How does a generator determine whether a waste contains a liquid for the purposes of testing for the ignitability and corrosivity characteristics?
The definitive procedure for determining whether a waste contains a liquid for the purposes of the ignitability and corrosivity characteristics is Method 1311, the pressure filtration technique. Method 9095B, the paint filter liquids test, may be utilized to demonstrate the “positive,” that is that a liquid exists for the purpose of testing for the corrosivity and ignitability characteristics; however, it is not adequate to demonstrate the “negative,” that is that a waste does not contain a liquid for the purpose of characteristic testing. This means that, if a generator obtains a free liquid phase using Method 9095B, then that liquid may be used for the purposes of determining ignitability and corrosivity. However; wastes that do not yield a free liquid phase using Method 9095B must be assessed for the presence of an ignitable or corrosive liquid using the pressure filtration technique specified in Method 1311 (60 FR 3089, 3092; January 13, 1995).
Methods 1311 and 9095B are available in SW-846 Online, which is available at the following URL: http://www.epa.gov/hw-sw846/sw-846-compendium.
Additional guidance regarding the use of Methods 1311 and 9095B for determining the presence of a liquid phase in a waste is available in the following documents:
Memo, Lowrance to Hiley; April 19, 1993 (RCRA Online #13601) http://yosemite.epa.gov/osw/rcra.nsf/0c994248c239947e85256d090071175f/BA9B81B092E63A56852568E30046803D/$file/13601.pdf
Memo, Lowrance to Wyatt; February 16, 1990 (RCRA Online #13352) http://yosemite.epa.gov/osw/rcra.nsf/0c994248c239947e85256d090071175f/580DB670E1DCE63B8525670F006C0241/$file/13352.pdf