Unfortunately, as noted
above, an appropriate test method has not been
developed by the Agency or any other organization
and until one is found the proposed definition
will be used.
2. One commenter questioned the possible overlap
between ignitable oxidizers and reactive oxidizers.
The commenter went on to question whether these
wastes would have to be recorded as both reactive
and ignitable on manifests and reports*
The difference between ignitable oxidizers and
reactive oxidizers is largely a natter of degree.
-44-
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Thus, it is almost impossible to draw a clear line
between the two. However, for purposes of these
regulations, an oxidizer which reacts violently should
be considered a reactive waste; on the other hand, an
oxidizer which reacts in a milder manner; should be
considered an ignitahle oxidizer. In the main, the most
important consideration is that these oxidizers be
cortro1led sufficiently to prevent danger to human
health and the environment.
E. Summary of Data on the Ignitability Tester Published in
the NUS Report* and Response to Comments Received on
that Noticed Report
On December 28, 1979 (44 FR 49278), the Agency noticed
a report for comment which contained the results of running
the PenskyMartens flash point tester to determine the
flash points of two selected waste sludges. The flash
point determinations were presented at Table 5, (pg.47),
and included the following explanation:
The ignitabilty (flash point) test results obtained
by the Pensky-Martens Closed Tester are exhibited in
Table 5. The ASTM method states that results submitted
by each of two laboratories should be considered sus-
pect if the results differ by more than 3.3°C (6°F) for
suspensions of solids having a flash range between 35
to 43.3°C (95 to 110'F). The procedure further
states that the reproducibility between the average
of duplicate results by two individuals or laboratories
would be considered suspect if the results differ by
*"Evalution of Solid Waste Extraction Procedures and Various Hazard
Identification (Final Report)", NUS Corporation, September, 1979.
-45-
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TABLE 5
ANALYSIS RESULTS FOR IGNITABILITY TESTS
Sample
•Refinery Sludge
(Tank Bottoms)
Paint, Pigment
Sludge
Refinery Sludge
(Tank Bottoms)3
Laboratory
J
K
J
K
J
K
Flash
C
31.1
-5.6
33.3
43.3
>82.2
>93.3
Point
F
88
22
92
100
>180
>180*
aSame sample, repeat analysis; no explanation can be offered
for the differences.
*0ne commenter noted that the F° conversion for >93.3 was in-
correct (i.e.', the conversion of >93.3°C should be >200°F not
180°F). The Agency agrees with this commenter.
-46-
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more than 10"C (18"F) for viscous and/or heavily
pigmented materials (e.g., paint and pigment sludge).
The refinery sludge (tank bottoms) results are defi-
nately not in agreement, whereas the paint and
pigment sludge results are considered questionable.
NUS made these conclusions about the Pensky-Martens
tester and the two samples:
The Pensky-Martens Closed Cup Tester gave incon-
sistent results for the refinery sludge (tank bottoms)
and marginal results for the paint and pigment sludge.
The refinery sludge was an oily mixture containing
water, and variable results can be expected for a non-
homogeneous sample of this type. The paint and
pigment sludge was highly viscous. The Pensky-Martens
Closed Cup Tester or equivalent is acceptable for
homogeneous mixtures containing a large fraction of
flammable volatiles. However, industrial wastes which
are viscous, heavily pigraented, and/or nonhomogeneous
are expected to give inconsistent and perhaps conflicting
test results. A different method may provide better
results with other sample types.
Two commenters stated that the results presented in the
NUS report seriously question both the validity and repro-
ducibility of the procedure. One coamenter argued that
given the contradictory results from the NUS ignitability
tests, additional developmental work needs to be conducted
to better define the test conditions and parameters of the
test. Another commenter stated that, until this was done,
the scientific basis for defining ignitable hazardous
waste would be inadequate. A third commenter stated that
inconsistent and perhaps conflicting test results are ex-
pected for other viscous, heavily pigmented wastes. The
first commenter noted that, in the refinery sludge sample, the
difference in flash point measurements between the two labora-
tories was 36.6°C or 66*F, and that when the samples were
-47-
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again run, the results were vastly different. This cosmenter
further noted that in this second run laboratory J, which
had initially reported a value of 31.1*, reported a value
of >82.2°C, a value which was totally unaceptable since
82.2*C is a temperature that should be determined with
precise accuracy by the use of comnonly available equipment.
The Agency believes that these conmenters may have been
somewhat rash in condemning an, industrially accepted standard
test method (the Pensky-Martens Closed Cup Tester - American
Society for Testing Materials Standard D-93-72) based on
the review of trial runs performed on two samples. This test
method has for a number of years been used successfully
by the Department of Transportation in its regulation of
hazardous materials. The Agency agrees that the (1) non —
homogeneous nature of one sample and (2) the high viscosity
of the other may have surpassed the liaits of the particular
test*. However, the Agency does not agree that the two
test results reported in the NUS report are sufficient indi-
cation that the test may not be reproducible. A large
number of circumstances could have produced this difference
in flash points. Difficulty in sampling and splitting
oil/water mixtures, insuring that light volatile fractions
*In promulgation of the ignitability standards»in todays
Federal Register, the most current test standards will be
incorporated (i.e. , Pensky-Martens Closed Cup Tester D93-
78). This updating should improve the applicability of
the test methods to sludge because of the incorporation of
dewatering techniques and viscosity limits.
-48-
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do not escape during handling, and sample preservation all
could have contributed to false readings. Next, the same
samples were run through the flash point .test at different
times. (The tank bottom sample was first run in the labora-
tories in November of 1978; these samples were then tested
again in February of 1979. The result of which produced
the much higher flash points of >180°F. In disagreement
with the commenter; this is an acceptable way to present
the data, as the samples began to boil around 180°F and
the test had to be terminated. The Agency was in error in
having the tank bottom sample re-tested after such a delay
in time and not reporting so. The other waste stream to be
tested (paint and pigment sludge) was a highly viscous
homogeneous waste with suspended solids. No viscosity
determination was made before the test. The result for
this test showing a 18eF difference between the two labora-
tories is a very good result considering the extreme viscos-
ity of the sample, only one test performed at each labora-
tory, and lack of a sample preservation technique. Obser-
vations made during the test were not reported.
