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may originate in the fiber/matrix, core or coating layer.
The inorganic constituents may be found in the coatings
or the hybrid layer.
(a) Results. There are several reasons why a non-detect
might be expected. Reason one is the regulatory limits
are too high. Reason two is the list doesn’t reflect the
type of material that is being testing.
1 Regulatory limits. The regulatory limits for the F and
D listed organic compounds are ppm levels. The lack of
analytical sensitivity when reporting ppm levels may have
eliminated trace or low-level compounds.
1 Paragraph 3.7a, Basics of Composites
2 Char
3 TCLP = toxicity characteristic leaching procedure
4 Composite sampling = Sample is a nondiscrete sample composed
of more than one specific sample collected at various location on site
or within a bulk piece.
TO 00-105E-9
3-28
2 Regulatory lists. The lists are generated for chemicals
used in industrial processes. That is the raw products
used to make the composite. Once the composite
material is formed to a specific shape (becomes a solid),
the raw products in their original form no longer exist (or
exists only in undetectable amounts). The lists may not
reflect the chemistry of the solid material or it’s combustion
or decomposition products.
(5) WASTE CATAGORIES1 . Of the six different ways
a mishap-composite could be defined as a hazardous
waste, the most likely would be the “characteristic” waste
or the contaminated media. Discussion for each follows.
Listed waste (F, K, P, U)
“Characteristic” waste (D)
Mixture of solid and listed waste
Contaminated debris
Derived from hazardous waste
Contaminated media
(a) “Characteristic” waste. Characteristics of waste
that are separate from listed wastes are ignitibility,
corrosivity, reactivity, and toxicity. Elimination of a characteristic
is based on the chemical a physical condition
of the material, the reasoning follows.
Ignitability Corrosivity Reactivity Toxicity
1 Ignitibility. A waste is an ignitable waste if it meets
any of the following.
Liquid - Flash Point <140°F
Not applicable to mishap-composites
Solid - Spontaneous combustion through friction.
May be applicable to mishap-composites if saturated with
fuel
Solid - Spontaneous combustion through
absorption or loss of moisture.
1 40CFR 261
Not applicable to mishap-composites.
Compressed gas or oxidizer defined by DOT
Not applicable to mishap-composite
2 Corrosivity. A waste is corrosive if it meets the
following conditions:
pH < 2 or > 12.5
Not applicable to mishap-composites unless site contamination
occurred (spilt battery acid or hazardous cargo).
NOTE
Burning resins can produce an acidic plume. The resin
char and fuel soot can be slightly acidic. Plume exposure
or a surface layer of resin char is not expected to
cause a 5-gram composite sample to have corrosive pH
conditions as defined.
3 Reactivity. A waste is reactive if it meets any of the
following conditions:
Readily undergo chemical change
React violently or forms explosive mixture when
mixed with water
Capable of detonation or explosion when exposed
to pressure and heat
Capable of detonation or explosion at standard
temperature and pressure
Defined as a forbidden explosive or Class A or
Class B explosive by DOT
Not applicable to mishap-composites
Toxic gas generation. Cyanide and sulfide bearing
waste when exposed to mild acidic or basic conditions
generates toxic gases.
250mg of free cyanide per kilogram of waste
500mg of free sulfide is generated per kilogram of waste
Hydrogen cyanide and sulfide are possible combustion
products for various resin types. Liberation occurs at very
high flame temperatures. When liberated, the compounds
could condense out on nearby surfaces, react with other
chemical species in the thermal column or rise with the
plume. Probability of detection on a mishap-composite
at the levels of concern is considered low.
4 Toxicity. A land-disposed waste is considered toxic
if it contains a toxic constituent. The constituent categories
are metals, volatile and semi-volatile organics, pesticide,
and herbicide.
TO 00-105E-9
3-29
Metals:
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Several of the metals could be present in reportable concentrations.
Volatile Organics:
Benzene
Carbon tetrachloride
Chlorobenzene
Chloroform
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