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Hazardous Waste Management
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Hazardous Waste Management
An Introduction
Second Edition
Cliff VanGuilder
This publication, portions of it, or any accompanying software may not be reproduced in
any way, stored in a retrieval system of any type, or transmitted by any means, media,
electronic display or mechanical display, including, but not limited to, photocopy, recording,
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Portions of this book have been quoted directly with permission from Introduction to
Environmental Science and Technology. Dr. S. Amal Raj. Laxmi Publications Pvt. Ltd. 2008.
The publisher recognizes and respects all marks used by companies, manufacturers, and
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Contents
Acknowledgments xiii
Introduction xv
Summary 118
Exercises 118
References 119
Conclusion 261
Appendix A Glossary 263
Appendix B United States Federal Hazardous Waste Regulations 273
Appendix C Protocol for Conducting Environmental Compliance
Audits for Hazardous Waste Generators Under RCRA 275
Appendix D Resource Conservation and Recovery Act
Self-Assessment Tools 277
Appendix E Answer Key to Even-Numbered Exercises 279
Index285
Acknowledgments
T
o my Family, thanks for all your love, patience and support.
To my church family at Faith Baptist Church, thanks for your prayers and
moral support.
To Laurie Bibighaus, thanks for your great technical review and sound
advice.
To Howard Brezner and the rest of my former team, thanks for the great
experiences.
To Pauline Bartel; thanks for inspiring me to write.
To Bruce Bergwall, thanks for putting me in touch with the right people.
To David Pallai and Jen Blaney; thanks for your patience and wisdom work-
ing through this process.
Introduction
T
he first edition of this book, Hazardous Waste Management, An In-
troduction was published in 2012, and the entire contents of this
text are current but several portions will be out of date over the next
few months.
This second edition is very timely, because in 2014 and 2015, the United
States Environmental Protection Agency (USEPA) introduced three major
revisions to the Solid and Hazardous Waste Regulations, those being the
first major revisions since 1990. These revised standards are taking effect
across all states (on schedules determined by states) authorized by the
USEPA to administer their own programs.
These changes were implemented by the USEPA for a variety of rea-
sons, with the majority of the solid waste regulations intended to tighten up
the regulation of recycling facilities, including hazardous waste recycling.
The bulk of the hazardous waste regulation changes were to simplify the
regulation of the smallest facilities that generate hazardous waste and to
recognize and help businesses that generate larger quantities of hazardous
waste on a one time or infrequent (episodic) basis.
This text also includes a description and discussion of a separate regula-
tory change in the hazardous waste arena, promulgated by the USEPA on
December 1, 2008. This action added a new Subpart K, which applies to
colleges and universities, and teaching hospitals and nonprofit research
institutes that are either owned by or formally affiliated with a college or
university. It was not included in the 2012 version of this book because it
had not yet been implemented in the individual states.
xvi • Introduction
tains the federal hazardous waste CFRs, along with a supplement on how to
pass hazardous waste inspections.
Owners of businesses and environmental managers face a daunting
task. They are expected to be familiar with a myriad of environmental regu-
lations and to comply with them all. The hazardous waste regulatory pro-
gram is arguably the most complicated environmental regulatory program,
in terms of understanding the language and the requirements. This book is
written to translate the language and intention of these complex hazardous
waste regulatory requirements into terms the business owners and environ-
mental regulators can understand.
The book also offers options for potential regulatory relief and cost sav-
ings in areas like neutralization of certain corrosive hazardous wastes, iden-
tification of certain hazardous wastes as universal wastes, and other areas.
Since my retirement with the NYSDEC in 2009, I have continued my
work in the environmental engineering and compliance arena as the owner
of two consulting firms; ARCH Environmental Compliance Service Associ-
ates, LLC, and VanGuilder Engineering, PLLC, both of which help clients
deal with environmental compliance.
Both of my firms offer compliance training in the form of preliminary
compliance audits to prepare for regulatory inspections, written plans for
compliance, and environmental and civil/structural engineering design.
