United States Office of
Environmental Protection Solid Waste and
Agency Emergency Response
&EPA DIRECTIVENUMBER: 9432.00-1
TITLE: Totally Enclosed Treatment Facilities Exemption
for Bag House Sludge
APPROVAL DATE: 2-11-86
EFFECTIVE DATE: 2-11-86
ORIGINATING OFFICE osw
FINAL
o DRAFT
STATUS:
REFERENCE (other documents):
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CTIVE DIRECTIVE DI
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DIRECTIVE NUMBER:
TITLE:
Totdlly Enclosed Tre tment Facilities Exemptjo 11
for Bag House Slu g’
APPR OVAL DATE:
EFFECTIVE DATE:
US EPA
ORIGINATING OFFIC adqua,.ters and Chemical Libraries
Q FINAL EPA West Bldg Room 3340
Mailcode 3404T
o DRAFT 1301 Constitution Ave NW
Washington DC 20004
STATUS: 202-566-0556
REFERENCE (other documents) epOSitOry Matena
Permanent Col’ection
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SWER OSWER OSWER
DIRECTIVE DIRECTIVE

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United States Environmental Protection Agency
Washington, DC 20460
EPA OSWER Directive Initiation Request
Originator Information
Interim Directive Number
9432.00-1
Name of Contact Person Mail Code
WH—565 A
Teleprtone Number
382—2550
Approved for Review
Date
Title
or
Totally Enclosed Treattnettt Facilities Exemption for Bag House Sludge
Summary of Directive
Treatment of EP tuxiL bag hous.e sludge is nut exempted by the totally
enclosed treatment facilities exempLiou. The exemption covers facilities
that are directly connected to industrial production processes thdt do not
release hazardous wdste to the environment. As the system is currently
set up, the bag hoi se is not directly connected to the cupola melting scrap,
so it does not meet the direcL connection criterid since the bag house is a
waste treatmenL unit. ixing with beLltouite clay would be treatment that
needs a peimit as currently et up. Reclaiming the EP toxic dust would not
be handling a solid waste accoiding to the definition of solid waste, so t i.e
company may want to explore that waste management alternative instead.
Type of Directive (Manual. Policy Directive. Announcement, arc) Status
Memorandum to Region V Solid Waste Branch Chief Draft New
Final 0 Revision
Does this Directive Supersede Previous 0irective s)? Yes No Does It Supplement Previous Directive s)) Yes No
If “Yes” to Either Ouest,on. What Directive (number, title)
Review Plan
0 AA -OSWER 0 OUST 0 OECM 0 Other(Specify)
0 OERR 0 OWPE OGC
0 OSW 0 Regions 0 OPPE
This Request Meets OSWER Directives System Format
Signature of Lead Office Directives Ofli er
Date
Signature of OSWER Directives Officer
Date
EPA Form 1315-17(10-85)

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O 974
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
____ WASHINGTON, 0 C 20460
p t$’
J,.i )F
FEB I SiLO W. 3rE ii E1GE
OSWER Directive # 9432.00—1
MEMORANDUM
SUBJECT: Totally Enclosed Treatment
FROM: Marcia Williams, Director
Office of Solid Waste (WH—562)
TO: David Stringham, Chief
Solid Waste Branch, Region V
5HS—JCK—13
This is the regulatory clarification you requested on
December 30, 1985 for the application of the totally enclosed
treatment facility exemption to a tank treating emission control
dusts at a scrap metal recycler. The system you describe is not
totally enclosed because of the reasons given below.
Your description of the Grede foundry indicates that it
heats scrap in a cupola. Emissions from the cupola rise into a
hood which is connected to a baghouse via ducts. Ms. Randi Kim
of your staff pointed out that hazardous waste is not generated
prior to the baghouse unit, and the hood is not directly connected
to the cupola. The emission control sludge captured in the
baghouse is EP toxic for lead, and possibly chromium, according
to Jim Roberts of the Michigan Department of Natural Resources.
Grede Foundries proposes to directly connect a mixing tank to the
baghouse by pipeline where the dust will be rendered nonhazardous
by mixing with nonhazardous foundry waste sands and dusts contain-
ing bentonite clay. Since the mixing tank does not exist, we
cannot determine whether the tank can technically prevent release
of hazardous waste into the environment during treatment through
use of traps, recycle lines, etc. Therefore, the central issue
you raise is whether the mixing tank can be considered directly
connected to the industrial production process, satisfying one
condition of a totally enclosed treatment facility as defined in
§260 .10.
The definition in §260.10 of totally enclosed treatment
facilities specifies that the treatment must be directly connected
to an industrial production process. In your foundry example,

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2
the cupola is part of the industrial production process, since it
produces reusable metal; and the baghouse is part of the waste
treatment process, since the sludge is not associated with product
or raw materials, i.e., the sludge is disposed of, not recovered
for further recycling. Therefore, the treatment that occurs
downstream of the baghouse cannot qualify for a totally enclosed
treatment exemption, since the cupola is open to the air before
the hood. collects the dust.
Although our preliminary information indicates that adsorption
to clay can be an acceptable treatment method, you should pursue
the question of whether the specific clay adsorption process pro-
posed for this facility will provide the effective treatment that
would allow it to be permitted as a treatment facility. Canton
Wiles, ORD/Cincinnati, FTS 684—7871, may be able to provide you
with further guidance on clay adsoption treatment standards that
should be incorporated into the treatment permit to assure effective
treatment.
With alternate management practices, the emission control
sludge would not be defined as a solid waste, and, therefore, would
not be a RCRA hazardous waste. If the fines were returned to the
cupola for metal recovery, the entire process would be viewed as
closed loop recycling, and the baghouse sludge would not be con-
sidered to be a solid waste according to §261.2(e)(1)(iii). [ f the
sludge were reclaimed elsewhere, it also would not be considered
to be a solid waste, according to §261.2(c)(3). Sludges being
reclaimed are not considered to be solid waste unless specifically
listed by EPA, and this particular sludge is not so listed.
Alternatively, the system could be engineered differently.
By connecting the hood directly to the cupola, the system could
then meet the criteria for being directly connected to an
industrial production process. The system may then qualify
as a totally enclosed treatment system if the treatment met
the technical standards for being closed to the environment.
Since mixing the baghouse dust with bentonite clay as
described would require a RCRA permit for treatment, Grede
Foundries may wish to pursue one of these other approaches that
are not regulated under RCRA. According to data from the 1981
mail survey, many waste streams of K061 and K069 sludge are
recycled both on and off site, so Grede may find that recycling
is a cost effective management strategy. If you have any ques-
tions about this matter, you can contact Irene Homer of my staff
at FTS 382—2550.
cc: Solid Waste Branch Chiefs
Regions I—IV and VI—X
Jim Roberts, Michigan DNR

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