oEPA
                United States
                Environmental Protection
                Agency
             OH.ce of
             Solid Waste ana
             Emergency Response
DIRECTIVE NUMBER:  944i.io(84)
TITLE; Regulatory Status of Residue from Stream-Stripping
     of Process Waste Containing Toluene
                 APPROVAL DATE:  5-15-84
                 EFFECTIVE DATE:  5-15-84
                 ORIGINATING OFFICE: office of solid waste
                 HI FINAL
                 :D DRAFT
                   LEVEL OF DRAFT
                     DA — Signed by AA or DAA
                     D 8 — Signed by Office Director
                     DC — Review & Comment
                 REFERENCE (other documents):
  OS WER       OS WER       OS WER
ME    DIRECTIVE    DIRECTIVE   Dl

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PART 261  SUBPART A - GENERAL
                                                DOC:  9441.10(84)
Key Words:

Regulations:

Subject:


Addressee:


Originator:

Source Doc:

Date:

Summary:
F-Wastes, Toluene

40 CFR 261.31

Regulatory Status of Residue from Stream-Stripping of Process
Waste Containing Toluene

Lloyd R. Cress, Greenebaum, Doll & McDonald, 1400 Vine Center
Tower, P. 0. Box 1808, Lexington, KY  40593

Jacqueline W. Sales, Environmental Engineer

#9441.10(84)

5-15-84
     F001-F005 listings pertain to the pure form or technical grade solvent
when spent or discarded, not to industrial process waste containing solvents.
If the process wastewater generated from a facility is not the listed hazardous
waste, the residue from the stream-stripping of the waste is also not a hazardous
waste unless it exhibits one of the characteristics of hazardous waste.

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                                                             9441.10  (84)
                                            Rffi  Disk  VCOS doe* f
                                             MAT  »5B84
 Lloyd X. Cress
 GreenebauM, Doll i McDonald
 1400 Vine Center Tower
 •P.O. Box 1808
 Lexington, Kentucky  40593  ,

 Dear Mr. Cresst
  *  •*
      Zn your letter of April 26, 1984, you requested confirmation
 of  our earlier discussion regarding the regulatory status of
 residue from stream-stripping of process waste containing toluene.

      As I explained in our recent conversation, the solvent
 listings (EPA flasardous Waste Nos. F001-P005)  pertain to
"the pure form or technical grade solvent, when spent or discarded.
 The listings do not pertain to industrial process waste containing
 solvents.  Since process wastewater generated from your client's,
'facility, is not the listed hasardous waste, the residue from
 treatment (i.e., stream-stripping) of the waste is also not a
 hasardous waste, unless it exhibits one or more of the character-
 istics of hasardous waste (i.e., ignitability, reactivity, corrosi-
 vity or EP toxicity).

      Z trust that this letter adequately responds to your inquiry.
 fhould you require additional information, please call me at
 (202)382-4807.
                             Sincerely,
                        Jacqueline w. Sales
                       Environmental Engineer
 WH-562:JSALES:ld:382-4807:S-248:5-ll-84:Dis)c VCOS doc. 9

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