ARCH Environmental Compliance Service Associates, LLC and Van-
Guilder Engineering, PLLC are both located in upstate New York at 333
Kingsley Rd, Burnt Hills, NY, and any questions about these firms can be
made at (518) 491-3287.
1
A Brief History of
Hazardous Waste
In This Chapter
●● Introduction to and definitions of solid waste and hazardous waste
●● The history of solid and hazardous waste management
●● The first U.S. solid waste law
●● The first U.S. hazardous waste laws
●● The fundamental principles of hazardous waste management
●● Examination of Fukushima Disaster
T
his chapter introduces readers to hazardous waste management in
the United States; more precisely, the history of solid and hazardous
waste, the identification of solid and hazardous waste, and U.S. haz-
ardous waste policy and regulations. Although technical discussions of solid
waste, hazardous waste, wastewater, and air pollution control are included
in this text, a substantial portion of this book is dedicated to outlining and
explaining the hazardous waste regulations in the United States and helping
the reader to understand the steps required to comply with them.
Figure 1.1 Hazardous waste label. (Washington State Department of Ecology at http://www.ecy.wa.gov/
programs/hwtr/hw_labels/index.html.)
A Brief History of Hazardous Waste • 3
Side Note
“Roman rubbish was often left to collect in alleys between buildings in the poorer
districts of the city. It sometimes became so thick that stepping stones were
needed. ‘Unfortunately its functions did not include house-to-house garbage
collection, and this led to indiscriminate refuse dumping, even to the heedless
tossing of trash from windows’ (Casson, Lionel. Everyday Life in Ancient Rome, revised
and expanded edition. Baltimore: The Johns Hopkins University Press, 1998. p 40.)
As a consequence the street level in the city rose, as new buildings were constructed
on top of rubble and rubbish” [WIKI 11a].
Health Hazards
These early dumps generally were not contained by any liners, leachate
collection systems, or groundwater barriers. Some of the contaminated
leachate from the dumps eventually leaked out and polluted groundwater
and surface water, creating health problems, but the source was not always
immediately obvious. Most dumps did not receive any kind of regular cover
material, such as soil, so numerous birds, insects, rodents, and other vermin
would go to the dumps to eat. These vermin became vectors of diseases
when they left the dumps and migrated to populated areas. Fires were a
problem at many of these dumps, sometimes purposely set by humans to
reduce the volume of the waste, at other times to drive off the vermin, and
sometimes from spontaneous combustion of materials in the landfills. The
odors from these dumps were a nuisance, and the smoke and fumes from
fires created air pollution that was annoying and unhealthy for the people
living or working downwind. An additional problem occurred when m oderate
A Brief History of Hazardous Waste • 5
or heavy winds blew waste papers, grocery bags, and other light materials
from uncovered dumps into cities, villages, suburbs, towns, or onto water
bodies. The image in Figure 1.2 is representative of these dump sites.
Side Note
The residents who bought houses near the Love Canal dump site in the 1950s
and 1960s had no idea that they were going to be living next to an inactive
hazardous waste cleanup site, or that they would be potentially exposed to the
30,000 + chemicals that had been dumped there. After the New York State Health
Department discovered the extent of the contamination, the State of New York
offered to buy the affected houses at a fraction of their assessed values. Some
(about 900) homeowners accepted the offers and moved out, but some residents
(about 90 homes) decided to stay, some houses within a few feet of the highly
8 • Hazardous Waste Management, Second Edition
contaminated dump. A few of these houses are still occupied today. They were
allowed to stay because it was their property and the houses were supplied with
public drinking water.
A great deal has been written about the history of the Love Canal dump
site. Although many of the books point to Hooker Chemical alone as the
villain in this tragedy, there is evidence to suggest Hooker Chemical acted
responsibly and a different culprit caused the Love Canal area to be devel-
oped into residential housing. A February 1981 article in Reason magazine
thoroughly chronicles the true Love Canal story [Zeusse 81].
Another informative article was written on the 30th anniversary of the
discovery of the problems at the Love Canal dumpsite [Engelhaupt 08].
