oEPA
United St
Environmental Protection
Agency
Off ice of
Solid WMM and
Emergency Re«pon»e
DIRECTIVE NUMBER: 9441.06(85)
TITLE: Use/Reuse Provisions in the Definition of Solid
Waste Rulemaking
APPROVAL DATE: 2-13-85
EFFECTIVE DATE: 2-13-85
ORIGINATING OFFICE: office of solid waste
E FINAL
; D DRAFT
LEVEL OF DRAFT
DA — Signed by AA or DAA
D B — Signed by Office Director
D C — Review & Comment
REFERENCE (other documents):
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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261 SUBPART A - GENERAL
DOC: 9441.06(85)
Key Words:
Regulations:
Subject:
Addressee:
Characteristics of Hazardous Waste, Solid Wastes
Use/Reuse Provisions in the Definition of Solid Waste Rulemaking
H. Bzura, Madison Industries, Inc., P.O. Box 175, Old Bridge,
NJ 08857
Originator: Matthew A. Straus, Chief, Waste Identification Branch
Source Doc: #9441.06(85)
Date: 2-13-85
Summary:
Baghouse flue dust and zinc oxide sludge which exhibits a hazardous waste
characteristic are not solid wastes if these materials are used as an ingredient
to make a new product provided they are not accumulated speculatively (as
defined in the January 4, 1985, rule) or are not used to produce a product that'
is placed on.the land for beneficial use. The effective date for the use/
reuse provisions in the definition of solid waste.rulemaking is December 20,
1.984.
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9441.06 (85)-
.- , FEB.I 3 1985
Mr. H. Bzura >— , • .-*. •
Madison Indusries, Inc.
P.O. Box 175
Old Bridge, New Jersey 08857
Dear Mr. Bzurat
This letter is response to our telephone conversation on
January 24 and your letter dated January 25, 1985 regarding
the regulatory status of the baghouse flue dust and zinc-oxide
sludge which you are considering recycling at your plant. in
^ addition, you also requested confirmation of the effective
° date for various provisions dealing with use/reuse in the
•j) definition of solid waste rulemaking. In particular, you
^ indicated that you are interested in purchasing baghouse flue
rj dust from manufacturers of brass as well as a zinc oxide sludge
n generated from air pollution control equipment. These secondary
£ materials as well as hydrochloric acid or sulfuric acid will
^ be mixed and pumped into a reactor where either zinc chloride
a or zinc sulfate will be produced. These solutions are then
a purified. You further indicated that no reclamation is
^| carried-out as part of the operation, but rather these
i* materials are used as a raw material in the manufacture of
^ zinc chemicals.
N Based on this description, you are correct that the
^ baghouse flue dust and zinc oxide sludge are not solid wastes
^ provided that these secondary materials are not accumulated
a speculatively (as defined in the January 4, 1985 rule) or are
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not used to produce a product that is placed on the land for
beneficial use.I/ in addition, you are also correct in your
reading of the regulations that the effective date for this
provision of the rulemaking—that is, the use/reuse provision-
is December 20, 1984. Please give me a call if I can be of
any further assistance. '
Sincerely yours,
Matthew A. Straus
Chief
Waste Identification Branch
4
ql I/ It should be noted that even if the zinc were .reclaimed,
s these secondary materials would not be defined as solid
i wastes since they are unlisted sludges.
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