oEPA
United St
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER
TITLE:
9444.03(85)
Identification of F Solvent Wastes
APPROVAL DATE: 4-1-85
EFFECTIVE DATE: 4-1-85
ORIGINATING OFFICE: office of solid
B FINAL
D DRAFT
STATUS:
[ J
[ }
I 1
A- Pending OMB approval
B- Pending AA-OSWER approval
C- For review &/or comment
D- In development or circulating
REFERENCE (other document!):
headquarters
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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261 SUBPART D - LISTS
DOC: 9444.03(85)
Key Words: Solvents, Authorized States, Mixture Rule
Ik--*-
Regulations: 40 CFR 261.30(b), 261.31, 261.32, 261.33
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Identification of F Solvent Wastes
John D'Aloia, Jr., Deuel and Associates, Inc.,
7304 Jefferson Street, N.E., Albuquerque, N.M. 87109
Alan S. Corson, Branch Chief, Studies and Methods
#9444.03(850
4-1-85
The letter addresses several aspects for identifying solvents which are
designated as F-listed wastes. Currently, The F001-005 listings cover only
solvents used separately. If individually used solvent waste streams are mixed
after generation, the result is a mixture of F-listed waste streams. EPA is
developing regulations that will identify spent solvents on the basis of total
solvent contained in the mixture.*
* Refer to Summary/Document //9444.15 for final EPA regulations.
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9444.03 (85)
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APR 1 ^ 5
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Mr. John D*Alois, Jr. g
Deuel and Associates, Inc. *
7304 Jefferson St., WE ^
Albuquerque, MM 87109 3
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Dear Johni 0
x.
There are, indeed, several facets to identifying which CD
solvents are P-listed wastes. I am going to review the *?
points we discussed over the phone on March 20th, in response *
to your letter dated March 6, 1985. ^
\
Only those solvents designated in the *P* series are **
listed as "P" solvent wastes. In the May 19, 1980 Pederal w
Register (45 PR 33122), §261.30(5) says that Appendix VII f
identifies the constituent which caused SPA to list the waste in *
1261.31 or §261.32 as BP toxic or toxic waste. In Appendix VII, v.
only the listed solvents are specified. The spent solvent 2-
listings in f261.31 are worded "The following spent halogenated/ £
non-halogenated solvents...* which clearly designates only the
listed solvents. 5
y
Moreover, currently, only solvents used separately are
covered by the P001-005 listings. The Agency issued a letter on
July 21, 1981, to the Safety-Risen Corporation that stated that
the $261.31 listings only refer to "...spent solvents identifiable
as any technical grade of the chemical that is produced or marketed
.and not to mixtures otherwise containing the chemical.? (A copy
of RIL 95 is enclosed.) As you observed, this interpretation
is consistent with the approach taken in identifying $261.33
hazardous waste.
If individually used solvent waste streams are mixed after
generation, the mixture is a mixture of P-listed waste streams.
You can see how important it is to be able to identify the
original source of the wastes in order to classify the mixture.
Just knowing the composition of the waste is not enough to
know what waste code(s)'to apply to the waste. Regulations
under development will identify spent solvents on the basis of
total solvent contained in the mixture.
Pinally, States with authorised programs may have more
stringent or extensive regulations than EPA or operate a program
with greater scope of coverage than EPA according to S5271.1(1)
and 271.121(i). If States designate mixtures of solvents used
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in combination, as F003, tha proqraa ~ra norm axtanaiva than tha
XCRA prograa),-1>ut oparating in liau of RCRA.
If you hava any furthat quaationa, plaaaa do not haaitata
to gat in touch again*
Sincaraly yours.
Alan 8, Ooraon
Branch Ghiaf
Studiaa and, Matboda
Bncloaura
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