One commenter argued that the additional cited docu-
ment did not provide validation of the characteristic test
method for listing or delisting. The Agency agrees with
this commenter. However, the primary objective in running
the test was to develop additional baseline data on running
wastes in the Pensky-Martens Closed Cup Test, not to validate
the test. The Agency assumes that this test method has al-
-49-
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ready been validated since the test method has been adopted
by DOT in their transportation regulations and is commonly
accepted by industry as a standard test method.
One commenter presented a rationale that explains
the failure of the two laboratories in relating equivalent
results. Stating, such results can be obtained in the
event that the sampling procedures, subsampling procedures,
and finally the individual test sampling procedures ".re
not all representative of the starting material. The
commenter goes on to say that what is needed is a method
of obtaining a small representative portion of these materials
That is to say, a sample of approximately 100-150 ml which
is in turn representative of the original sample, e.g., a
lagoon or holding tank. Such materials are, frequently,
themselves inhomogeneous and contain lumps and even rubbish
so that a truly representative sample from all strata
within the holding tank or lagoon and from various locations
should be appropriately composited into a large vessel.
This large initial vessel, possibly a five gallon container
or even a fifty-five gallon drum, itself should be tightly
capped during storage and thoroughly homogenized before sub-
samples are taken. Also, the commenter suggests that
after the test samples have been obtained, they should be
introduced without delay into the Pensky-Martens apparatus
at room temperature. If the sample flashes immediately,
another sample aliquot should be cooled and introduced into
-50-
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a clean cooled Pensky-Martens apparatus. Further, the
flash point technician should be thoroughly trained in the
sciences of running the Pensky-Martens apparatus. This
commenter also relates that in their experience lumps of
material and bumping during the stirring process can lead
to spuriously high or spuriously low flash points. The
commenter recommends that the testing be reported in duplicate
(do not average). If values disagree by more than some
specified value (pick a number), then run samples in dupli-
cate on another test date. Report all data obtained together
with all anecdotal information, e.g., "couldn't stir sample,"
"sample foamed," "boiled over," "extinguished flame."
The Agency feels that this commenter1s suggestions are
very much in order. EPA is currently developing a sampling
methodology, sample preservation, and sample splitting
handbook which will be available to the public. The problem
of obtaining a representative sample of a particular waste
stream so that appropriate testing can be accomplished has
been a concern of the Agency and it's contractors who must
sample and analyze waste streams. The Agency agrees that
reporting anecdotal information or observations made during
a test is necessary. Data collection on very viscous,
high solids, and/or nonhomogeneous sludges will .be the way
the Agency assesses the hazard of sludges which because of
some physical restraint are outside the limits of a particular
tester. This is not to say that what is not reproducible
in one standard is reproducible in another. The Agency
-51-
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again agrees with this commenter in that more information
should be reported concurrently with flash points so that
proper hazard evaluation can be made.
V. Promulgated Regulation
As a result of EPA's review of the comments regarding
the ignitability characteristic, EPA is promulgating an
ignitability characteristic which differs from the proposed
regulations in two aspects. First, the definition for
liquid igni.tables specifically excludes wastes which have
a flash point less than 140°F and contain 24 percent or
less alcohol by volume; secondly, the definition for non-
liquid ignitables has been clarified ro better reflect the
Agency's regulatory intent.
§261.21 Characteristic of ignitability
(a) A solid waste exhibits the characteristic of
ignitability if a representative sanple of the waste has
any of the following properties:
(1) It is a liquid, other than an aqueous solution
containing less than 24 percent alcohol by volume, and has
a flash point less than 60°C (140°F), as determined by a
Pensky-Martens Closed Cup Tester, using the test method
specified in ASTM Standard D-93-79, or a Setaflash Closed
Cup Tester, using the test method specified in "ASTM standard
D-3278-78, or as determined by an equivalent test method
approved by the Administrator under the procedures set
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forth in §§260.20 and 260.21.*
(2) It is not a liquid and is capable, under
standard temperature and pressure, of causing fire through
friction, absorption of moisture or spontaneous chemical
changes and, when ignited, burns so vigorously and persis-
tently that it creates a hazard.
(3) It is an ignitable compressed gas as defined
in 49 CFR 173.300 and as determined by the test methods
described in that regulation or equivalent test methods
approved by the Administrator under §§260.20 and 260.21.
(4) It is an oxidizer as defined in 49 CFR
173.151.
(b) A solid waste that exhibits the characteristic of
ignitability, but is not listed as a hazardous waste in Sub-
part D, has the EPA Hazardous Waste Number of D001.
*ASTM Standards are available from ASTM, 1916 Race Street,
Philadelphia PA 19103.
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References
1. Up-date, ASTM Committee on Flash Point Methodology and
Government Response. Memorandum. C. Oszman, Office of
Solid Waste to A. Corson, Office of Solid Waste.
December 4, 1978.
2. Department of Transportation. Hazard Materials Regulations
Code of Federal Regulations. Title 49. Part 171-177.
Federal Register Part IV. Monday, September 27, 1976.
3. Ohio. Ohio Revised Code. 3734. EP-20-01.
4. Kuchta, J.M. and David Burgess. Recommendation of Flash
Point Method of Evaluation of Flasraability Hazard in
Transportation of Flammable Hazard in Transportation
of Flammable Hazard in Transportation "of Flammable
Liquids. April 29, 1970. lip.. Available from
National Technical Information Service, 5258 Port Royal
Road, Springfield, Va . 22151. PB-193077.
5. Department of Labor. Hazardous Materials Regulations.
Title 29. Code of Federal Regulations. Part 1910.106.
6. Blannon, Janet C. and Mirdza L. Peterson. Survival of
Fecal Coliforms and Fecal Streptococci in a Sanitary
Landfill. News of Environmental Research in
Cincinnati. U.S. EPA, April 12, 1974.
