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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