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printech, March, 2001
Re: Representative sampling of waste stream


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From:Gary Jones (gjonesprinting@aol.com )
Date:Sun, 4 Mar 2001 14:38:00 EST


Your email does not mention the specific waste stream or streams or circumstances surrounding their generation and disposal. Without these details, it is difficult to provide a specific answer. However, some general information may be helpful. In determining the regulatory classification of a waste in terms of hazardous or not, it is the clearly the generators responsibility and no one else. The generator is allowed to use a variety of approaches ranging from "applying knowledge" through testing for every characteristic under the four characteristics of hazardous waste. With that bit of background, using a waste hauler/disposal companies profile of a waste to classify any given waste stream would be acceptable as long as the profile reflects the specific waste in question and it covers all of the characteristics. In many of the profiles for lithographic ink waste that I have seen, they only check for pH, water content, flashpoint, and Btu value as this is what is most important for disposal facility because they are going to burn the waste. The profiles generally do cover heavy metals on the TCLP list and this test should also be conducted as it is difficult to "apply knowledge" for metal content of ink wastes. It is also important to check the flashpoint determination method as EPA will only accept TCC closed cup. The results of the profile should be compared to the MSDSs to see if they are representative. While EPA does allow for some flexibility in determining the status of waste, it is always best to have an independent set of data using the EPA approved methods to be absolutely certain. The question about one drum in 16 flashing is also a general question. When you say flash, do you mean the waste in the drum exhibits a flashpoint below 140oF? What is the nature of the waste in the drum and how does it compare to the other 15 drums? Are they all the same or different wastes? There are a multitude of reasons why this could occur ranging from the breakdown of chemicals over time to the fact that some plant personnel may have put the wrong waste into the wrong drum. Without a plausible explanation, I would suspect all drums and have each one sampled and tested. It is better to be safe than sorry. In terms of the historical knowledge question, additional detail is needed. How long ago was the waste stream profiled 1, 5 10 years? Has the generator or their supplier changed any input materials that make up this waste stream? If the waste stream originally profiled is still representative of the waste stream of today and that profile is complete and accurate, then it could be used. Again, it is ultimately the generators responsibility for the correct classification of any waste stream. They need to use the most accurate and correct data available. For more information, see the PNEAC fact sheet at http://www.pneac.org/sheets/all/whatisahazwaste.cfm. Please let me know if you have any additional questions. Gary Jones



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