v>EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
9444.03(83)
DIRECTIVE NUMBER:
' Hazardous Wastes From Solar Cell and High Tech Industries
APPROVAL DATE: 7-20-83
EFFECTIVE DATE: 7-2°-83
ORIGINATING OFFICE: Office of Solid Waste
0 FINAL
D DRAFT
STATUS:
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A- Pending OMB approval
B- Pending AA-OSWER approval
C- For review &/or comment
D- .In development or circulating
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REFERENCE (other documents):
OSWER OSWER OSWER
fE DIRECTIVE DIRECTIVE
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PART 261 SUBPART D - LISTS
DOC: 9444.03(83)
Key Words:
Regulations:
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Generators, High Tech Wastes, Characteristics of Hazardous Waste
40 CFR Part 261, Subparts C and D
Hazardous Wastes From Solar Cell and High Tech Industries
Leland Modesitt, Director, Office of Legislation (A-103)
John Skinner, Director, Office of Solid Waste
#9444.03(83)
7-20-83
Not all wastes generated from the production of high technology devices
(solar cells, transistors, integrated circuits, etc.) should be considered
hazardous. The determination is made in one of two ways. In one case, the
Agency has listed certain wastes as hazardous including: §261.31-wastes from
non-specific sources; §261.32-wastes from specific sources; and §261.33-
discarded commercial chemical products.
In another case, a waste is hazardous if it exhibits one of the charac-
teristics of a hazardous waste (ignitability, corrosivity, reactivity, and EP
toxicity). Under §261 Subpart C, each generator is responsible for determining
whether his waste exhibits any of these characteristics. If so, the facility
will be deemed a generator of hazardous waste, and the waste must be managed in
accordance with the hazardous waste management regulations.
For further information on this matter, please do not hesitate to contact
Matthew Straus at 475-3551.
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9444.03 (83)
MEMORANDUM REl WCBLG2016
Subjects Hazardous Wastes from Solar Cell
and High Tech Industries
From: John Skinner, Director
Office of Solid Waste (WH-562)
Toi Leiand Modesitt, Director
Office of Legislation (A-103)
In response to your inquiry for follow-up with
Senator Burdicfc's staff, the production of solar cells and
other high technology devices (transistors, integrated circuits),
involves a variety of manufacturing processes and can include
the use of industrial solvents and metal treatment. Hazardous
wastes generated from these operations include electroplating
wastewater treatment sludges that contain cyanides and heavy
vo metals that are toxic or reactive* spent solvents that are
£ toxic or ignitable; and discarded commercial chemical products
(N or manufacturing chemical intermediates that are also toxic
^ or reactive.
w However, this does not mean all wastes generated from
o the production of high technology devices should be considered
hazardous. The determination as to whether or not a waste
r is considered hazardous is made in one of two ways. In one
g ease, the Agency has listed certain wastes as hazardous
~ under 40 CFR 261, Bubpart D ($261.31 wastes from non-specific
r- sources; |2<1«32 — wastes from specific sources; f261.33 -
£ discarded oossssrcial chemical products). In another case, a
,1, wsste is hazardous if it exhibits one of the characteristics
GO of a hazardous waste (i.e., ignitability, corrosivity, reactivity,
1! and IF toxioity). Cinder 40 CPU 261 Subpart C, each generator
« is responsible for determining whether his wsste exhibits
s§ : -~ :
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