American Chemistry Council
EPARulemakingEPA-HQ-OLEM-2018-0830

Modernizing Ignitable Liquids Determinations

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Last modified
Jun 12, 2024
Comment window
closed 2612d ago
American Chemistry Council filings
1

Activity

American Chemistry Council filed 1 comment on this docket between Jun 5, 2019 and Jun 5, 2019. 3 other organizations filed here. The comment window closed 2612d ago.

What American Chemistry Council filed (1)

Jun 5, 2019· Comment submitted by Richard Starr, Regulatory & Technical Affairs, American Chemistry Council (ACC)· EPA-HQ-OLEM-2018-0830-0173

Filed on regulations.gov — full text not in the inline record.

Abstract

Certain reference testing methodologies and test methods from SW-846 are incorporated by reference into the regulations that implement Subtitle C of RCRA. EPA updates the content of SW-846 over time as new information and data are developed or supporting changes are needed due to the advances in analytical instrumentation and or techniques for testing and monitoring compliance. This proposal consists of five actions. First, EPA proposes to update the flash point test methods from 1978, 1979, and 1980 (required for determining if a liquid waste is an ignitable hazardous waste) to include current ASTM International (ASTM) standards. Second, EPA is proposing to codify existing guidance regarding the regulatory exclusion in the ignitable characteristic for aqueous liquids containing alcohols and is requesting comment on whether additional changes may be warranted. Third, EPA is proposing to codify existing sampling guidance for ignitable waste mixtures having multiple phases. Fourth, EPA is proposing to update cross references to Department of Transportation (U.S. DOT) regulations and to remove obsolete information in the ignitability regulation. Finally, EPA is proposing to provide alternatives to the use of mercury thermometers in the air sampling and stack emissions methods 0010, 0011, 0020, 0023A, and 0051 in SW-846. Adding the option of using non-mercury thermometers in place of mercury thermometers would provide the regulated community with increased flexibility in their implementation of these required test methods. The use of alternatives to mercury thermometers is consistent with previous Agency actions and helps achieve the Agency’s goal of minimizing the use of mercury.

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