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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