6EPA
United States
Environment*! Protection
Agency
Office of
Soitd Waste and
Emergency Response
DIRECTIVE NUMBER: 9432.03(84)
TITLE: Permit Policy for Decanning and Crushing Operations
*
APPROVAL DATE: 4-26-84
EFFECTIVE DATE: 4-26-84
ORIGINATING OFFICE: osw
Q FINAL
D DRAFT
LEVEL OF DRAFT
DA — Signed by AA or DAA
D B — Signed by Office Director
DC — Review & Comment
REFERENCE (other documents):
OS WE Ft OSWER OSWER
ME DIRECTIVE DIRECTIVE Dl
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PART 260 SUBPART B - DEFINITIONS
DOC: 9432.03(84)
Key Words: Treatment, Dilution
Regulations: 40 CFR 260.10, Parts 264, 270
Subject: Permit Policy for Decanning and Crushing Operations
Addressee: James H. Scarbrough, Chief, Residuals Management Branch,
Region IV
Originator: John H. Skinner, Director, Office of Solid Waste
Source Doc: #9432*03(84)
Date:
Summary:
4-26-84
If- an owner/operator adds wastewater to a crushing operation making the
waste non-hazardous or less hazardous, s/he meets the definition of "treatment"
as defined in §260.10.
The addition of wastewater to reduce potential for fires/explosions
rendering certain wastes nonhazardous constitutes treatment by definition
provided in §260.10. It does not matter that wastewater serves other purposes
(e.g., keeping gears clean) because these activities do not alter the fact that
treatment is taking place.
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9432.03 (84)
APR 26 1984
KcHQKAKOUH
SUBJECT: Permit Policy for Oecannlng and Crushing Operations
FROM: . John H. Skinner, Director
Office of Solid Waste
TO: . James H. Scarbrough, Chief
.Residuals Management Branch, Region IV
aenorandun Is In response to your April 5. 19d4,
request for a headquarters policy Interpretation on permitting
of Hazardous waste decannln,) and crusnlng operations.
co Based on our understanding of the process at Shulton, Inc.,
toiletry crushing operation clearly meets the definition of
^"treataent* as specified In §264.10. It Is tnerefore subject to
« permitting under Parts 264 and 270. We have based our conclusion
on tha following:
»•
£ a) The addition of wastewater 1n the crushing operation
2 serves to reduce the potential for fires and explosions,
and also dilutes the alcohol to a non-hazardo'us state.
3 This 1s consistent with the treatment definition, which
0 extends to any "process. ..desl gned to change the physical,
chenlcal or biological character or composition of any
hazardous waste. ..so as -to render such waste non-hazardous,
or less hazardous, or safer to transport, store or dispose
of...." That the water way serve other purposes, such
as keeping tne gears of tne mechanism clean and cleaning
tfte container residuals, does not alter tha fact that
N treatment of tha hazardous wastes 1s taking place. We
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was designed siaply to ao-jrugate th« wastes Into
larger containers. The wastes w«r* not rendered
,non-hazardous or less hazardous, and any change 1n
tne wastes' characteristics (such as a posslole cnan-je
In concentration) was 1n this Instanca truly incidental.
Changes in a waste's characteristics cannot be prosunod
to oe Incidental sltaply &*cjuse they occur in a crushing
or oeca.inl n
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