oEPA
               United States
               Environmental Protection
               Agency
 Office o*
 Solid Waste and
 Emergency Response
               DIRECTIVE NUMBER: 9444.09(85)
               TITLE: Toluene-Laden Filter Residue Generated from an Ink
                    Production Process
               APPROVAL DATE: 6-3-85
               EFFECTIVE DATE: 6-3-85
               ORIGINATING OFFICE: office of solid waste
               B FINAL
               D DRAFT
                 STATUS:
[
               A- Pending OMB approval
               B- Pending AA-OSWER approval
           [  |  C- For review &/or comment
           [1  D- In development or circulating
REFERENCE (other documents):      headquarters
  OSWER      OSWER      OSWER
VE   DIRECTIVE   DIRECTIVE   Dl

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261  .SUBPART D - LISTS
                                                DOC:  9444.09(85)
Key Words:

Regulations:

Subject:


Addressee:


Originator:

Source Doc:

Date:

Summary:
Solvents, Toluene
Toluene-Laden Filter Residue Generated from an Ink Production
Process

James H. Scarbrough, Chief, Residuals Management Branch, EPA
Region IV

John Skinner, Director, Office of Solid Waste

#9444.09(85)

6-3-85
     The F005 listing covers wastes that consist of solvents (and other mate-
rials) that no longer meet the specifications for which they were originally
used and are intended for discard and further processing.  This listing does
not include wastes where solvents are contaminants in the waste stream (i.e.,
where solvents are used in the industrial process).

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                                                               9444.09 (85)
                              JUN3   1985
MEMORANDUM
SUBJECT:  Request for Guidance on Part B Applications

PROMi     John Skinner/ Director
          Office of Solid Waste (WH-562)

TO«       James H. Scarbrough, Chief
          Residuals Management Branch
          EPA Region IV

     This memorandum responds to your inquiry of April 29, 1985,
requesting concurrence on the status of toluene-laden filter
residue generated from the ink production process at Union Camp
Corporation.  Your memorandum states that both EPA Region IV and
Georgia EPD consider the waste to be a spent solvent—EPA Hazardous
Waste No. F005.  We disagree with this determination.

     In general, chemicals which are used as solvents are not
consumed, nor are they physically or chemically altered during
the process.  When used in this manner, that is, for their
•solvent" properties, wastes generated are considered spent
solvents when they consist of solvents (and other materials)
which no longer meet the specifications for which they were
originally used and are intended for discard or further processing.

     The filtering unit at Union Camp is an integral part of
the production process., since its primary function is removal
of unreacted chemicals, excess reactants and other impurities
from the product.  The filtration cake generated at this unit,
however, is not a spent solvent.  The waste stream apparently
only includes the solvent as a contaminant.  As noted in Union
Camp's letter to John D. Taylor of the Georgia Environmental
Protection Division, "the filter cake waste stream consists
primarily of filter aid, unreacted metal oxides, and resinate
product."  Th« listing background document notes,

          th« wastes encompassed by this listing do not
     include waste streams where solvent is a contaminant,
     such that the waste stream is not spent solvent, as
     defined above.  Thus, wastes which contain as consti-
     tuents solvents which are used in the industrial
     process are not included within the scope of this

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                                                                       o 1
     listing.  Nor are these waste streams  hazardous by               § i
     virtue of the mixing rule  (Sec.  261.3(a)(2)(ii )),                 £*
     since • spent solvent is not being mixed  with                     °,®
     another«olid waste  (Listing Background Document,                  «*
     p. 81).                                                           o *
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