7. Wigh, Richard J. Boone County Field Site Interim Report
Test Cells 2A, 2B, 2C, and 2D. Solid and Hazardous
Waste Research Division, Municipal Environmental
Research Laboratory, Cincinnati, Ohio. EPA-600/2-79-058,
8. EMCON Associates. Sonoma County Solid Waste Stabilization
Study. Environmental Protection Agency. National
Technical Information Service, U.S. Department of
Commerce, Springfield, Virginia. PB - 239 778.
9. Banerji, Shanka K. Management of Gas and Leachate in
Landfills. Proceedings of the Third Annual Municipal
Solid Waste Research Symposium. NTIS, Springfield,
Virginia. EPA-600/9-77-026. September, 1977.
10. Eliassen, R. Decomposition of Landfills. American
Journal Public Health. 32 9, 1029 (1942).
11. Kuchta, J.M. and A.F. Smith. Classification Test Methods
for Flammable Solids. Report of Investigastion 7593.
Pittsburg, Mining and Safety Research Center. Bureau
of Mines. Pittsburg, Pa. 1972.
-54-
-------
12. King, P.V., and C.A.H. Lasseinge. Hazard Classification
of Oxidizing Materials and Flammable Solids for
Transportation Evaluations of Test Methods. Department
of Transportation Report TSA-20-72-6. National Technical
Information Service, Springfield, Va. 22151.
13. Hough, R., A. Lasseigne, and J. Fankow. Hazard Classi-
fication of Flammable and Oxidizing Material for
Transportation-Evaluation of Test Methods, Phase II.
Department of Transportation Report TES-20-73-1.
National Technical Information Service, Springfield,
Va. 22151. April 1973.
14. Dale, C.6. Classification of Oxidizers and Flammable
Solids, Phase III. Department of Transportation
Report TES-20-75-2. National Information Technical
Information Service, Springfield, Va. 22151. March 1975.
15. Kuchta, J.M., A.L. Furno, and A.C. Inhof. Classification
Test Methods for Oxidizing Materials. U.S. Dept. of
Interior, Bureau of Mines Report of Investigations
7594. 1972. (Ap-pendix B-6)
16. Methane on the Move: Your Landfill's Silent Partner.
An Administrative Guide, Intergovernmental Methane
Task Force. U.S. EPA Region VIII, March 1979.
17. Personal communication. M.J. DiMeo, National Fire Protection
Association to D. Viviani, Office of Solid Waste, August 26,
1977.
18. California. Environmental Health. Title 22. Register 77,
No. 42-10/15/77. Chapter 2. Minimum Standards for Manage-
ment of Hdazardous and Extremely Hazardous Wastes.
Article 1. Definitions. Section 60112.
19. Minnesota. Minnesota Pollution Control Agency.
HW-1 General Applicability, Definitions, Abbrevia-
tions, Incorporations, Severability, and Variances.
HW-2 Classification, Evaluation, and. Certification
of Waste. Draft Document. June 3, 1977.
20. Oregon. Proposed Regulations on Hazardous Waste
Disposal. 63-015(1) (C). Sep 4, 1975.
21. Washington. Washington State Department of Ecology.
Washington Administrative Code (WAG). Hazardous
Waste Regulations. Chapter 173-302 WAC.
Juanuary 27, 1978.
22. Consumer Product Safety Commission. Title 16. (Conmercial
Practices). Code of Federal Regulations. Part 1500.
-55-
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23. National Fire Protection Association. Fire Protection
Handbook. National Fire Protection Association
International. 60 Batterymarch Street, Boston 10,
Mass., U.S.A. Chapter 11, Fire Hazard Properties of
Flammable and Combustible Liquids.
24. Personal communication. Max J. Blanchet, Pacific Gas
and Electric Company to Chris W. Rhyne, Office of
Solid Waste, EPA. January 25, 1979.
25. Denver Research Institute. The Disposal and Environ-
mental Effects of Carbonaceous Solid Wastes from
Commercial Oil Shale Operations. National Technical
Information Service. Springfield, Virginia. PB-231-
796. January, 1974.
26. Green, H.E., J.R. Johnson, S.F. Page, G. Richard,
K.M. Slimak, and M.M. Yamada. Evaluation of Emission
Control Criteria for Hazaradous Waste Management
Facilities. Final Report EPA Contract No. 68-01-4645,
April, 1978.
-56-
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Bibliography
National Fire Protection Association.
Fire Protection Guide on Hazardous Materials.
6th Edition.
Boston, Massachusetts. 1975
National Fire Protection Association.
National Fire Codes.
Boston, Massachusetts. 1973.
Department of Transportation.
Hazardous Materials Regulations.
49 CFR Parts 171-177.
Federal Register Part IV.
Monday, September 27, 1976.
U.S. Environmental Protection Agency.
Issue Analysis from Discussions at Four Public Meetings
Public Meetings Record (SW-524). December 1975.
Kuchta, J.M. and A.F. Smith.
Classification Test Methods for Flammable Solids.
Bureau of Mines Report of Investigation 7593. 1972.
Underwriters' Laboratories, Inc..
Tests for Comparative Flammability of Liquids.
Stgandard for Safety 340.
March 24, 1972.
Grumpier, Gene.
Development of a Working Definition for
Volatility of Potentially Hazardous Liquids and Solids.
OSW - Technology Assessment Program - SPA.
Kohan, A.M..
A Summary of Hazardous Substances.
Classification Systems.
U.S. EPA Report 0SW-171. 1975.
Environmental Protection Agency
OSW Hazardous Waste Guidelines and
Federal Register Part V Monday, May 2, 1977.
Electronic Industries Association.
Ignitability and Flammable Tests.
EIA RS-325. June 1966.
ASTM. Standard Method of Testing for
Ignition Properties of Plastics D 1929-68.
ASTM. Standard Method for Testing for
Vapor Pressure of Petroleum Products (Reid Method)
D 373-72.
-si-
-------
ASTM. Standard Method for Testing for
Vapor Pressure of Petroleum Products (Micro Method)
D2551-71.
ASTM. Standard Method for Testing for
Flash Point by Pensky-Martens Closed Tester
D 93-73.
ASTM. Standard Method for Testing for
Flash Point of Chemicals by Closed-Cup Methods
E 502-74.
