United St
              Environmental Protection
              Agency
         Office of
         Solid Waste and
         Emergency Re«pon«e
     oEPA
DIRECTIVE NUMBER:  9444.04(81)
TITLE:  Freon TF Recovery Still Bottoms

APPROVAL DATE:  6-22-81
EFFECTIVE DATE:  6-22-81
ORIGINATING OFFICE: office of solid waste
£ FINAL
D DRAFT
 LEVEL OF DRAFT
   DA — Signed by AA or OAA
   D B — Signed by Office Director
   Q C — Review & Comment
REFERENCE (other documents):
  OSWER      OSWER     OSWER
VE   DIRECTIVE   DIRECTIVE   Dl

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PART 261  SUBPART D - LISTS
                                                              DOC:  9444.04(81)
Key Words:    Freon TF Recovery

Regulations:  40 CFR 261

Subject:      Freon TF Recovery Still Bottoms

Addressee:    T.E. King, Gould, Inc., Becks Mill Road, Salem, IN 47167

Originator:   David Friedman, Manager, Waste Analysis Program, Hazardous and
              Industrial Waste Division
              #9444.04(81)

              6-22-81
Source Doc:

Date:

Summary:

     With respect to Freon TF recovery still bottoms:

     (1)  The resinous material remaining after the recovery of the
          1,1,2-trichloro-l,2,2-trifluoroethane (Freon TF) is the listed waste
          F002 and is thus a hazardous waste.

     (2)  If the generator is classified as a small quantity generator then it
          is legally permitted to dispose of the residue in state approved
      . •   landfills.

     (3)  If showing that the waste does not contain 1,1,2-trifluoro-1,2,2-
          trichloroethane is used to support a petition to EPA to delist still
          bottoms, then methods shown in SW-846 may be used to analyze for the
          chlorofluoro-carbon residues.  The SW-846 manual is available from
          Government Printing Office.

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                                                         9444.04 (81)
             UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
            _           WASHINGTON D.C.  20460

                       OFFICE Or SOLIE WASTE
 Mr. T, E-. King, Sr.
 Gould Inc.
 Powder Metal Products Division                         OFFICE OF WATER
 Becks Mill Road                                     AND WASTE MANAGEMENT
 Salem, IN  47167

 Dear Mr.  King:

      I apologize for the delay in responding to your letter
 of November 5, 1980 requesting clarification of the hazardous
 waste regulations with respect to Freon TF recovery still
 bottoms.

      First of all,  if this is the only hazardous waste you
 generate  and  you only generate 150kg/month of it, you would
 be considered a small generator.   In answer to your other
 questions.

      A.   The  resinous material remaining after recovery of
          the  l,l,2-triohloro-l,2,2-trifluoroethane (Freon TF)
          is  the listed'waste F002 and is thus a hazardous waste.

      B.   If,  as described  above,  you classify as a small generator
          you  are legally permitted to dispose of this residue
          in state approved landfills.

      C.   If you desire to  petition the Agency to delist this
        ..still  bottom by showing  that the waste does not contain
          1,l,2-trifluoro-l,2,2-trichloroethane either method
          8.01  (BSD) or method 8.24 may be used to analyze for
          the  chlorofluorocarbon residues.  Detailed protocols
        •for  these methods may be found in EPA Office of
        'Solid  Waste  Publication  SW-846.   Copies are available
          from Ed Cox,  Solid Waste Information,  U.S. Environmental
          Protection Agency,  26 West St.  Clair Street,  Cincinnati,
          OH  45268'*

     I hope this information  answers  your questions.   If you
have any  additional questions  or  would  like  a further
clarification of any of  the  above areas  please give me  a call
at (202)  755-9187.

                           Sincerely,
                        David Friedman
                           Manager
                    Waste Analysis Program
          Hazardous and Industrial Division  (WH-565)

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