ROMIC Environmental Technologies Corp. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh Street, S.W. Research and special Programs Administration FEB 26 1998 Mr. Kurt Swart 1 Health & Safety Manager ROMIC Environmental Technologies Corp. ! 2081 Bay Road East Palo Alto, CA 94303-1316 Dear Mr. Swart: This is in response to your letter dated December 22, 1997, regarding reportable quantities for Resource Conservation and Recovery Act (RCRA) wastes under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether the RQ for the EPA waste number supersedes the RQ for the individual constituent. The appropriate RQ for a hazardous waste depends on the amount of information available on the waste stream including the constituents of the waste stream and their respective concentrations. If the constituent and its concentration in the waste stream are known, then the RQ for the constituent is appropriate. For example, Pyridine has an RQ of 1000 Ibs (454 kg). If Pyridine is the only constituent and its concentration in a mixture or solution is known, then the RQ for Pyridine is appropriate. However, if the waste's constituent or its respective concentration is unknown, then the appropriate RQ is that which is assigned to the waste stream. For example, the reportable quantity for a waste stream described under F005, and which contains Toluene in an unknown concentration, is 100 Ibs (45.4 kg). I hope this answers your inquiry. If we can be of further assistance, please do not hesitate to contact us. Sincerely, Debathings Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#

Page 2© ROMIC ENVIRONMENTAL TECHNOLOGIES CORP FAX - 202-366-8700 / Phone - 800-467-4922 December 22, 1997 Ed Mazzullo (DMH-10) Director of Office of Hazardous Materials Standards 400 7th Street SW U.S. Department of Transportation / RSPA Washington, D.C. 20590-0001 RE: Applicability of Reportable Quantities Dear Mr. Mazzullo, On November 4, 1997, Romic Environmental FAXed the enclosed letter regarding thie applicability of DOT reportable quantities. We are anxiously awaiting DOT's response. However, the RQ questions posed in our November 4th letter used the hazardous waste constituent Xylene in the examples. The RQ for Xylene is now 100 pounds; thus, Xylene is no longer a valid constituent for the examples. Romic requests that when responding to the RQ questions to now consider Pyridine as follows: A generator is planning to ship the following RCRA Hazardous Waste mixtures that have concentrations specified by the definition of "Hazardous Substance" found in 49 CFR been classified with the following EPA waste numbers. Regardless of the container size and 171.8, which RO's must be considered? In other words, does the RQ for the EPA waste number supersede the RQ for the individual constituent? CONSTITUENT EPA WASTE NUMBER RQ Pyridine D001 Pyridine F0O5 100 Pounds Pyridine The Constituent Itself 100 Pounds Pyridine None 1,000 Pounds None Please note in the next example that Isopropanol does not have an RQ when it is a Which RQ applies? Hazardous Material, but does have an RQ of 100 pounds when it is a Hazardous Waste. CONSTITUENT EPA WASTE NUMBER Pyridine Pyridine D001 100 Pounds F005 Pyridine 100 Pounds Isopropanol The Constituent Itself D001 1,000 Pounds Isopropanol The Constituent Itself 100 Pounds None If you have any questions, please contact me at 415-462-2390. Sincerely, Kurt Swart Environmental, Health & Safety Manager Recycling. Lab Packing, Field Services, Consultings 2081 Bay Road • East Palo Alto, CA 94303-1316 • Tel: (415) 324-1638 * Printed on recycled paper#

Page 3• ROMIC TECHINOLOGIES CORP. ENVIKONMENTAL follow up polydere s FAX - 202 366-8700 / Phone - 800-467-4922 December 22, 1997 Ed Mazzullo (DMH-101 Director of Office of Hazardous Materials Standards U.S. Department of Transportation / RSPA 400 7th Street SW Washington, D.C. 20590-0001 RE: Applicability of Reportable Quantities Dear Mr. Mazzullo, On November 4, 1997, Romic Environmental FAXed the enclosed letter regarding the applicability of DOT reportable quantities. We are anxiously awaiting DOT's response. However, the RO questions posed in our November 4th letter used the hazardous waste constituent Xylene in the examples. The RQ for Xylene is now 100 pounds: thus, Xylene is no longer a valid constituent for the examples. Romic requests that when responding to the RQ questions to now consider Pyridine as follows: A generator is planning lo ship the following RCRA Hazardous Waste mixtures that have oncentrations snecified bv the definition of 171,8, which RQ's must be considered? In other words, does the RQ for the EPA waste number supersede the RO. for the individual constituent? CONSTITUENT EPA WASTE NUMBER Pyridine D001 Pyridine FOOS 100 Pounds 100 Pounds Pyridine The Constituent Itself 1,000 Pounds Pyridine None None Please note in the next example that Isopropanol does not have an RO when it is a Hazardous Material, but does have an RQ of 100 pounds when it is a Hazardous Waste. Which RO applies? CONSTITUENT EPA WASTE NUMBER Pyridine D001 100 Pounds Pyridine F005 100 Pounds Pyridine The Constituent Itself 1,000 Pounds Isopropanol DOOT 100 Pounds Isopropanol The Constituent Itself None If you have any questions, please contact me at 415-462-2390. Sincorely, : Kurt Swart Environmental, Health & Safety Manager tRavele Tab packing Field Servis: Consting 3.0 .... 2i181 Ray Road • Must Pale Allo, (A 04303-1310 • Tel: (4151,124-1638 * lined en receshal gaper#

Page 4O KUMIL TECHNOLOGIES CORP. ENVIRONMENTAL FAX - 202-366-8700 / Phone - 800-467-4922 November 4, 1997 Ed Mazzullo (DMH-10) Director of Office of Hazardous Materials Standards 400 7th Street SW U.S. Department of Transportation / RSPA Washington, D.C. 20590-0001 RE: Applicability of Reportable Quantities Dear Mr. Mazzullo, Romic Environmental has an enforcement question regarding DOT reportable quantities. We writing to you. contacted the DOT Hotline at 800-467-4922 and they suggested that we put our questions in A generator is planning to ship the following RCRA Hazardous Waste mixtures that have been classified with the following EPA waste numbers. Regardless of the container size and concentrations specified by the definition of "Hazardous Substance" found in 49 CFR 171.8, which RO's must be considered? In other words, does the RQ for the EPA waste number supersede the RQ for the individual constituent? CONSTITUENT EPA WASTE NUMBER Xylene D001 100 Pounds Xylene F003 100 Pounds Xylene The Constituent Itself 1,000 Pounds Water None None Please note in the next example that Isopropanol dees not have an RO when it is a Hazardous Material, but does have an RO of 100 pounds when it is a Hazardous Waste. CONSTITUENT EPA WASTE NUMBER Xylene D001 100 Pounds Xylene F003 100 Pounds Xylene The Constituent Itself 1.000 Pounds Isopropano! D001 Isopropanol The Constituent Itself 100 Pounds None Water None None If you have any questions, please contact me at 415-462-2390. • Sincerely. • Kutswart Kurt Swart Health & Safety Manager Environmental, TE Recyling. Loo Packing, Feld Service Consults on 2081 Bay Road • Eas Palo Allo. CA 94303-1336 - Tel: (315) 324-1638 & Fired on recycled paper •#