ASTM. Standard Method for Testing for
Flash Point of Liquids by Setaflash Closed Tester
D 3278-73.
ASTM. Standard Method for Testing for
Flash Point by Tag Closed Tester
D 56-70.
Kirk-Othmer. Encyclopedia of Chemical Technmology.
Second Edition. Interscience Publishers.
Chemical Rubber Company.
Handbook of Chemistry and Physics. 56th Edition.
Litton Educational Publishing, Inc. 1968.
Department of Transportation*
Annual Report of the Secretary of Transportation on
Hazardous Materials Control.
Section 302, PL 91-458. 70, 71, 72, 73, 74, and 75.
Battelle Memorial Institute.
Program for the Management of Hazardous Waste,
EPA Office of Solid Waste Management Programs.
King, P.V. and A.H. Lasseigne.
Hazardous Classification of Oxidizing Materials and Flammable
Solids for Transportation - Evaluation of Test Methods.
Report No. TSA-20-72-6.
National Technical Information Service.
Department of Transportation.
.Hazard Classification of Flammable and Oxidizing Materials for
Transportation - Evaluation of Test Methods, Phase II.
Report No. TES-20-73-1.
National Technical Information Service.
"Dale, Charles B.
Classification of Oxidizers and Flammable
Solids, Phase III.
DOT - Office of Hazardous Materials
Report No. TES-20-75-2.
National Technical Information Service.
-------
Kovalick, Walter W. , Volatility of Hazardous Waste (Information)
Memo to John P. Lehman, OSW, EPA. August 15, 1975.
-------
Appendix I
Examples of Accidents
Involving Ignitable Waste
-------
East St. Louis, St. Clare County
The Mal-Milam landfill has accepted various industrial
wastes for more than ten years. Some of these wastes come from
the Chrysler Corporation and Mallinkrodt Chemical Works and
include solvents (phenols) and wastes from plastics manufacture.
Two serious fires occured at the site during compaction operations
on August 29, 1973 and on April 4, 1974. The fires burned for
two days and involved personal danger and much difficulty to
extinguish. Only after the second fire when the disposed
permits came under review were changes made in the operation.
Fire protection handbook lists phenol (C6H50H) with a flash
point of 175°. Waste from plastics manufacturing may include
a number of ignitable solvents and their still bottoms.
Illinois
Chicago, Dan Ryan Expressway
Several dozen barrels of chemical waste exploded in a
truck bin on the Dan Ryan Expressway, spewing barrels and flames
over cars and snarling rush-hour traffice on all four Chicago
expressways. The explosions occured at 3:15 p.m. on the elevated
portion of the Ryan Expressway. The chemical believed to be
sodium nitrate, was part of a load being carried by an industrial
garbage truck to a garage in Crestwood from a chemical company •
on West 18th Street. Barrels which were catapulted into the
air landed among the cars or dropped 50 feet to the ground
level. Two policeman were treated for eye injuries from the
1-1
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smoke. Sodium nitrate is a D.O.T. oxidizer and being such is
an EPA ignitable oxidizer.
Pennsylvania
Harrisburg. Dauphin County 1/75
An explosion occurred at the Harrisburg City incinerator
which resulted in building damage totaling approximately $95,000.
The explosion resulted from the ignition of a drum of spray
adhesives delivered by the Rolance and Rolance Supply Co.
Proper disposal of these adhesives would of prevented this
dangerous situation. Municipal incinerators like municipal
landfills are generally not equipped nor permitted to handle
ignitable hazardous waste.
Pennsylvania
Whitemarsh Township, Montgomery County
Two explosions and the contamination of residential drinking
water resulted from the development of methane gas in a landfill
in Deck Quarry, Montgomery County, Pennsylvania. The gas noved
through rock fractures. A well-pump spark ignited the gas
causing explosions. Residents have evacuated their houses
permanently and the contaminated well area has been vented by a
trench and holes dug at the landfill in late 1969. The landfill
accepted municipal and some industrial wastes until Its closure
In 1969. The migration of gases from landfills Is a problem
throughout the country. Organic solvents which volatilize at
1-2
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ambient temperatures (that is, less than 60° C) join with
refuse degradation products causing concentration build-up in
nearby structures, manholes, conduits, and in the ground itself.
A detail analysis of landfill gas from a different landfill,
one in California, showed fifty-some organic contaminates to
the methane.^
New Jersey
Toms River, Berkeley Township
1500 or more deteriorating chemical drums buried in Berkeley
Township, and considered potentially explosive by the state,
could cause the relocation of a major Ocean County Sewerage
Authority interceptor lines. The presence of the hazardous
drums known to State Department of Environmental Protection
since 1974 has resulted in hiring an engineering firm to monitor
ground water. One of the substances known to be buried at the
site is metallic sodium (825 drums from Union Carbide buried in
1960) which is a ignitable solid. A fire at the dump site in
1974 was put out with dry sand after water made the flames
worse. Metallic Sodium is an ignitable solid.
Illinois
Calumet, Cook County 9/75
A landfill operator died from severe burns when the
iompacter that he was operating struck a 55-gallon drum of ethyl
acetate (flash point 24°). The incident occured after a scavenger/
1-3
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hauler had deposited a load at the Calunet Industrial Develop-
ment Landfill in the dark hours of the morning.
Washington
Everett, Snohomish County 9/74
The N.W. Wire Rope Corp., cleaning off debris from the
site of a metal reduction plant, sent 200 cubic yards to a
landfill near Siver Lake. The debris consisted of aluminum
dust, magnesium chips, and two broken drums o-f concentrated
phosphorus. Upon dumping and compaction, the material ignited
and developed into a fire. Water could not be applied to the
waste and explosions eliminated chances to obtain samples need
for analysis. The fire started after the improper disposal of
ignitable solids.
Michigan
Forest Waste Disposal, Genesee County
While burying drums containing an unknown waste, a bulldozer
operator at the Forest Waste Disposal Landfill began experiencing
dizziness and eye irritations. As a result, he left his
bulldozer and upon returning found the nachine in flames.