The second quartet, in D minor (K. 421), takes both from its tonality
and from the nature of its themes a thin veil of melancholy. The
opening theme is poignantly expressive, but the fire of it is often
covered. The characteristic width of its intervals is used throughout
the entire movement, with a strange effect of yearning, now
resigned, now passionately outspoken. The andante, in F major, is
tinged with the same melancholy. The trio of the minuet is one of the
few places where Mozart made use of pizzicato effects. The last
movement is a series of variations on a melancholy little theme cast
in the rhythm of the Siciliana, one of the Italian rhythms already
made use of by Handel and Gluck, among others.
The third quartet, in E-flat major (K. 428), is on the whole reserved
and classical in spirit. The opening theme, given in unison, has a
gentle dignity which marks the whole first movement. The measures
following the second theme are especially smooth and lovely in their
slowly falling harmonies. In the second movement, andante con
moto, there is a constant shifting of harmonies, and a somewhat
restless interchange of parts among the instruments. The trio of the
minuet, in C minor, is subtly woven over a drone bass. The final
movement is a lively rondo.
The fourth, in B-flat major (K. 458), is, in the first movement, very like
Haydn, light-hearted and wholly gay. The following minuet, adagio,
and rondo need hardly be specially mentioned. The A major quartet
(K. 464), the next in the series, is in a similar vein. The slow
movement, again the third in the cycle, is in the form of variations;
and the last is full of imitations and other contrapuntal devices.
The last of these quartets, in C major (K. 465), is the most profound
and the most impassioned. The boldness of Mozart’s imagination in
harmonies is in most of his work likely to fail to impress the modern
ear. One hears but half-consciously the subtlety of his modulations.
But here and there in his work the daring of the innovator still has
power to claim our attention; as in the andante of the last pianoforte
sonata in F major (K. 533), and still more in the introduction of this
quartet. The sharp harmonies of the first few measures roused
hostility; and the discussion as to their grammatical propriety was
continued for more than half a century after Mozart’s death.
There remain three more quartets to mention. These were written for
Frederick William II of Prussia, at whose court Mozart had been a
frequent attendant during the early spring of 1789. The first quartet
was completed in Vienna, in June, 1789. The other two were written
about a year later. In Köchel’s index the three are Nos. 575, in D
major, 589, in B-flat major, and 590, in F major.
All are very plainly written with a king in mind who played the
violoncello. In most of the movements the 'cello is given a very
prominent part, frequently playing in unusually high registers as in
the announcement of the second theme in the first movement of the
first of these quartets; in the trio and the finale as well. In many
places the viola plays the bass part, leaving the 'cellist free to be
soloist, as in the opening measures of the Larghetto in the second
sonata. Thus these quartets, fine and free in style as they are, are
not the fullest expression of Mozart’s genius, as the series of six
dedicated to Haydn may be taken to be.
With the quartets may be mentioned the four great quintets for
strings, written, two in the spring of 1787, one in December, 1790,
and one in April, 1791. Of the combination of five string parts Haydn
made little use. Boccherini, however, had written at least one
hundred and twenty-five quintets. He was himself a 'cellist and, as
might be expected, the added instrument in his quintets was a 'cello.
Mozart added another viola to the group. Though this added no new
strand of color to the whole, it rather complicated the problems
offered by the quartet. As Otto Jahn has carefully explained, with the
volume of sound thus thickened, there came a need for even more
active movement of the separate parts. Since the additional part was
among the middle voices, the outer voices must be spread as far
apart as possible so as to allow sufficient freedom of movement to
the inner. The extra viola might be treated as a bass part to the first
and second violins, or as the upper part above the other viola and
the 'cello. Mozart made use of this possibility of contrast nowhere
more clearly than in the opening pages of the quintet in G minor.
The four quintets are respectively in C major (K. 515), G minor (K.
516), D major (K. 593), and E-flat major (K. 614). Of these that in G
minor is clearly the most remarkable; and it is indeed conspicuous
above almost all his instrumental music, for the passionate intensity
of the moods which it voices. Needless to say it still holds its place
as one of the supreme master-works in chamber music. More than a
similarity of key unites it to the symphony in G minor. The themes in
both works seem much alike, and both are equally broad in form and
full of harmonic color.
