5EPA
United States
Environmental Protection
Agency
Off ice of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER:
9433.07(84)
TITLE: Information Required for Review of Delisting
Petitions
APPROVAL DATE: 12-21-84
EFFECTIVE DATE: 12-21-84
ORIGINATING OFFICE: osw
D FINAL
D DRAFT
LEVEL OF DRAFT
DA — Signed by AA or OAA
D B — Signed by Office Director
DC — Review & Comment
REFERENCE (other documents):
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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. PART 260
Key Words:
SUBPART C - RuLEMAKING PETITIONS
OOC:
9433.07 (84)
Delisting
40 CFR 260.22
Regulations:
Subj ect:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Information Required for Review of Delisting Petitions
T. E. Stutts, Executive Vice President, Loxcreen Co.; Inc.,
P. O. Box 523, Highway 84 West, Hayti, MO 63851
Scot t J. Maid, Environment al.,Protect ion Specialist, Waste
Characterization Branch. "--
119433.07(84)
12-21-84
The Hazardous and Solid Waste Amendments (HSWA) of 1984 require that peti-
tioners address constituents for which the petitioned waste was initially listed
as well as other hazardous constituents that may reasonably be expected to be
present in the petitioned wastes. While the specific information required
depends upon the petitioned waste, the following general data are required:
o
A list of raw materials and a description and schematic diagram of manu-
facturing processes which 'may contribute waste, wastewater, or rinse
water to the wastestream.
o
An evaluation of rep~esentative samples for the hazardous waste charac-
teristics of ignitability, corrosivity, or reactivity.
o
Data showing that representative composite samples underwent EP toxici~y
testing.
o
A determination of the total oil and grease content and total organic.
content of the waste by testing representative samples.
o
A statement indicating that samples analyzed and reported in the petition
are considered representative of any variation in constituent concentra-
tions in the waste.
o
Average and maximum quantities of waste generated per month/year.
o
Quality assurance procedures followed during sampling and analyses.
o
An explanation why planned changes of equipment, feedstock materials,
and manufacturing processes will not alter the chemical makeup of the
wastestream.
.
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'-f\
9433.07 (84.)
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LJ ~ ~ ~ 1 bc}
Hr. T.E. Stutts
Executive.Vice President
Loxcreen Co., Inc.
P.o. Box 523
Ri~hway 84 West
Hayti, Missouri 63851
Re:
Additional information and clarification of Dellstln~ Petition
',52 for Loxcreen Co.
Dear Mr. Stutts:
The purpose of
complete the review
for final exclusion
Missoari facility.
The RCRA amendments si~ned into law on 9 November 1984
require EPA to determine 1f, other hazardous constituents besides
those for which the waste was ori~lnally listed are adequately
characterized anrl qua~tified by the petitioner. The additional
information requirements that the Agency would like Loxcreen to
address are summarized in'Attachment 1. These additional require-
ments will help to verify that the other hazardous constituents
in quest 10n are .not present at levels of reFulatory concen'\.
this letter is to collect data necessary to
of Loxcreen's petition (subcitted 8 May 1981)
of treatment residues from Loxcreen'.s Haytl,
The ne~ amendments have.also instituted. timetable for
i process!np, temporary exclusions, so it is very important for
Loxcreen to forward this data to our office as soon as possible.
All facilities that hold temporary exclusions must recetve final
exclusions.by the November 1986 deadline or. else they will lose
their exemptions, and the petitioned wastes will be brou~ht back
into the waste mana~ement system. 1£ TOU have any questions
re~ardin~ the data requested above, please do not hesitate to
call me at (202) 382-4488.
.
Sincerely,
Scott J. Maid
Environmental Protection Specialist
Uaste Identification Branch (WH-562B)
Enclosure
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',:,,:~~:,,=:,,~,,:_,.:"-= :'. Attachment I
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1). A complete list of .11 raw materials used -In' .anufactUrin~ -: - -. -
processes contributiri~ to the waste stream' (~rouped by
.' 'subproc:e..). Supply information on any 8olvents, acids',
paint., etc. that c:ould conceivably be introduced into the
waste atream. Include Material Safety Data Sheets for any
materials listed by brand name or any name that does not
precisely describe the contents of the substances.
. \
2) A list and description of each process whlch may contribute
waste, wastewater, or rinse water to the waste stream.,
-
3) Test results for total oil and grease content of the petitioned
waste (minimum of 4 samples) using Method No. 502D- Method
for Determinin~ Total Oil and Grease (copy enclosed). If oil
and grease content of the waste is found to exceed 1%, EP
Toxicity testing for EP metals and cyanide must be repeated
usin~ the EP Toxicity Test for Oily Waste (coPy enclosed) on
a uinimum of 4 samples.
, ,
4) Test results for total organic content (TOe) on a minimUm of
four representative samples of the petitioned waste, usin~
Method 415.1- Total Organic Carbon (copy enclosed). If TOe
exceeds 1%, a total constituent analysis for organics should
be run on a minimum of 4 samples. '
5) An explicit statement attesting that the samples analyzed and
reported in support of ~he petition are considered representative
of any variation in. constituent concentration in the waste.
6) An evaluation of representative sa~ples for the hazardous waste
, characteristics of i~nitability, corrosivity, and reactivity
(includin~ tests for cyanides and sulfides, Method Nos. 9010
and 9030 r,spectively in Test Methods for Evaluatin~ Solid
Waste). -.. ,-,' ,". .
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t
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