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Interpretation Response #98-0415 ([ROMIC Environmental Technologies Corp.] [Mr. Kurt Swart])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: ROMIC Environmental Technologies Corp.

Individual Name: Mr. Kurt Swart

Location State: CA Country: US

View the Interpretation Document

Response text:

FEB 26, 1998


Mr. Kurt Swart
Health & Safety Manager
ROMIC Environmental Technologies Corp.
2081 Bay Road
East Palo Alto, CA 94303-1316

Dear Mr. Swart:

This is in response to your letter dated December 22, 1997, regarding reportable quantities for Resource Conservation and Recovery Act (ReRA) wastes under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether the RQ for the EPA waste number supersedes the RQ for the individual constituent.

The appropriate RQ for a hazardous waste depends on the amount of information available on the waste stream including the constituents of the waste stream and their respective concentrations. If the constituent and its concentration in the waste stream are known, then the RQ for the constituent is appropriate. For example, Pyridine has an RQ of 1000 lbs (454 kg). If Pyridine is the only constituent and its concentration in a mixture or solution is known, then the RQ for Pyridine is appropriate. However, if the waste's constituent or its respective concentration is unknown, then the appropriate RQ is that which is assigned to the waste stream. For example, the reportable quantity for a waste stream described under F005, and which contains Toluene in an unknown concentration, is 100 lbs (45.4 kg).

I hope this answers your inquiry. If we can be of further assistance, please do not hesitate to contact us.



Delmer F. Billings
Chief Standards Development
Office of Hazardous Materials Standards

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.101 Purpose and use of hazardous materials table