oEPA
              UniMdSt
              Environment*! Protection
              Agency
          OHice of
          Solid Waste ana
          Emergency Respons«
DIRECTIVE NUMBER. 9441.06(84)
TITLE: Regulatory Status of Mixtures of Spent Solvents
    F001-F005
               APPROVAL DATE:  4-10-84
               EFFECTIVE DATE:  4-10-84
               ORIGINATING OFFICE: office of solid waste
               Q FINAL
               D DRAFT
                 LEVEL OF DRAFT
                  DA — Signed by AA or DAA
                  D B — Signed by Office Director
                  DC — Review & Comment
               REFERENCE (other documents):
  OSWER     OSWER      OSWER
VE   DIRECTIVE   DIRECTIVE   Dl

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     261  SUBPART A - GENERAL
                                                DOC:  9441.06(84)
Key Words:

Regulations:

Subject:

Addressee:


Originator:
Solvents, Exclusion

40 CFR 261.31

Regulatory Status of Mixtures of Spent Solvents - F001-F005

Robert J. Nelson, Associate Director, National Paint and Coatings
Association, 1500 Rhode Island Avenue, N.W., Washington, D.C. 20006

Eileen B. Claussen, Acting Director, Characterization and
Assessment Division
Source Doc:   #9441.06(84)

Date:         4-10-84

Summary:

     At present, solvent mixtures are not regulated unless they exhibit one or
more characteristics of a hazardous waste.  However, EPA plans to amend its
regulations to include mixtures in the solvent listing.  The amendment will
regulate spent solvent mixtures when treated, stored, transported, or disposed
of; or when treated, stored, or transported prior to use, reuse, recycle, or
reclamation.

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                                                               9441.06 (84)

                            APR 10  1984
Robert J.  Melson
Associate 'Director
National Paint and Coatings
  Association
1500 Rhode Island Avenue,  N.V7.
Dear Mr.

     This letter responds to your inquiry of March 20 ,  1934,
regarding the regulatory status of mixtures of spent solvents
listed in 40 CFR 261.31 (EPA Hazardous Waste Nos. F001-F005).

     As you correctly stated in your letter, the solvent listirrj
pertains only to the technical grade or pure form of the solvent
Thus, solvent mixtures are not regulated unless they exhibit  one
or more of the characteristics of hazardous waste.  At  this
tirae, however, we are in the process of revising the solvent
listing to include these mixtures.  We expect to propose an
amendment by early next year.  When this rule is promulgated,
spent solvent mixtures will oe regulated when treated,  stored,
transported, or disposed of.? and when treated, stored,  or
transported prior to use, reuse, recycle or reclamation.
However, pursuant to- the new proposed definition of solid
waste, certain recycling/reclamation activites will be  exempt
from regulation.  As a practical matter, this means that
solvents (and solvent mixtures) that are reclaimed either
under certain batch tolling arrangements or on-site by  the
generator for use as a suostitute for the commercial product
will oe exempt from regulation.  (See PR 14472-14512, April 4,
1933, for details.)

     Should you have further questions or require additional
information, feel free to contact Jacqueline Sales, of  my staff,
at (202) 382-4770.

                        Sincerely yours,
                       Eileen H. Claussen
                        Acting Director
       Characterization and Assessment Division (WH-5623)

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