Evidently, some of the drums contained ignitable solvents and
the waste hauler, Berlin and Farrow, was supposed to incinerate
their ignitable waste. The wastes were generated by the
.*
Saganough Steering Gear Co. Landfill owner is contemplating legal
*
action against the waste hauler.
1-4
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Ohio
Elda, Inc. Dump, Cincinnati
An employee of a private dump was burned over 50 percent
of his body when several containers of unknown volatile liquid
caught fire and enveloped his bulldozer. The employee was
attempting to put out a small fire when the bulldozer hit the
containers. Firemen were hampered because no hydrants were
located at the dump. The problem of unidentified ignitable
solvents being placed in municipal landfills keeps cropping up.
Danger to landfill personnel and degradation of the environment
occur from this waste.
PennsyIvania
Springfield Township, Delaware County
The Mayer landfill of Delaware County, Pennsylvania, formly
accepted various kinds of industrial wastes. At times, tank-car
quantities were dumped at the site as well as many barrels of
unidentified chemical wastes. During compaction operations in
1971, an explosion occurred which destroyed a bulldozer and
caused a fire that burned for several days. Problem disposal
sites like this exemplify the need for ignitable waste controls.
1-5
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Appendix II
Regulation of States, Organizations, Agencies
-------
Regulations of States
California18
Flammable. (a) "Flammable means:
(1) A liquid which has a flash point at or below 37.8
degrees centigrade (100 degrees farenheit) as
defined by procedures described in Title 49, Code
of Federal Regulations, Section 173.115.
(2) A gas for which a mixture of 13 percent or less,
by volume, with air forms a flammable mixture at
atmospheric pressure or the flammable range with
air at atmospheric pressure is wider than 12 percent
regardless of the lower limits. Testing methods
described in Title 49, Code of Federal Regulations,
Section 173.115, shall be used.
(3) A solid which is likely to cause fires due to
friction, retained heat from processing or which
can be ignited under normal temperature conditions
and when ignited burns so as to create a serious
threat to public health and safety. Normal temperature
conditions means temperatures normally encountered
in the handling, treatment, storage and disposal
of hazardous wastes.
(4) A gas, liquid, sludge or solid which ignites
spontaneously in dry or moist air at or below
54.3 degrees centregrade (130 degrees Fahrenheit)
or upon exposure to water.
(5) A strong oxidizer. Section 60415 "Strong Oxidizer"
means a substance that can supply oxygen to a
reaction and cause a violent reaction, or sustain
a fire when in contact with a flammable or combustible
material in the absence of air.
Minnesota1^
Flammable material: any material that:
a. has a flash point below 93.3°C (200°F), except the
following:
(1) a material comprised of miscible components
having one or more components with a flash
II-l
-------
point of 93.3°C (200°F), or higher, that make
up at least 99Z of the total volume of the
mixture;
(2) a material that has a flash point greater than
37.8°C (100°F) and that when heated to 93.3°C
(200°F) will not support combustion beyond the
flash;
(3) an explosive material; or
b. may ignite without application of flame or spark
including, but not limited to, nitro cellulose,
certain metal hydrides, alkali metals, some oily
fabrics, processed metals, and acidic anhydrides.
Flash point: The minimum temperature at which a material gives
off vapor within a test vessel in sufficient concentration to
form an ignitable mixture with air near the surface of the
material.
Oxidative material: Any material with the property to readily
supply oxygen to a reaction in the absence of air. Oxidative
materials include, but are not limited to, oxides, organic
and inorganic peroxides, permanganates, chlorates, perchlorates,
persulfates, nitric acid', organic and inorganic nitrates,
iodates periodates, bromates, perselenates, perbromates,
chromates, dichromates, ozone, and perborates* Bromine,
chlorine, fluorine, and iodine react similarly to oxygen
under some conditions and are therefore also oxidative
materials.
Flammable materials: Whenever the flash point of a waste is
to be determined, one of the following test procedures shall
be used. The test chosen shall be appropriate for the
characteristics of the waste that is tested.
(a) Standard Method of Test for Flash Point by Tag
Closed Tester (ASTM D56-70).
(b) Standard Method of Test for Flash Point of Aviation
Turbine Fuels by Setaflash Tester (ASTM D3243-73).
(c) Standard Methods of Test for Flash Point of Liquids
by Setaflash Closed Tester (ASTM D3278-73)-
(d) Standard Method of Test for Flash Point by Pensky-
Martens Closed Tester (ASTM D93-73) or alternate
tests authorized in this standard.
For any waste containing components with different
volatilities and flash ponts and having a flash point higher
than 93.3°C (200°F) according to the test procedure employed,
a second test shall be conducted on a sample of the liquid
II-2
-------
portion of the material that remains after evaporation in an
open beaker (or similar container), under ambient pressure
and temperature (20 to 20°C) conditions, to 90 percent of
original volume or for a period of four hours, whichever
occurs first, with the lower flash point of the two tests
being the flash point of the material.
Oregon^O
Flammability is defined as:
(a) material which is readily ignited under ambient
temperatures
(b) material which on amount of its physical form
or environmental conditions can form explosive
mixtures with air and which is readily dispersed
in air, such as dusts of combustible solids and
mists of flammable or combustible liquids
(c) material which burns with extreme rapidity,
usually by reason of self-contained oxygen,
materials which ignite spontaneously when exposed
to air
(d) liquids, solids or gasious material having a
flash point below 37.8°C (100°F).
Ohio3
Flash points below 175°F
Very volatile flammable liquids, very flammable liquids
and gases, and substances that, in the form of dusts or mists
readily form explosive mistures when dispersed in air.
Washington21
Flammable: substances which have a flash point at or
below 40°C (100°F), as determined by the Tagliabue open cup
.tester, or other suitable method.
II-3
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Agencies and _0r.ganizatIons
Department of Transportation^
(1) flammable liquids are those having flash points
helow 37.8°C (100°F).
(2) combustible liquids are those having flash points at
or above 37.8°C (100°F) and below 93.3°C (2008F).
