Memo Detail

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RCRA Online Number: 14609
Title: REGULATORY STATUS OF CRUDE SULFATE TURPENTINE (CST) UNDER RCRA
Document Date: 2002-08-08
To: Wasserstrom
From: Cotsworth
Organization of Recipient: American Forest & Paper Association (AFPA)
Description: Crude sulfate turpentine (CST) is not a solid waste when it is burned for energy recovery because it is a commercial chemical product (CCP) that is itself a fuel (SEE ALSO: 50 FR 14219; 4/11/85). EPA rejected using turpentine as a benchmark fuel in establishing comparable fuel specifications, since CST is not widely used as a fuel (SEE ALSO: 63 FR 33782, 33785; 6/14/99). CST contains hydrogen sulfide that can pose health risks, thus it should be managed in accordance with applicable OSHA standards.
Regulatory Citation(s): 261.2(c)(2)(B)(ii), 261.33
Official ORCR Policy: Yes
Associated Topic(s): Burning, Identification of Hazardous Waste