vvEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9444.15-84
: Response to questions from State Pestcide Control Office: What is
.Disposal Cinteria for Waste with only 1 Active Ingredient?
APPROVAL DATE: flugust 8, 198U
EFFECTIVE DATE: flugust 8, 198H
ORIGINATING OFFICE:
0 FINAL
of Solid Waste
D DRAFT
STATUS:
[ ] A- Pending OMB approval
{ j B- Pending AA-OSWER approval
[ ] C- For review &/or comment
[ ] D- .In development or circulating
headquarters
REFERENCE (other documents):
OSWER OSWER OSWER
fE DIRECTIVE DIRECTIVE
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vvEPA
Wasnmgton. DC 2CW60
OSWER Directive Initiation Request
9444.15-84 ,
Name of Contact Person
Skinner
Mai. Cooe - Branch
Telephone f«umoer
Leaa 0'
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9444 .-,5-8 4-<:- 8 AUG7984
Response to Questions from State pesticides Control Officers
John H. Skinner
Director
Office of Solid Waste and Emergency Response (WH-562)
Amy E. Schaffer
Program Analyst
Office of Solid Waste and Emergency Response (WH-527)
The following responses are presented for the questions and
issues posed by the State Pesticides Control Officers concerning
RCRA. Some of the questions were quite difficult to interpret
and were answered to the best of our ability. If additional
information or clarification is required, please contact
Francine Jacoff at 475-8551.
(1) NEW MIXING, LOADING AND TEMPORARY STORAGE STANDARDS -
Currently no standards exist which indicate acceptance
methods. Society must lay out its level of accepta-
bility if actions taken today are not to result in
similar concerns to the old sites issue.
RCRA does have existing standards that apply to
temporary storage, that is, for less than 90 days.
(2) Are there reasons which would justify the "economically and
technically feasible" standards for some pesticide disposal?
The question is taken out of context and is difficult\x
to answer. None of the RCRA disposal standards are xx
based on economics but instead are based on a "protect \
human health and the environment" study. They may be \
referring to tailored standards for particular pesticides.;
RCRA either requires compliance with Subtitle C standards;;.
for listed hazardous wastes or excludes them for specified
reasons. ' ' ; .. -',
t " '
(3) Container disposal, particularly ULV products and in
impregnated fertilizer situations. What if triple rinsing
is impossible? . -. = .' . '/v : "-
Section 261.7 is pertinent only if the product is ,
listed in $261.33. Section 261.7, Residues of
hazardous waste in erapty containers, is explicit./
(4) Bulk pesticide storage standards - are they needed?^-/-c;
RCRA is concerned with waste storage, not product
. storage. OPP should answer this question. .-...
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(5) Old products disposal - A reasonable policy to rid the
storage area of "unusable" material is needed with emphasis
on recycling.
RCRA encourages recycling of hazardous wastes by
exempting them from Subtitle C standards when recycled..-
Old products disposal are only regulated by RCRA if
product is listed in §261.33.
(6) Small dip tanks associated with local lumber facilities
accumulate sludge (PCP). A policy which allows annual
purging, of the system requires the material to be landf illed
in a regulated hazardous waste site but removes the require-
ment of being a generator would assure better disposal.
Is such a policy obtainable?
is presently studing the wood preserving industry
in order to determine additional listings of hazardous
waste. It should be noted though, that there is an
existing exclusion for generators of small amounts of
hazardous waste, (<1000 ks/ma)
(7) What aid for developing recycling incentatives exist? What
funding is available?
RCRA does not provide for financial assistance. However
if unique ideas are presented to SPA's ORD, there might
be a possibility of a research and development grant.
(8) Is use of a pesticide regulated under RCRA?
NO .
(9) At what level (if any) does decontaminated water become
unregulated?
If the contaminated water is listed as a hazardous waste/
the generator that "decontaminates" it must submit a
delisting petition to the OSW.
(10) What analysis has been done of existing disposal techniques -,
and systems to determine their acceptability for decontamina-
tion? For exaraple, the Purdue system causes operators to : ;
become generators. Is that the intent of proper disposal ,i--^
policy? .--. , ..--; ' , ;.. / .. .- :,.-?_.^.;;?>....::.:;;^^
EPA is constantly interested in updating their disposal:;
standards. This issue may be better addressed by OPP. '.^
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(11) Pits used for breaking down residual chemicals are now
considered to be disposal sites and are regulated as such.
Many sites forced applicators to adopt this "new" technology
several years ago. How these sites have caused individuals
to be regulated the same as major hazardous waste sites.
Is a lesser classification reasonable and obtainable?
It depends on whether the pit is a tank or a surface '
impoundment. If a tank, the waste stream is exempt
frora RCRA when subject to an NPDES permit. If a surface
impoundment, and the waste stream is hazardous, it is
'regulated by RCRA. Lesser classification would be
cumbersome and confusing and would not b« in keeping
with the intent of RCRA which is to protect human health
and the environment.
(12) What EP toxicity testing is required when chemicals which are
intended for disposal are mixed together?
EP toxicity testing ia the same for all wastes that ara
meant for disposal. See SW-846.
(13) When a waste contains only one active ingredient, how do«a
disposal criteria differ from more than one active ingredient
waste?
Discarded commercial chemical products are only regulated
as hazardous waste where the chemical listed in $261.33
is the sole active ingredient.
(14) We seem to b« indicating storage of types of pesticide
wastes, i.e., herbicide waste or insecticide waste, together
is acceptable procedure today. Is that correct?
Yes, if there is no reactivity between the wastes and
the wastes are compatible with the container.
(15) Exemptions, are they fair and do the existing standards
really safeguard the environment?
V ' . ' '
This is a rhetorical question. EPA regulations and concerns.
are dynamic and always subject to change if warranted. / v
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