oEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9487.05(85)
TITLE; Use of Absorbents for Containerized Liquid
" Hazardous Wastes
APPROVAL DATE: 9-20-85
EFFECTIVE DATE: 9-20-85
ORIGINATING OFFICE: office °f s°iid
E FINAL
D DRAFT
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STATUS: B- Pending AA-OSWER approval
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[ ] D- In development or circulating
REFERENCE (other documenu): headquarters
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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'PARTS 264-265 SUBPART N - LANDFILLS
DOC: 9487.05(85)
Key Words: Containers, Absorbents
Regulations: 40 CFR 264.314, 265.314
Use of Absorbents for Containerized Liquid Hazardous Wastes
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Robert M. Pyle, President, MPF Services Incorporated,
112 West 9th Street, Suite 615 Los Angelas, California 90015
John P. Lehman, Director, Waste Management and Economics Division
#9487.05(85)
9-20-85
This letter clarifies the use of absorbents for containerized hazardous
wastes. Pursuant to requirements in 3004/(c)(2) of HSWA, EPA will promulgate
regulations prohibiting the disposal of liquids that have been absorbed in
materials that biodegrade or that release liquids when compressed.
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9487.05 (85)
SEP 20 !985
Mr. Robert H. Pyle
President
MPF Services Incorporated
112 West 9th Street, Suit* 915 £
Los Angelos, California 90015 1
w
Dear Mr. Pylet ^
••
This is in response to your letter of August 29, 1985, £u
requesting clarification of the use of absorbents for •£
containerised liquid hazardous wastes. "o
••
IT)
The RCRA Hazardous and Solid Waste Amendments of 1984 (see ^
Section 3004(c)(2) attached) require that not later than 15 months <*
after the date of enactment (February 8, 1986), the Administrator \
shall promulgate final regulations which minimize the presence of ^
free liquids in containerized hazardous waste to be disposed ot «
in landfills* The regulations shall also prohibit the disposal
the use of absorbents nor do they restrict the type of absorbent >•
that can be used. I do wish to point out that, and although not !2
prohibited in the current regulations, the Agency strongly advises j°
against the use of biodegradable absorbents such as shredded paper a
or sawdust. We believe that good management practices should not ^
allow biodgradable absorbents to be used because of their ability
to degrade and release liquids and hazardous constituents. Like-
wise, we believe absorbents that do not have structural stability
(i.e., that behave like a sponge and release liquids under
pressures found in a landfill) should not be used.
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The last point on which you requested clarification concerned
the substance of the final regulations to be published by the
Agency to implement S3004(c)(2). Section 3004(c) (2) requires BPA
to 'prohibit the disposal in landfills of liquids that have been
absorbed in materials that biodsgrads or that rsl«as* liquids
whsn coaprssssd as might occur during routlas landfill operations*
Clearly, Congress intsnded to allow the uSe of acceptable physical
treataent under I3004(c)(2) for containerised liquids as contrasted.
to the chenieal treataent laplied by the requirement in S3004U) (1)
for bulk hasardous liquid wastes* It appears, at this ti»e, that
the final regulations for |3004(e)(2) will not require chemical
treatment of containerised liquids. . ' • .
Thank you for your intsrest in this issue. Should you
have additional questions, please contact Mr* Paul Cassidy at
(202) 302-4682. .
Sincerely,
John P. Lehman
Director
Waste Management and
Economics Division
Attachments
bees Ken Shuster
Art Day
Paul Cassidy
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