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): OSWER OSWER CTIVE DIRECTIVE DI EJBD ARCHIVE OSWER Dir ------- Off Of mu’Slv—, - j Pro,c , Solid Wws slid Etnsr 9 vicy NS$p ,i EPA 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 6) — — SWER OSWER OSWER DIRECTIVE DIRECTIVE ------- 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) ------- 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, ------- 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 ------- |