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
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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.
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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
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