(3) a flammable solid is any solid material other than
one classified as an explosive, which, under conditions
normally incidental to transportation is liable to
cause fires through friction, retained heat from
manufacturing or processing, or which can be ignited
readily and when ignited burns so vigorously and
persistently as to create a serious transportation
hazard.
Consumer Product Safety Commission^
(1) the term "extremely flammable" shall apply to
any substance which has a flash point at or below
20°F as determined by the Tabliabue Open Cup
Tester
(2) the term "flammable" shall apply to any substance
which has a flash point above 20°F, to and including
80°F, as determined by the tester mentioned above
(3) "Extremely flammable solid" means a solid substance
that ignites and burns at an ambient temperature of
80°F or less when subjected to friction, percussion,
or electrical spark
(4) "Flammable solid" means a solid substance that when
tested by the method described in Section 1500.44,
Ignites and burns with a self-sustained flame at a
rate greater than one-tenth of an inch per second
along its major axis.
Environmental Protection Agency (Title 40 (Pesticides), CFR,
Part 162)
The proposed rulemaking includes flanmability labeling
requirements. "Extremely flammable" and "flammable" categories
correspond to those found in Title 15, U.S. Code, Sec. 1261.
II-4
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(1) Extremely flammable - a flash point less than 20°F.
(2) Flammable - a flash point greater than 20°F and
less than 80°F.
(3) Combustible - a flash point greater than 80°F and
less than 150°F.
National Academy of Sciences (Ad - 782 476):
Rating Definition
0 - Insignificant hazard Not Combustible
1 - Slightly hazardous Flash point larger than
60°C (140°F)
2 - Hazardous Flash point from 37.8 to
60°C (100 to 140°F)
3 - Highly hazardous Flash point less than 37.8°C
(100°F) and boiling point
greater than 37.8°C (100°F)
4 - Extremely hazardous Flash point less than 37.8°C
(100°F) and boiling point less
than 37.8°C (100°F)
National Fire Protection Association^
Flammable liquid shall mean a liquid having a flash point
below 37.8°C (100°F) and having a vapor pressure not
exceeding 40 pounds per square inch (absolute) at
37.8°C (100°F) and shall be known as a Class I liquid.
Class I liquids shall be subdivided as follows:
Class IA shall include those having flash points below
22.8°C (73°F) and having a boiling point at or below
37.8°C (100°F). Class IB shall include those having-
flash points below 37.8°C (100°F) and having a boiling
point at or above 37.8°C (100°F). Class 1C shall include
those having flash points at or above 22.8°C (73°F) and
and below 37.°C (100°F).
Combustible liquids shall be subdivided as follows:
Class II liquids shall include those having flash points
at or above 37.8eC (100°F) and below 60°C (140°F).
II-5
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Class IIIA liquids shall include those having flash
points at or above 60°C (140°F) and below 93.3°C (200eF)>
Class IIIB liquids shall include those having flash
points at or above 93.4°C (200°F).
Booz-Allen Research, Inc., EPA, 1973 (PB 221-464):
A material is flammable if it has a flash point that is
less than 37.8°C (100°F) and a boiling point less than
37.8°C (100°F) spontaneous combustion and/or explosive
reaction.
Department of the Navy:
Hazard L_eyeJL
4
3
2
1
0
Criteria
Flash point less than 100°F and
boiling point less than 73°F.
Fp less than 100° and Bp greater
than 73°F and less than 100°F.
Fp greater than 100°F and less
than 200°F.
Fp greater than 200°F.
Material will not burn.
II-6
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Appendix III
Definitions
These definitions are the working definitions of ASTM's
Coordinating Committee on Flashpoint and Related Properties and
Interaction with Government Agencies on these Properties.
-------
NOTE: The Agency has used several of the definitions listed
below, e.g. flash point in the body of the background
document. The remainder are included as a standard for
future work.
Autoignition -the spontaneous ignition (without an external
ignition source) of a material as the result of heat
liberation from an exothermic reaction.
Burning Velocity -fundamental velocity of a combustion
wave measured normal to the flame front.
Combustible -capable of undergoing combustion.
Combustion -a rapid exothermic oxidiation process accompanied
by continuous evolution of heat and usually light.
Deflagration -combustion which propagates into the reacting
medium at a subsonic velocity.
Detonability Limits -the maximum and minimum concentrations of
a combustible in an oxidant, e.g., air, which will propagate
a detonation when initiated at specified temperature and
pressure.
Detonation -combustion or other reaction which propagates into
the reacting medium at a supersonic velocity.
Fire -the phenomenon of Combustion.
Fire Point -the minimun temperature to which a material
must be heated,in an open vessel to sustain combustion for
a specified period of time after ignition by an external
source.
Flame -a zone of gas or particulate matter or both in
gaseous suspension that is undergoing combustion, as
evidence by the evolution of both heat and usually light.
Flame Temperature -the temperature of the product species in
flaming combustion.
Flame Speed -velocity of a combustion wave measured relative to
a stationary observer.
Flash Point -the lowest temperature, corrected to a pressure
of 101.3 kPa (1013 millibars), of a substance at which
application of an ignition source causes the vapors above
the substance to ignite under the specified conditions of
test.
Ignite -to initiate combustion.
III-l
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Lower Flammable Limit -the lowest concentration of a combustible
substance that is capable of propagating a flame through a
homogenous mixture of combustible substance and a gaseous
oxidizer under specified conditions of test.
Lower Temperature Limits -the lowest temperature at which a
combustible substance will produce a vapor concentration
equal to the lower flammable limit under specified conditions
of test.
Minimum Oxygen Concentration -the minimum concentration of
oxygen required to sustain burning or flame propagation.
Temperature -the thermal state of matter as measured on a
defined scale.
Upper Flammable Limit -the maximum concentration of a combustible
substance that is capable of propagating a flame through a
homogenous mixture of combustible substance and a gaseous
oxidizer under specified conditions of test.
Liquid - (flammability regulations) -a substance that has a
definite volume but no definite form except such given by
its container. It has a viscosity of 1 x 10~3 stokes
(1 x ID'7 to 1 x 1CT1 m2 s'1) at 104° F (140° C) or an
equivalent viscosity at agreed upon temperature.
