&EPA
                   Environment*! Protection
                   Agency
                Office of
                Solid w««i« md
                Emergency Retoonte
DIRECTIVE NUMBER:  9487.03(85)

TITLE: Clarification of Ban or Disposal of Liquids in
      Landfills
                   APPROVAL DATE:  5-29-85

                   EFFECTIVE DATE:  5-29-85

                   ORIGINATING OFFICE:  office °f s°lid Waste

                   Q FINAL

                   D DRAFT
                     OTATIIC       ^  ^   A~ Pendin§ OMB approval
                     STATUS:           B- Pending AA-OSWER approval
                                        C- For review &/or comment
                                   [  ]   D- In development or circulating

                   REFERENCE (other document*):        headquarters
'E    DIRECTIVE    DIRECTIVE     D

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PARTS 264—265 SUBPART “ — LANDFILLS DCC: 9487.03(85)
Key Words: Liquids Wastes, Landfills
Regulations:
Subject: Clarification of Ban or Disposal of Liquids in Landfills
Addressee: Bernard L. Jones, Project 1anager, GSX Services of South
Carolina, Inc., Route 1, Box 255, Pinewood, SC 29125
Originator: John H. Skinner, Director, Office of Solid Waste
Source Doc: 1/9487.03(85)
Date: 5—29—85
Summary:
This letter reiterates portions of HSWA 85 §300 4 (c) dealing with the disposal
of Liquids in landfills. It also states that chemical stabilization is only
one option for treating bulk liquid hazardous wastes. OSW has developed
other options which are described in this Letter.

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9487.03 (85)
i\Y ; :‘ S
Mr. Bernard L. Jones
Project Manager
GSX Services of South Carolina, Inc.
Route 1. Box 255
Pir ewood, South Carolina 29125
Dear Mr. Jones:
I ant responding to your concern., outlined in your March 26,
1985 lGtter, about Section 3004(c) of the RCRA Amendments dealing
with the ban on disposal of liquids in landfill.. I wish to
clarify a number of poInts that you brought out in your letter.
In your Background section, you state that the law specif-
ically prohibits the use of only biodegradable absorbents titer
February 8, 1986. The law U3004(c)(2)) also prohibits the
disposal of containerized liquid wastes when the liquid, have
been absorbed in materials that release liquids when compressed
as might occur during routine landfill operations.
You also state that by your interpretation, fixation by
direct chemical reaction with any or all waste components is
required for bulk liquid wastes, in order to convert the liquid
to a solid. Chemical stabilization is one option for dealing
with bulk liquid hazardous wastes but not the only option.
Enclosed is a revised guidance memorandum (May 9, 1985) that
the Office of Solid Waste has developed for the bulk hazardous
liquid provision. A copy of an earlier draft was sent to
Mr. Richard Moon. Director of Research and Technical Assistance,
GSX Services, on March 27, 1985.
PCassidy:vh:WH_565E:OSW:rm2lO2M:382—4658:04/17/85:dBkPC# 4

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2
Your sr ecific recornnerv atior.s appear to be generally consis—
tei-it .iith the policies described in the draft mertorartdur . I hope
the enclosed guidance clarifies the Agency’s current approach
toward implementing the new statute. If you should have any
r uegtiofls or comments, please contact Paul Cassidy at 202—382—4682.
Sincerely yours,
John H. Skinner, Director
Office of Solid Waote
Enclosure
cc: Jack Lehman
Kenneth Shuater
Arthur Day
Paul Ca sidy

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