oEPA
United States
Environmental Protection
Agency
OHice of
Solid Waste ana
Emergency Response
DIRECTIVE NUMBER. 9441.15(85)
TITLE; Emptying Hazardous Waste from Paper Bags
*
APPROVAL DATE: 5-20-85
EFFECTIVE DATE: 5-20-85
ORIGINATING OFFICE: office of solid waste
Q FINAL
D DRAFT
LEVEL OF DRAFT
DA — Signed by AA or DAA
D 8 — 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: 9441.15(85)
Key Words:
Regulations
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Containers
40 CFR 261.33(c)(e), 261.7(b)(3)
Emptying Hazardous Waste from Paper Bags
Stanley L. Johnson, Division of Licensing and Enforcement,
Department of Environmental Protection, State House Station 17,
Augusta, Maine 04333
Irene B. Homer, Environmental Protection Specialist, Studies and
Methods Branch
#9441.15(85)
5-20-85
This letter states tht bag beating is an acceptable alternative to triple
rinsing for paper bags that contained P-listed wastes and indicates that open
burning may also be acceptable, subject to Federal, State, and local approval.
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9441.15 (85)
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MAY 2 0 1985
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Mr. Stanley L. Johnson Q
Division of Licensing and Enforcement ^
Department of Environmental Protection ®
State douse Station 17 \
Augusta, Maine 04333 £
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Dear Mr. Johnson t i
Alan Corson asked me to respond to your letter dated >-
April 10, 1935, because we previously collaborated on the £
paper bag issue. Section 261.33(c) considers a container that ^
held a hazardous waste listed in $261. 33 (e) (P-listed waste) ^
to be hazardous waste until the bag is empty as defined in o
S261.7(b)<3). Section 261. 7(b) ( 3) ( i ) involves triple rinsing ^
with an appropriate solvent, (ii) allows cleaning "by another ui
method that has been shown in the scientific literature, or by w
tests coducted by the generator, to achieve eqivalent removal, * J$
and (iii) declares that a container is empty if the liner is t
emoved. Your question was how can paper bags -i°et these en
criteria? The answer is that beating the bags after emptying £
can be an alternative to triple rinsing, as the RCRA/Superfund \
Hotline explained. •-
u
*•
The Office of Solid Waste had no written policy until M
this letter, but "bag beating* has been an acceptable alternative i
to triple rinsing on an oral basis probably since 1981. There f
are, however, no references in the literature that compare* the M
removal efficiency of repeated tapping of the outside of an
inverted paper bag vs. triple rinsing that the regulations
seem to require.
Ray Krueger, of the Office of Pesticide Programs, EPA,
said that repeated tapping with a- stick is an effective removal
mechanism, though OPP has no written policy saying so. He
expressed concern about the worker exposure, and he suggested
an alternative, explained on the enclosed copy of PR notice
183-3, issued March 29, 1983, by OPP, that cites open burning
as a possible disposal method, subject to Federal, State, and
local approval. The pesticide program has data that indicates
that such open burning leaves little residue in the soil,
because the thermal treatment break down the chemicals. In
terms of RCRA, the November 25, 1980, (45 PR 78528) preamble
sayss "Forma of container cleaning other than triple rinsing*
.ay constitute treatment. . .the burning operation is designed
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to remove and destroy the wastes...These processes meet the RCRA
definition at 'treatment1 and are thus subject to the require-
ments of Pare 264 and 265.* Unless the generator net the
small quantity generator requirements* generating less than
one kilogram of P-liated wastes in the given calendar month,
burning the bags would be subject to RCRA treatment standards.
I hope this letter answers your question for emptying
paper bags. If you have any questions, please feel free to
contact me at (202) 382-2550.
Sincerely yours*
Irene S. Borner
Environmental Protection Specialist
Studies and Methods Branch (WH-562B)
Enclosure
cc> Alan S. Corson
RCRA/Su per fund Hotline
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