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 ------- |