
FAXBACK 136019445.1993(04)USE OF PAINT FILTER LIQUIDS TEST TO DETERMINE FREE LIQUIDS IN A WASTEUnited States Environmental Protection AgencyApril 19, 1993Mr. Raymond D. HileyGoodwin, Procter & HoarCounsellors at LawExchange PlaceBoston, Massachusetts 02109-2881Dear Mr. Hiley:Thank you for your letter of March 24, 1993 concerning thedetermination of the corrosivity characteristic. The Paint FilterLiquids Test (Method 9095 in SW-846) was developed to determinefree liquids in a waste. It was never intended for use indetermining if a waste contains any bound or absorbed liquid or ifsuch liquid is aqueous. The Office of Solid Waste is looking at the issue of whatconstitutes a liquid for characteristic testing. We will shortly beproposing revisions to the Third Edition of "Test Methods forEvaluating Solid Waste" (SW-846) in the Federal Register. In thisproposal, we hope to clarify the meaning of liquid forcharacteristic testing. After this rule is proposed in the FederalRegister, we would happy to sent you a copy of the notice. The guidance on the use of Method 9095 provided in theFebruary 16, 1990 letter to Mr. Robert D. Wyatt would still be ourbest advice to you until rules have been promulgated defining themeaning of "liquid" and "aqueous" for characteristic testing. As you have correctly stated, under the present regulations anaqueous phase must be present in the sample in order to determinethe corrosivity characteristic by pH measurement. This is becauseit is technically impossible to determine pH in liquids where wateris not present. I hope that this information will be of use to your analyticalprogram. If you have any questions, please feel free to call OllieFordham of our Methods Section at (202) 260-4778.Sincerely,Sylvia K. LowranceDirectorOffice of Solid Waste


