PA
               United States
               Environmental Protection
               Agency
            OH.ce of
            Solid Waste ana
            Emergency Response
DIRECTIVE NUMBER:  9442.01(84)
TITLE: Listing of Spent Iron Sponge as a Hazardous Waste

APPROVAL DATE: 2-7-84
EFFECTIVE DATE: 2-7-84
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
   DC — Review & Comment
REFERENCE (other documents):
  OS WER      OS WER      OS WER
VE   DIRECTIVE    DIRECTIVE   Dl

-------
PART 261  SUBPART B - CRITERIA
                                                DOC:   9442.01(84)
Key Words:    Iron Sponge

Regulations:  40 CFR 261.23

Subject:      Listing of Spent Iron Sponge as a Hazardous Waste

Addressee:    Dov Weitman, Attorney, Office of General Counsel

Originator:   David Friedman, Manager, Methods Program

Source Doc:   #9442.01(84)
Date:

Summary:
2-7-84
     Although fresh spent iron sponge is probably hazardous as defined by RCRA,
until a study is prepared to determine its exact hazardous characteristics,
Headquarters will not be able to support Regional enforcement actions against
facilities that manage spent iron sponge without a RCRA permit.

-------
 F£B  7  ,'Sai                                              9442.01 (84)


Spent Iron Sponge

David Friedman, Manager
Methods Program (WH-562B)

Dov Weitman, Attorney
Office of General Counsel (LE-132S)
                           *

     I have reviewed-the material available to'us on the'spent
iron sponge issue and am afraid I cannot give you a definitive
answer as to whether or not the material is hazardous by  reason
of reactivity (40 CFR 261.23).         ".        :•  _•"•-/ ;
                                  .      ~   ,•.'•'   ~   «-•     *~  ^  *
                                         1 •              '-.•-'"'
     While the Camp, Dresser and McKee report  indicates  the"
material poses a hazard due to both auto ignition and hydrogen  '
sulfide release, the letters from Connelly^GPM, Inc. deny this.-

     However, what bothers me is that the denials are not    •
absolute.  They are qualified by management practices (i.e.,    *
that the material is water soaked).    '".._,   ..            '-•"
             *                          •      '      -.,'..••.
     The bottom line is that the fresh spent iron "sponge-is.    :
probably hazardous withing the meaning of RCRA.  -However, •-.'"  '
pending a study of the aaterial to find out exactly what  the
facts are, I am afraid that we cannot resolve  the issue.       *
Given the priority this issue holds, it is unlikely that  OSW .-
can undertake any such study in the near future. ' I, thus^
recommend that we notify the Regions of this uncertainty  and * -•
Inform them that headquarters will not be able, at  this,  time,*
to support their taking enforcement action, against  facilities who
manage spent iron sponge and do not have a RCRA permit.    .   . ':.J.-*;

cc:  B. Claussen •'""
     A. Corson :/• ""^
     M. Straus  -
    .iJ« Poppiti
     P. Richardson

-------