FOOTNOTES:
[62] L. Piquot: Notice sur la vie et les ouvrages de Luigi Boccherini; Paris, 1851.
[63] These are Nos. 1-18, inclusive, in Pohl’s index. The opus numbers by which
Haydn’s quartets are usually designated are taken from the thematic index
prefixed to the complete Trautwein Edition of 1844. These first quartets are: Opus
1, Nos. 1-6; opus 2, Nos. 1-6; and opus 3, Nos. 1-6.
[68] Adagio, allegro, minuetto. The finale rondo was added some years later. Cf.
‘W. A. Mozart,’ by de Wyzewa and de Saint-Foix: Paris, 1912.
[69] Cf. Wyzewa and Saint-Foix: op cit. Gassmann was born in Bohemia in 1723
and died in Vienna in 1774. A great many of his works in manuscript are in the
libraries at Milan. He had been appointed to a place in Vienna in 1762, and was
hardly likely, therefore, to be in Milan when Mozart was; but he had lived at one
time in Milan and came back there occasionally from Vienna to superintend
performances of his operas.
CHAPTER XVI
THE STRING QUARTET: BEETHOVEN
Beethoven’s approach to the string quartet; incentives; the six
quartets opus 18—The Rasumowsky quartets; opera 74 and 95—
The great development period; the later quartets, op. 127 et seq.:
The E-flat major (op. 127)—The A minor (op. 132); the B-flat
major (op. 130); the C-sharp minor (op. 131); the F major (op.
135).
I
Beethoven’s six quartets, opus 18, were first published in 1800. He
had already experimented in other forms of chamber music, not only
for strings alone. The sextet for two clarinets, two bassoons, and two
horns; the quintet, opus 16, for piano, oboe, clarinet, horn, and
bassoon; the string quintet, opus 4; three trios for violin, viola, and
violoncello; the trio, opus 11, for piano, clarinet, and violoncello; and
sonatas for violin and piano, and violoncello and piano, had already
been written. The pianoforte sonatas up to that in B-flat, opus 22,
and the first symphony had likewise been completed. Beethoven
thus turned to the composition of string quartets after an experience
with almost all other branches of music had made him master of the
art of composition.
Apart from any inner development in the man which waited thus long
before attempting expression in that form in which the very last and
in some ways the most remarkable of his thoughts were to find
utterance, one or two external circumstances probably turned his
attention to the string quartet. One was undoubtedly the morning
musicales at the house of his friend and patron, Prince Lichnowsky,
where such music was especially in demand, and where Beethoven
must constantly have heard the quartets of Haydn and Mozart.[70]
Another was his personal acquaintance with Emanuel Aloys Förster,
[71] a composer of quartets for whom Beethoven had a high regard.
These first quartets appeared in two groups of three. They are not
arranged in the order of their composition. For example, that in D
major, the third in the first set, is probably the oldest of the six. But
the series presents little evidence of development within its limits,
and there is hardly reason to attach serious importance to the order
in which the various quartets were created. Besides, with the
exception of the quartet in C minor, No. 4, the entire series is
expressive of much the same mood and intention. If one quartet is at
all distinguished from the others, it is only by a few minor details,
usually of biographical or otherwise extrinsic significance. The
technique is that of Haydn and Mozart, lacking, perhaps, the assured
grace of the earlier masters; the character, one of cheerfulness, with
only here and there a flash of the emotional imperiousness with
which Beethoven took hold of music.
II
The year after the publication of these first quartets appeared the
quintet for strings, in C major, opus 29. This is the only original string
quintet of Beethoven’s, except the fugue written for a similar group of
instruments in 1817, probably as a study. The quintet, opus 4, is a
rearrangement of the octet for wind instruments, written in 1792,
before coming to Vienna. The quintet, opus 104, is an arrangement
of the trio in C minor, opus 1, which Beethoven made in 1817,
following an anonymous request, and which he regarded
humorously.
