United States
           Environmental Protection
           Agency
              Office of
              Solid Waste and
              Emergency Response
vvEPA
DIRECTIVE NUMBER:
TITLE:
9432.05(84)
                  Definition of Treatment as Defined in 40 CFR
                  Section 260.10 Subpart B - Definitions
                          11-6-84
                               OSW
APPROVAL DATE:
EFFECTIVE DATE:  u_6_84
ORIGINATING OFFICE:
m FINAL
D DRAFT
  LEVEL OF DRAFT
    DA — Signed by AA or DAA
    D B — Signed by Office Director
    DC — Review & Comment
REFERENCE (other documents):
  WER       OS WER        OS WER
  DIRECTIVE    DIRECTIVE    Dl
                                          EPA Report Collection
                                          Regional Center for Environmental Information
                                          U.S. EPA Region HI
                                          Philadelphia, PA 19103

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PART 260  SUBPART B - DEFINITIONS
                                                DOC:   9432.05(84)
Key Words:

Regulations

Subject: .
Treatment

40 CFR 260.10

Definition of Treatment as Defined in 40 CFR §260.10 Subpart  B -
Definitions
Addressee:    James Scarbrough, Chief, Residuals Management  Branch,  Region IV

Originator:   John H. Skinner, Director, Office of Solid Waste

Source Doc:   #9432.05(84)

Date:         11-6-84

Summary:

     The definition of treatment is made up of two parts:

     1)  The change in the waste's character affected by treatment.

     2)  The purpose of the change.  Purposes include: to neutralize,  to recover
         energy or material resources, to render such waste  non-hazardous,
         safer to transport, store, or dispose; amenable for recovery, amenable
         for storage, or reduced in volume.

     To be considered treatment, facility processes must serve one of  the
purposes listed in No. 2 above when changing the waste's character.

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                                                          9432.05  (84)
                               NGV . 6 iS-2-i '
MEMCP.XMPfJM
SUBJECT:  Definition of Treatment; Application to
          Great Lakes Carbon Corp*

   FROM:  John H. Skinner,  Director
          Office of Solid Waste  (WH-562)

     TO:  Jartes Scarbrough, Chief
          Residuals Manacement Branch
          EPA Region IV


     We have reviewed and interpreted the definition of treatment
as defined in 40 CFR 260.10, Subpart B - Definitions.  The defini-
tion is made up of two parts:  the change in the waste's character
effected by treatment and the purpose of the change.  Based on this
definition, the process proposed by Great Lakes Carbon Corporation
(GLCC) does not constitute  treatment.  GLCC's plan to add water to
the cyanide contained in dissolvable plastic bags will change the
physical character of the cyanide waste.  However, the purpose of
this change is to facilitate disposal.  The change will not make
the waste safer to dispose*  None of those purposes Listed in the
definition, that is to neutralize; to recover energy or material
resources; to render such waste non-hazardous or less hazardous,
safer to transport, store,  or dispose; or amenable for recovery,
amenable for storage, or reduced in volume, apply to the process
proposed by GLCC*

     If you "have any questions, please contact Mr. Thema3 Baugh of
the Waste Treatment Branch  at PTS 382-2550.

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