PA
                United States
                Environmental Protection
                Agency
            OH.ce of
            Solid Waste ana
            Emergency Response
DIRECTIVE NUMBER: 9441.23(85)

TITLE: Disposal Requirements of Scrap DEHP and Small
     Capacitors Containing DEHP
                 APPROVAL DATE:  6-27-85

                 EFFECTIVE DATE:  6-27-85

                 ORIGINATING OFFICE: office of solid waste

                 13 FINAL

                 D DRAFT

                   LEVEL OF DRAFT

                     DA — Signed by AA or DAA
                     OB — Signed by Office Director
                     DC — Review & Comment

                 REFERENCE (other documents):
  OS WER       OS WER       OS WER
VE    DIRECTIVE    DIRECTIVE    Dl

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261 vSUBPART A - GENERAL
                                                DOC:  9441.23(85)
Key Words:    Characteristics of Hazardous Waste, Exclusion, Listing

Regulations:

Subject:
Addressee:


Originator:

Source Doc:

Date:

Summary:
Disposal Requirements of Scrap DEHP and Small Capacitors
Containing DEHP

N. Ray Clark, Universal Manufacturing Corp., 200 Robin Road,
Paramus, New Jersey 07652

Matthew A. Straus, Chief, Waste Identification Branch

#9444.23(85)

6-27-85
     Contaminated or unusable DEHP that becomes a waste generated in the normal
course of the manufacturing process must be disposed of according to the RCRA
hazardous waste rules.

     Capacitors unusable for electrical or mechanical reasons are not defined
as a listed hazardous waste and would only be hazardous if they exhibit one or
more of the characteristics of a hazardous waste.

     Miscellaneous solid materials that absorbed some DEHP would be listed as
hazardous if they became contaminated as a result of waste management activities
but would not be listed as hazardous if they became contaminated as a result of
use during the manufacturing process.

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                                                               3441.23 (85)
                                      27 iS85
Mr. N. Ray Clark
Universal Manufacturing Corp.
200 Robin Road
Parami*/ New Jersey  07652

Dear Mr. Clarks

     This letter ia in response to your letter datttd April
30, 1995* regarding the diapoaal requirements of scrap  (off"
specification) DBHP and small capacitors which contain  OEHP.
first* 1st me apologise for taking so long in getting back to
youi I have been very busy and hope my delay has not created
a problem for you.  Concerning your specific questions, I
generally agree with the answers given by Mr. Travis Wagner
of the RCRA Hotline.  More specificallyi

     •  Contaminated or unusable DEHP which is generated in
        the normal course of the manufacturing process  and
        becomes a waste which must be disposed of  is subject
        to the RCRA hasardous waste rules (i.e., if shipped-
        off-site must be manifested, must go to a  facility
        with interim status or one which is fully  permitted,
        etc.)

     *  Capacitors which are found to be unusable  for
        electrical or mechanical reasons are presently  not  •
        defined as a listed hasardous waste (i.e., U028)-.
        Therefore, these wastes would only be hazardous if
        they exhibit one or more of the hasardous  waste
        characteristics (i.e., ignltabillty, corrosivity,
        reactivity, or extraction procedure (EP) toxicity).

     With roffMOi to your third question, you ask whether rags,
gloves, chipbMNPd, and other miscellaneous solid materials
which have aismmrtood some DEHP are RCRA hasardous wastes.  The
answer to tmisv sjmestion is yes and no* that is, if the  solid
material has bmoome contaminated as a result of waste management
activities 
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                        , however, woold be a hazardous wastes
                        the characteristics of hazardous wastes.

           	,       *«• ai*« »• a call if i can be of any
 further:a»a\UtaBC
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