In 1808 were printed the three great quartets opus 59, dedicated to
Count (later Prince) Rasumowsky. Beethoven’s earlier patron, Prince
Lichnowsky, had left Vienna, and the famous quartet under the
leadership of Schuppanzigh, which had played such a part in his
Friday morning musicales, was now engaged by Rasumowsky,
Russian Ambassador to the court at Vienna. Rasumowsky
commissioned Beethoven to write three quartets in which there was
to be some use of Russian melodies.
The Russian quartets are regular in structure, but they are as broad
as symphonies by comparison with opus 18. The style is bold,
though the details are carefully finished, and the instruments are
treated polyphonically, each being as prominent and as important as
the others. This in particular marks an advance over the earlier
works in the same form. There is in them, moreover, an emotional
vigor, which, expressed in broad sweeps and striking, often strident,
harmonies, worked in the opinion of many contemporaries a
barbarous distortion of the hitherto essentially delicate form. To
interpret them is but to repeat what has been already made familiar
by the sonatas of the period, by the Eroica, and by Fidelio. It is the
same Beethoven who speaks here with no less vigor, though with
necessarily finer point.
The second quartet of the series is less forceful, and far more
sensitive and complicated. The key is E minor. Two incisive, staccato
chords, tonic and dominant, open the movement. One remembers
the opening of the Eroica. There follows a full measure of silence
and then the melodic kernel of the first movement, pianissimo in
unison—a rising figure upon the tonic triad (which will again recall for
an instant the Eroica) and a hushed falling back upon the dominant
seventh. Again the full measure of silence, and again the rising and
falling, questioning, motive, this time in F major. After an agitated
transitional passage, the first violin gives out the second theme, a
singing melody in G major. But the threefold first theme—the incisive
chords, the measure of silence, and the questioning figure—carry
the burden of the work, one of mystery to which the second theme is
evidently stranger. At the beginning of the middle section, and again
at the beginning of the long coda, the chords and the breathless
silences assume a threatening character, now hushed, then
suddenly angry, to which the figure reluctantly responds with its
unanswered question.
The last of this series of quartets—in C major—is for the most part
wholly outspoken. There is little obscurity in meaning, none in form.
At the basis of the slow introduction lies a series of falling half-tones,
given to the 'cello. The first allegro is almost martial in character. The
second movement—andante con moto quasi allegretto, in A minor—
is in the nature of a Romanza; and the frequent pizzicato of the 'cello
suggests the lutenist of days long gone by. There follows a Minuet
instead of a Scherzo; and at the end there is a vigorous fugue.
Between these three quartets and the final series beginning with
opus 127, stand two isolated quartets: opus 74, in E-flat major, and
opus 95, in F minor. Neither indicates a considerable change in
Beethoven’s method, or in his attitude towards his art. The former,
composed in 1809 and dedicated to Prince Lobkowitz, is in the spirit
of the last of the Rasumowsky quartets; that is, outspoken, vigorous,
and clear. The relatively long, slow introduction alone hints at a tragic
seriousness; but it serves rather to show from what the composer
had freed himself, than to expose the riddle of the piece. The first
theme of the first movement is stalwart and well-built; the second, of
rather conventional character, chiefly made up of whirring scale
groups. In the development section there are many measures of
arpeggio figures, at first pizzicato, later growing into arco; by reason
of which the quartet has been given the name of Harfenquartett
(Harp-quartet). In connection with this passage Dr. Riemann has
remarked that all such experiments in sound effects [such as
pizzicato, harmonics and playing on special strings] serve only to
reveal the actual lack of different tone-colors in the quartet; and,
indeed, distract the attention from the ‘drawing’ [i.e., the pure lines of
the various parts] which is peculiarly the affair of the quartet.
The movement is not completed, but goes without pause into the
next, a strangely built scherzo, allegro assai vivace, ma serioso. The
vivace evidently applies to the main body of the movement, which is
in a constantly active, dotted rhythm. The serioso is explained by the
part of the movement in G-flat major, which one may regard as the
trio. This is merely a chorale melody, first given by the second violin.
