oEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9444.18(84)
TITLE: Listing of Spent Cartridges Containing Per-
chloroethylene from Dry Cleaning Establishments
APPROVAL DATE: 10-4-84
EFFECTIVE DATE: 10-4-84
ORIGINATING OFFICE: office of solid waste
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VE DIRECTIVE DIRECTIVE Di
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PART 261 SUBPART D - LISTS
DOC: 9444.18(84)
Key Words:
Regulations
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Solvents, Small Quantity Generator
40 CFR 261 -
Listing of Spent Cartridges Containing Perchloroethylene from
Dry Cleaning Establishments
Gary A. Edelstein, Hazardous Waste Management Section, Wisconsin
Department of Natural Resources, 101 S. Webster Street, 6EF 11,
Box 7921, Madison, WI 53707
Jacqueline W. Sales, Environmental Engineer
#9444.18(84)
10-4-84
Solvent listings (F001-F005) include the sludge or residue from the recovery
of these solvents. Filter cartridges used to recover spent perchloroethylene
(F002) from dry cleaning processes are considered as listed waste when spent
or discarded, because they are residue from the recovery. The cartridge is
not viewed as a container, but as an integral component of the waste. The
weight of the entire cartridge is considered in determining whether the small
quantity generator exclusion applies.
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9444718^(84)
iset
Gary A. Edelstein
Hazardous Waste Management Section
Wisconsin Department of
Natural Resources
101 S. Webster St., SEP 11
Box 7921
Madison, Wisconsin 53707
Dear Gary:
This letter responds to your request (September 26, 1984)
for confirmation of our recent conversation regarding spent
filter cartridges-from dry cleaning establishments. As wt?
discussed, spent cartridges containing perchloroethylene are a
listed hazardous waste (i.e., EPA Hazardous Waste No. F002).
The following section explains both the rationale for this
determination and the manner in which small quantity generator
status is determined.
The Agency interprets the solvent listings (F001-F005)
to also include sludge or residue from the recovery of these
solvents (in addition to spent solvent and still bottoms from
the recovery of these solvents). Filter cartridges which are ••
used to recover spent perchloroethylene (F002) from dry
cleaning processes are considered the listed waste, when spent
or discarded, because they are the residue from this recovery.
The Agency does not view the cartridge as a "container,"
rather the Agency considers it an integral component of the
waste; thus, the entire cartridge is a hazardous waste. For
example, spent lead-acid batteries typically are deemed
hazardous waste because they exhibit the characteristics of
corrosivity and EP toxicity. In making this determination,
the entire battery (including the casing) is considered the
waste. Data show that in several cases where empty battery
casings have been disposed of improperly, environmental damages
have resulted. The Agency views spent filter cartridges in
the same manner and^therefore believes that t-hey may pre^^n*-
an identical hazard when land1 disposed or improperly man-. ,-••!.
Based on this interpretation of the regulations, as they
they pertain to spent filter cartridges, the weight of the
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entire cartridge is considered in determining whether the
small quantity generator exclusion applies. -
I trust this explanatory letter adequately addresses
your inquiry. I have conferred with Irene Horner (a former
KCRA hotline staff member) whose expertise has shed significant
light on this issue. If" you have questions or require further
explanation, please call roe at (202) 382-4807six.
, ' "*
Sincerely yours,
Jacqueline W. Sales
Environmental Engineer
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