🚀 go-pugleaf

Can anyone tell me what the technical
term/classification/gender? or whatever would be applied to
the following:

The office of Solid Waste in DC wrote a letter to various
parties who had requested an exemption be given to a form of
treatment of hazardous waste which they (the solicitors)
wished to carry out in a particular industry.

The treatment was evaporation of wastewater classified as
hazardous not only because of 'derived from rule' but also
because of its toxicity characteristic.  The OSW wrote
stating that "based on information supplied by.........., we
feel that these evaporators meet the definition of
"wastewater treatment unit" under RCRA. Therefore, these
units would not require RCRA permits, provided the criteria
for qualifying as a wastewater treatment unit outlined in 40
CFR Section 260.10 are met."

What would this opinion be called? Is it as meaningful as
opinions expressed in FR?   Have the individual states
descretion to accept or reject this 'opinion'.  May the
validity be questioned?

Thanks for any help on this.
egion X BBS