Monsanto Company — Hazardous Materials Safety Interpretation

Page 1f Transportatio S. Departmer Washington, D.C. Special Programs Research and Administration MAR 1 0 2000 Mr. William J. Briner lonsanto Company regulatory Affairs Manage Ref. No. 00-0025 800 North Lindbergh Blvd. St. Louis, MO 63167 Dear Mr. Briner: This is in response to your letter dated January 13, 2000, Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). regarding the definition of a hazardous substance under the Specifically, you ask whether a package containing 400 pounds of a D001 waste, the composition of which is known to be 100% mineral spirits, would exceed its reportable quantity (RQ) as stipulated under Appendix A to § 172.101. The appropriate Rl for a hazardous waste depends on the amount of information available on the waste stream including the constituents of concentrations. the waste stream and their respective If the constituent and its exact the constituent is appropriate. concentration in the waste stream are known, then the RQ for RQ of 1000 pounds (454 kg). If Toluene is the only For example, Toluene has an constituent and its concentration in a mixture or solution is known, then the RQ for Toluene is appropriate. However, if the waste's constituent or its respective concentration is the waste stream. unknown, then the appropriate RO is that which is assigned to and their exact concentration in the mineral spirits, Therefore, you must know the constituents ee mineral otherwise the material is subject to the RO for a (100 pounds (454 kg)). . D001 waste I hope this satisfies your request. Sincerely, Transportation Regulations Specialist Office of Hazardous Materials Standards 000025 1118#

Page 2BAt MONSANTO Food - Health • Hope S1718H Hazardous Substan ST. LOUIS, MISSOURI 63167 0o NORTH LINDBERGH BOULEVAR January 13, 2000 00 - 0025 U.S. Department of Transportation Ottice of Hazardous Materials Standards (DHM-10) Research and Special Programs Administration Washington, 400 Seventh Street, S.w. Attn: Mr. Thomas Allan 20590-0001 Dear Mr. Allan: I am writing to request a written interpretation concerning 49 Substances and Reportable Quantities. CFR 172.203 (C) and Appendix A to 172.101 - List of Hazardous A 55-gallon drum contains a net weight of 400 lbs. of an EPA RCRA 100% mineral spirits, a D001 characteristic hazardous waste. Ine composition of the waste is known to be Mineral spirits is not specifically listed as a hazardous substance in Appendix A to 172.101 - List of Hazardous Substances and Reportable, Table 1 - Hazardous Substances Other Than Radionuclides. Question: Does this drum contain a reportable quantity of the hazardous substance D001? Thank you in advance for providing this interpretation. If you have any questions, please call me at (314) 694-2999. Sincerely, Wiliam If Briner William J. Briner Regulatory Affairs Manager -#