It all started with a telephone conversation on 09.25.20 but spread into email correspondence (which I prefer). From the telephone conversation:
- Person had a waste Butanol Solution recovered from a spill.
- SDS indicated the following:
- 70-80% nonionic surfactant.
- 5-10% n-Butyl alcohol (CAS 71-36-3).
- Flash point of 130 degrees Fahrenheit.
email correspondence began that same day:
I did receive the SDS on the butyl alcohol and it turns out it is a Butanol Solution with a flash point of 130 F. The chemical composition is 70-80% Nonionic Surfactant and 5-10% Butyl Alcohol (the kind that is on the U-list). Do you think this still meets the criteria for a U-listed waste for at this point? I realize it would receive a D001 and WA State Toxic WT02 for the liquid solution itself.
Thank you!
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My reply late on a Friday night (it’s what I do):
Please see below.
- To be a P- or U-listed Haz Waste it must be pure or technical grade or the sole active ingredient in the solution. It does not seem to me that the U-listed material is the sole active ingredient in the solution so it would not be a U-listed Haz Waste.
- The product would be a D001 but it is not certain that the recovered spilled material would still be below the fp. But it probably is.
- I am not certain about the WT02 and its applicability. I would have to do more research.
Inquisitor’s reply even later that Friday night:
Thank you for responding back and on a Friday evening! I was thinking the same in that it would not fall under a U-listed waste since it was an ingredient in a solution at 10% maximum. Also appreciate the feedback on flash point for the recovered material. I did not consider that it may be above benchmarks so I think I will suggest testing to check.
I’ve got the state regs covered so no worries on that 😊.
Again thank you for your help. I will do a review with high marks. Be well and enjoy your weekend!
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Conclusion:
Determination of a P- or U-listed hazardous waste is a challenge due to all of the complex requirements of this listed hazardous waste. However, just because it is difficult to determine doesn’t mean you are not a generator of a P- or U-listed hazardous waste. Generators need to take extra care in situations like this one where spilled material is recovered. If you ever have questions about the hazardous waste determination, don’t hesitate to contact me.