UniMdStMM
Environment*! Protection
Agency
Off ice of
Solid Waste and
Emergency Response
SEPA
DIRECTIVE NUMBER: 9444.01(^3)
TITLE I Interpretation of RCRA Hazardous Waste Regulations
as Pertaining to Spent Solvent Listings and the
Status of Leachate From Sanitary Landfills that
Have Received Hazardous Waste
APPROVAL DATE: e-io-83
EFFECTIVE DATE: e-io-83
ORIGINATING OFFICE: office of solid waste
C3 FINAL
D DRAFT
LEVEL OF DRAFT
DA — Signed by AA or OAA
D B — Signed by Office Director
DC — Review & Comment
REFERENCE (other documents):
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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PART 261 SUBPART D - LISTS
DOC: 9444.01(83)
Key Words:
Regulations:
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Solvents, Sanitary Landfills, Municipal Landfills
40 CFR Part 264, Subpart N
Interpretation of RCRA Hazardous Waste Regulations as Pertaining
to Spent Solvent Listings and the Status of Leachate From Sanitary
Landfills that Have Received Hazardous Waste
Dan Nelson, Waste Management, Inc., 3003 Butterfield Road,
Oak Brook, Illinois, 60521
Matthew A. Straus, Manager, Hazardous Waste Definition Program
#9444.01(83)
6-10-83
Industrial process waste which contains solvents is not included in the
solvent listings (naming those solvents used specifically for their solvent
properties) except to the extent that it is a mixture of a solid waste and a
spent solvent. As an example, spent 1,1,1-trichloroethane generated from a
cleaning process is considered EPA hazardous waste No. F002, while industrial
process waste containing 1,1,1-trichloroethane as a contaminant is not a
hazardous waste, unless specifically listed. It should be noted, however, that
these wastes may be listed under Subpart D of the regulations.
Leachate from a sanitary landfill that has received listed wastes is also
considered a hazardous waste by virtue of the mixture rule in 40 CFR 261.3(c)(2)(i)
Leachate containing F003 listed solvents is only hazardous to the extent that
it exhibits the characteristic of ignitability.'
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9444.01 (83)
£
JUN ! 0 1983 u.
U1
Dan Nelson ' HK: WCBJS0614 \
Waste Management, Inc. en
1003 Butterfield Road £
Oak Brook^ Illinois 60521 ^
'A
*«
Dear Mr. Nelson: ^
••
In your letter of April 4, 19«3, you requested that s>
EPA confirm your interpretation of the RCRA hazardous waste &
regulations as they pertain to the spent solvent listings, £.
and the status of leachate frorn sanitary landfills that have ' NJ
received hazardous waste. I trust that this letter adequately ^
addresses your concerns. " ^
»•
As stated in your letter, the solvent listings (EPA Hazardous \
Waste Nos. F001-F005) certain to spent solvents (i.e.,:solvents ^
used for their solvent properties). Industrial process waste co
containing solvents, .on the other hand, are not included in .?
the solvent listings except to the extent that it is a mixture . ^
of a solid waste and a spent solvent. Thus, you are correct ?>
in stating that spent 1,1rl-trichloroethane generated from a i?
cleaning process is considered EPA Hazardous Waste No. P002, ^
while industrial process waste containing 1,1,1-trichloroethane a
as a contaminant are not listed spent solvents. These wastes, 2
however, nay be listed individually under Subpart D of the A
regulations.
Leachate from a sanitary landfill that has received listed
wastes is also considered a hazardous waste. However, as you
stated, leachate containing F00"> listed solvents is only hazardous
to the extent that it exhibits the characteristic of ignitability.
Should you have any questions, please feel free to give
a call at (202) 382-4770. :
Sincerely yours,
Matthew A. Straus
Manager
Hazardous waste Definition Program
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