Question # 557

557. Waste containing barium chloride is shipped off-site to a RCRA treatment, storage, or disposal (TSD) facility. The TSD facility treats the barium chloride, converting it to barium sulfate. The barium sulfate is stabilized and subsequently disposed. Since barium sulfate is excluded from the EPCRA section 313 barium compounds category, should the barium chloride be reported as shipped off-site for treatment or transferred off-site for disposal?
Barium chloride is being converted into a chemical that is not reportable under EPCRA section 313. Therefore, the barium chloride would be considered to be treated for destruction. The barium chloride should be reported in Section 6.2 as transferred off site for treatment. M69 'other waste treatment' should be used. Despite the fact that barium chloride is a metal compound, the quantity of barium chloride transferred off-site should be reported in Section 8.7 rather than Section 8.1. The waste management of barium chloride is reported this way in Section 8 because the metal compound that barium chloride is converted to (barium sulfate) is not reportable and thus the barium chloride can be considered destroyed. The following is effective starting January 1, 1998: The TSD facility receiving the barium chloride should apply the quantity of the barium chloride that is converted to barium sulfate to the otherwise use threshold because it received the barium chloride from off-site for purposes of waste management and the facility treated the barium chloride for destruction (a listed chemical converted into a non-listed chemical). The TSD should also report the quantity of barium chloride that was treated for destruction in Section 8.6 (Quantity Treated On-site). It should also report any other releases or other waste management activities associated with the treatment for destruction of this toxic chemical.