PA
United States
Environmental Protection
Agency
Off ice of
Sond Waste ana
Emergency Response
DIRECTIVE NUMBER: 9441.36(84)
TITLE: RCRA Implications of Treating Gases Vented from
Compressed Cylinders
APPROVAL DATE: 12-17-84
EFFECTIVE DATE: 12-17-84
ORIGINATING OFFICE: office of solid waste
3 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 WER OS WER OS WER
VE DIRECTIVE DIRECTIVE Dl
-------
PART 261 SUBPART A - GENERAL
DOC: 9441.36(84)
'Key Words:
Regulations:
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Compressed Gas Cylinders
40 CFR Part 261 Subpart C and D
RCRA Implications of Treating Gases Vented from Compressed
Cylinders
James-H. Scarbrough, Chief, Residuals Management Branch, Region IV
John Skinner, Director, Office of Solid Waste
#9441.36(84)
12-17-84
A facility built to treat fluorine (P056) and other gases vented from com-
pressed gas cylinders is not a RCRA treatment facility for any handling of the
gases removed from the cylinders including flaring, venting, neutralizing, and
scrubbing. Any liquid or solid residues derived from the cylinders or from
treatment of the cylinders' contents that are listed in 40 CFR Part 261 Sub-
part D or are hazardous under Part 261 Subpart C are regulated under RCRA.
-------
C 1 7 1984
o
o
3
rr
z
MEMORANDUM ?
O
SUBJECT: RCRA Implications of Treating Gases «
Vented prom Compressed Cylinders i
t-^
PROM: John Skinner, Director w
Office of Solid Waste (WH-562B)
TO: James H. Scarbrough, Chief
Residuals Management Branch
Region IV
This is in response to your November 23, 1984, memorandum
regarding a facility built to treat fluorine (P056) and other
gases vented from compressed gas cylinders. You are correct
in your application of the response to the letter to the
Compressed Gas Association from Christopher Capper, dated
November 6, 1981.
According to that letter, customers return cylinders to gas
suppliers for refilling, not for disposal, and no waste is involved.
If the gas supplier decides to discard the contents of the.returned
cylinders, any liquid or physically solid wastes removed from
the cylinders are guhjggf, t-n *£** if they are hazardous waste.
Cylinders containing regulated quantities of hazardous waste
would need.to be manifested to off-site facilities for treatment,
storage, or disposal. However, the letter goes on to say that
the handling—OJL yaseous resj-dues removed from the cylinders and
neutralization or scrubbing of gases"prior to release are not
subject to RCRA regulation. Any liquid or physically solid
wastes derived from the treatment of hazardous compressed gas
is still subject to RCRA regulations, if it is derived from listed
waste or if the residual is hazardous under Part 261 Subpart C
(characteristics).
Therefore, your conclusions are correct. The facility is not
a RCRA treatment facility for any handling of the gases removed
from the cylinders. Any liquid or solid residues derived from
the cylinders or from treatment of cylinder contents that are
listed in 40 CFR 261 Subpart D or are hazardous under Part 261
Subpart C are subject to Subtitle C hazardous waste regulations.
If you have any further questions, please do not hesitate to
contact Alan Corson or Irene Horner, of my staff, at 382-4770.
cc: Hazardous Waste Branch Chiefs, Regions I-III and V-X
------- |