(This does not include powders and granular materials).
Liquids are divided into two classes:
CLASS A (low viscosity) a liguid having a viscosity of
1 x 10~3 to 25.00 stokes (1 x 10"7 to 25.00 x 10~4 a_ s"1) at
104° F (40° C) or an equivalent viscosity at an agree upon
temperature•
CLASS B (high viscosity) a liquid having a viscosity of
25.01 - 1 x 103 stokes (25.01 x 10~4 to 1 x 10 -1 m2 s"1) at
104° F (40° C) or an equivalent viscosity at an agreed upon
temperature.
note: The above definition of liquid does not apply to
the meaning intended in this document but rather a
general definition of ASTM.
III-2
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Appendix IV
Test Methods for Ignitable Waste
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Table of Contents
IV-1, 2 Tests to Determine
Ignitable Gases
(49 CFR 173,300)
IV-3 Test to Determine
Ignitable Liquids
(Pensky-Martens.
Closed-Cup ASTM)
IV-4 '• T.est to Determine
Ignitable Liquids
(Seta-flash Closed
Cup ASTM D3278-73)
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IV-1,2 Aerosol Flame Projection Tests
-------
OCIATtON OF.
'LSI
'IONS AND MAINTENANCE DEPARTMENT • BUREAU OF EXPLOSIVES
RAILROADS BUILDING - WASHINGTON, D.C 20035 • 202/2934048
ft. Ft. MAN/ON
Vice-President
ft. M. GRAZIANO
Director
AEROSOL FLAME PROJECTION TESTS
Section 173. 300(b) subparagraphs (2), (3), and (4) of Title 49 to
the Code of Federal Regulations referenced The Bureau of Explosives'
Flame Projection Apparatus, Open Drum Apparatus and Closed Drum
Apparatus to be used when examining aerosol products.
The following are descriptions of the equipment and testing pro-
cedures to be used when conducting the tests. Any further questions
relating to this testing should be addressed to the Director at the above
address.
FLAME PROJECTION TEST
EQUIPMENT - The test equipment consists of a base
four inches wide and two feet long. A thirty inch rule (with inches marked)
is supported horizontally-on the side of the base and about six inches above
it. A plumber's candle of such height that the top third of the flame is at
• the height of the horizontal rule is placed at the zero point in the base.
PROCEDURE - The test is conducted in a draft-free area
that can be ventilated and the atmosphere cleared between each test. The
self-pressurized container is placed at a distance of six inches from the
ignition source and the spray jetted into the top third of the flame with valve
opened fully for periods of 15 - 20 seconds. The length of the flame pro-
jection from the candle position is read on the horizontal-scale. Three or
more readings are taken on each sample and the average is taken as the
result. Samples are also tested with valve in partially open positions to
test for "burning back" to valve.
DRUM TESTS
EQUIPMENT- The equipment consists of a 55 - gallon open-
head steel drum or similar container which is placed on its side and fitted
with a hinged cover over the open end that will open at a pressure of 5 p. s. i.
\-\
-------
The closed or solid end is equipped with one shuttered opening at the top. ^
This is for the introduction of the spray. The opening is approximately
two inches from the edge of drum head and is two inches in diameter.
There is a safety glass or plastic window six inches square in the center
of the solid end. A lighted plumber's candle is placed inside the drum on
the lower side and midway between the ends.
PROCEDURE - The tests are conducted in the open and
when temperature is between 60CF and 80°F.
OPEN DRUM TEST
This test is conducted with hinged end in a completely
open position and with the shutter closed. The spray from the dispenser,
with valve opened fully, is directed into the upper half of the open end
and above the ignition source for one minute. Any significant propaga-
tion of flame through the vapor-air mixture away from the ignition source
shall be considered a positive result -- but — any minor and unsustained
burning in the immediate area of the ignition source shall not be considered
a positive result.
CLOSED DRUM TEST
This test is conducted with the hinged cover dropped into
position to rest freely against the end and to close the open end of the
drum to make a reasonably secure but not necessarily a completely air-
tight seal. The shutter is opened and the spray is jetted into the drum
through this shutter with valve fully opened for one minute. After clear-
ing the atomsphere in the drum, the jetting is repeated similarly three
times. Any explosion or rapid burning of the vapor-air mixture
sufficient to cause the hinged cover to move is considered a positive
result.
ADril, 1974
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ASTM D93-72
Pensky-Martens Closed Cup Tester
-------
ITv
> I fj Designation: D 93 - 72
lpDesi9n»tion:34/71
AiMricwt N«ion*l Sundwd Z11.7 - 1972
Aarond M»y 18. 1972
by Anwf ican Niton* Sundard* Inmtul*
Mtthod 1102— FMMM! T.«
Mithed Slinriwd No 7916
F«*wM«n of Secictwi (or
ftmt Tcchnologr Swndwd No. Dl-5-68
Bmnh Stwidwd 2839
AMERICAN SOCIETY FOR TESTING AND MATERIALS
IfU R*c« St., PttiUoVtlpfcU. P«M 171U
Rcpriftiwtf from ch» AanuU Book of ASTM SuMUrtl. Coprri«ht ASTM
Standard Method of Test for
FLASH POINT BY PENSKY-MARTENS CLOSED
TESTER1
ADOPTED (as method GO-7). 1924; LAST REVISED. 1971
This Standard of the American Society Tor Testing and Materials is issued under the fixed designation D 93: ibe number
immediately following the designation indicates the year of original adoption or, in the «•*«* of revision, the year of last
revision. A number in parentheses indicates the year of bst reapproval. This is ilso a standard of the Institute of Pe-
troleum issued under the fixed designation IP 3*. The final number indicates the year of last revision.
This method was adopted at a joint .ASTH-IF Standard in 1967.
1. Scope
I.I This method covers the determination
of the flash point by Pensky-Martens Closed
Cup Tester of fuel oils, lube oils, suspensions
of solids, liquids that tend to form a surface
film under test conditions, and other liquids.
For the determination of the flash point of
drying oils and solvent-type waxes refer to
Note 1.
