v>EPA
              United States
              Environmental Protection
              Agency
            Office of
            Solid Waste and
            Emergency Response
DIRECTIVE NUMBER: 9443.01(83)

TITLE: Definition of Ignitable Solids



APPROVAL DATE:   i-io-83

EFFECTIVE DATE:   1-10-83

ORIGINATING OFFICE: Office of Solid Waste

0 FINAL

D DRAFT

 STATUS:
                        [  1
                        {  1
A- Pending OMB approval
B- Pending AA-OSWER approval
C- For review &/or comment
D- .In development or circulating

          headquarters
               REFERENCE (other documents):
  OSWER      OSWER      OSWER
/£    DIRECTIVE   DIRECTIVE    Di

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PART 261  SUBPART C - CHARACTERISTICS                         DOC:  9443.01(83)


Key Words:   Ignitable Waste

Regulations: 40 CFR 261.21

Subject:     Definition of Ignitable Solids

Addressee:   David A. Wagoner, Director, Air and Waste Management Division,
             Region VII

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

Source Doc:   #9443.01(83)

Date:        1-10-83

Summary:

     In order for a solid waste to be considered "ignitable," two specifications
must be met.  Such a waste must be capable under standard temperature and
pressure of:

      1. Causing fires through friction, absorption of moisture or spontaneous
         chemical changes; and

      2. Burning so vigorously and persistently that it creates a hazard.

     As an example, titanium swarf which is difficult to ignite, would not be
classified as a hazardous waste even though once ignited, it may pose a hazard.
To remove ambiguities in the definition, OSW is in the process of developing
specific testing methods and hazardous waste thresholds for ignitable solids.

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                            JAN  I 0 1983

                                                 RE: WCbDf034b

MEMORANDUM

SUBJECT:  lynitable Solids  Definition

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

TO:       David A. Wagoner, Director
          Air and Waste Management Division, Region VII


     As you requested in your memo of December 15, I am writing
to clarify th« definition of an ignitable solid under 40 CFR
261.21 as it applies to materials such as titanium swarf.

     As Gene Grumpier correctly advised Greg Weber- of Region V,
in order for a solid waste  to be an ignitable waste it must
be capable, under standard  temperature and pressure, of both
causing fires through friction, absorption of moisture or
spontaneous chemical changes and burn so vigorously and per-
sistently that it creates a hazard.  Thus, if the titanium
swarf is very difficult to  ignite it would not be classified
as a hazardous waste even thouyh, once ignited, it raay pose a
hazard.

     In order to remove the ambiguities inherent in such a
definition, OSW is in the process of developing specific testing
methods and hazardous waste definition thresholds for ignitable
solids.  However, s\ich tests are not expected to b« ready tor
proposal until PY 84.  \

     If you have any comments or questions concerning the
ignitabla waste definition please give David Friedman or
Florence Richardson a call  at PTS 382-4770.
WH-565B:DFRIEDMAN:df:S248:382-4770:WSM:1-5-83    Disk DF:03:45

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