The lower instruments follow the melody with note-for-note
harmonies; the first violin adds to each note of the melody an
unvarying formula of ornamentation. All this is done first in the key of
G-flat major, then in D major. The opening section is then repeated,
and after it comes the chorale melody, a little differently scored; and
a coda, piu allegro, brings the movement to an end.
The last movement is preceded by a few introductory measures,
which are in character very like the Lebewohl motive in the sonata,
opus 81. And the progression from the introduction into the allegro
agitato is not unlike the beginning of the last movement of the same
sonata. The allegro itself is most obviously in hunting-song style,
suggesting in the first melody Mendelssohn, in parts of the
accompaniment the horns at the beginning of the second act of
Tristan und Isolda. The second theme is a horn-call. Just before the
end the galloping huntsmen pass far off into the distance, their horns
sound fainter and fainter, finally cease. Then there is a mad coda, in
alla breve time.
III
There follows between this quartet and the quartet, opus 127, a
period of fourteen years, in which time Beethoven composed the
seventh, eighth, and ninth symphonies, the last pianoforte sonatas,
the Liederkreis, and the Mass in D. He turned to the quartet for the
last expression in music of what life had finally come to mean to him,
stone-deaf, miserable in health, weary and unhappy. There is not
one of the last five quartets which does not proclaim the ultimate
victory of his soul over every evil force that had beset his earthly
path.
Of the five last quartets the first and last are formally the most clear;
the intermediate three, especially those in A minor and C-sharp
minor, are perhaps the most intricate and difficult music to follow and
to comprehend that has been written. All but the last are very long,
and thus tax the powers of attention of the average listener often
beyond endurance. Their full significance is discerned only by those
who not only have made themselves intimately familiar with every
note and line of them, but who have penetrated deep into the most
secret mysteries of the whole art of music.
The first variation opens with the melody for violoncello, only slightly
altered from its original form. The violins add a counterpoint in
dialogue. This variation comes to a full stop. The second brings a
change in time signature (C, andante con moto). The theme, now
highly animated, is divided between the first and second violins. In
the fourth variation (E major, 2/2, adagio molto espressivo) only the
general outline of the theme is recognizable, cut down and much
compressed. The fifth variation brings back the original tempo and
the original key. The violoncello has the theme, only slightly varied in
rhythm, and the first violin a well-defined counter-melody. The sixth
and last variation (in this movement) grows strangely out of the fifth,
in D-flat major, sotto voce, leads to C-sharp minor, and thence to A-
flat major. There is a short epilogue.
The main themes of the Scherzo and Trio which follow are so closely
akin to the theme of the adagio, that the movements may be taken
as further variations. The main body of the Scherzo is in that dotted
rhythm of which Beethoven made frequent use in most of his last
works; and is fairly regular in structure, except for the intrusion, at
the end of the second part, of measures in 2/4 time, in unison, which
may be taken as suggestions of still another fragmentary variation of
the adagio theme. The Trio is a presto in E-flat minor.
The Finale is entirely in a vigorous, jovial and even homely vein. The
themes are all clear-cut and regular; the spirit almost boisterous,
suggesting parts of the ‘Academic Festival Overture’ or the
Passacaglia from the fourth symphony of Brahms.
III
This E-flat major quartet was completed at the latest in January,
1825. Work on the following three quartets—in A minor, B-flat major,
and C-sharp minor—began at once, but was interrupted by serious
illness. About the sixth of May Beethoven moved to Gutenbrunn,
near Baden; and here took up the work again. The A minor was
completed not later than August, the B-flat in September or October,
the C-sharp minor some months later, after his return to Vienna.
The three quartets are closely related. In the first place all show a
tendency on the part of Beethoven to depart from the regular four-
movement type. There are five movements in the A minor, six in the
B-flat major, seven in the C-sharp minor; though in the last, two of
the movements are hardly more than introductory in character. The
Danza Tedesca in G major in opus 130, was written originally in A
major and intended for the A minor quartet. Finally the chromatic
motive, clearly stated in the introduction to the A minor quartet, and
lying at the basis of the whole first movement, may be traced in the
fugue theme in opus 130, and in the opening fugal movement of
opus 131.