NOTE 1—The flash point of drying oils may be
determined using Method D 1393 and the-flash
point of solvent-type liquid waxes may be deter-
mined using Method D 1437.
NOTE 2—This method may be employed for
the detection of contamination of lubricating oils
by minor amounts of volatile materials.
2. Applicable Documents
2.1 ASTM Standards:
D 56 Test for Flash Point by Tag Closed
Tester*
D 1310 Test for Flash Point of Liquids
by Tag Open-Cup Apparatus1
D 1393 Test for Flash Point of Drying
Oik*
D 1437 Test for Flash Point of Solvent-
Type Liquid Waxes*
E 1 Specification for ASTM Thermom-
eters1
3. Summary of Method
3.1 The sample is heated at a stow, con-
stant rale with continual stirring. A small
fiame is directed into the •.-••p at r';'»Iar in-
tervals with simultaneous ur.erruption of stir-
ring. The flash- point is the lowest tempera-
ture at which application of the test flame
causes the vapor above the sample to ignite.
4. Apparatus
4.1 Pensky-Mariens Cloud Flash Tester,
as described in Appendix Al.
NOTE 3—There are automatic flash point testers
available and in use which may be advantageous
in the saving of testing time, permit the use or
smaller samples, and have other factors which may
merit their use. If automatic testers are used, the
user must be sure that all of the manufacturer's in-
structions for calibrating, adjuring, and operating
the instrument arc followed, in any cases of dispute,
the flash point as determined manually shall be
considered the .referee test. —
4.2 Thermometers—Two standard ther-
mometers shall be used with the ASTM
Pensky-Martens tester, as follows:
4.2.1 For tests in which the indicated read-
ing fails within the limits 20 to 200 F (-7 to
-t-93 C), inclusive, an ASTM Pensky-Mar-
tens Low Range or Tag Closed Tester Ther-
mometer having a range from 20 to 230 F
(—5 to +110 C) and conforming to the re-
quirements for Thermometers 9F (9C) and
as prescribed in ASTM Specification E I or
IP Thermometer 15F (I5C) conforming to
specifications given in Appendix A3, shall be
used.
3.2.2 For tests in which the indicated read-
ing falls within the limits 230 to 700 F (110
to 371 C), in ASTM Pensky-Martens High
1 This method is under the jurisdiction of ASTM Com-
mittee D-2 on Petroleum Products and Lubricants.
Current edition approved Aug. 29. 1972. PuUished
October 1972. Originally published « D 93 - 21 1921. La«
p-evious edition D 93 - 66.
In the IP. this ir.rthcd is under ihr jurisdiction of fix
St:^.iJ*di73iton Com;mUcc.
In 1971 the scope was revised.
'Annual Boot of ASTM Standards. Tan 20.
•Annual Book of ASTM Siaidardi. Pan II.
•Annual Book of ASTM SienJaidi. Part 22.
•Annual Bool of ASTM Standard}, Pans 18 and 30
33
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"IV-4 D3278-73
SETAflash Closed Cc? Tester
-------
Appsndix C
Ill-
Designation: D 3278 - 73
AMERICAN SOCIETY FOR TESTING AND MATERIALS
1916 Race St., Philadelphia. PX, 19103
Reprinted from the Annual BooSc of ASTM StandxtJi. Copyright ASTM
Standard Methods of Test for
FLASH POINT OF LIQUIDS BY SETAFLASH CLOSED
TESTER1
This Standard a issued under the fixed designation D 3278; the number immediately following the designation indicates the
year of original adoption or. in the case of revision, the year of last revision-. A nu=nbtr in parentheses indicates the year of :asl
reapproval.
1. Scope
_ •
1.1 This method covers the determination of
the flash point, by Sctaflash® Closed Tester, of
paints, enamels, lacquers, varnishes,' and re-
lated products and their components having
fiash points, between 32 and 230°F (0 to 1 IO°C)
having a viscosity lower than 150 stokes at
77 °F (25 °CV
Nort 1—Tests at higher or lower temperatures
arc possible.
1.2 The procedure may be used to determine
whether a material will or will not flash at a
specified temperature or to determine the finite
temperature at which a material will Hash.
1.3 The results from this method are compa-
rable to those obtained by the Tag Closed
Tester procedure described in M±:hod D563
and the Pensky-Martens Tester method de-
scribed in Method D 93.
2. Applicable Documents
2.1 ASTM Standards:
D 56 Test for .Flash Point by Tag Closed
Tester*
D 93 Test for Flash Point by Pensky-Mart-
ens Closed Tester2
D850 Test for Distillation of Industrial
Aromatic Hydrocarbons and Related
Materials*
D 1015 Test for Freezing Points of High-
Purity Hydrocarbons3
D 1078 Test for Distillation Range of Vola-
tile Organic Liquids*
3. Summary of Method
3.1 By means of a syringe. 2 ml of sample is
introduced through a leakproof entry port into
the lightly closed Setaflash Tester or directly
into the cut that has been brought to within 5°F
(3°C) below the expected flash point. As a-
flash/no flash .test, the expected flash point
temperature may be a specification or other
operating requirements. The temperature of the
apparatus is raised to the precise temperature
of the expected flash point by slight adjustment
of the.temperature dial. After I min, a test
flame is applied inside the cup and note is taken
as to whether the test sample flashes or not. If a
repeat test is necessary, a fresh sample should
be used.
3.2 For c finite flash measurement, the tem-
perature is sequentially increased through the
anticipated range, the test flame being applied
at 9°F (5°C) intervals until a flash is ovscrved.
A repeat determination is then made using a
fresh sanp-e, starting the test at the tempera-
ture of the last interval before the flash point of. .
the material and making tests at increasing 1°F
(0.5°C) intervals.
4. Apparatus
4.1 Setaflash Tester*, shown in Fig. XI, and
described in Appendix XI.
4.2 Ttierrnomelers* conforming to specifica-
•Thcss methods are under the jurisdiction .of ASTM
Commutes D-I on Paint. Varnish. Lacquer, and Related
Products.
Currer.; ediiior. approved Oct. 29. 1973. Published De-
cember 1C7J.
' !97
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