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

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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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