3EPA
United St
Environmental Protection
Agency
Off ice of
Solid Waste and
DIRECTIVE NUMBER: 9443.08(84)
TITLE: Designation for Waste Ink and Solvent Mixtures
Generated from Printing Facilities
APPROVAL DATE: n-23-84
EFFECTIVE DATE: 11-23-84
ORIGINATING OFFICE: office of Solid Waste
E FINAL
:D DRAFT
LEVEL OF DRAFT
DA — Signed by AA or DAA
D B — Signed by Office Director
D C — Review & Comment
REFERENCE (other documents):
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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'PART 261 SUBPART C - CHARACTERISTICS
DOC: 9443.08(84)
Key Words:
Regulations:
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Solvents
40 CFR 261.31
Designation for Waste Ink and Solvent Mixtures Generated from
Printing Facilities
Donald Dean, Environmental Manager, Imperial Manufacturing
Company, Underwood Avenue, P.O. Box 280, Plattsburgh, N.Y. 12901
Eileen Claussen, Characterization and Assessment Division,
Office of Solid Waste
#9443.08(84)
11-23-84
Waste inks containing solvents generated from printing facilities are
considered hazardous if they exhibit one or more of the characteristics of
hazardous waste (i.e., ignitability, reactivity, EP toxicity, and corrosivity).
Waste ink containing MEK, MIBK, toluene, xylene, and acetone will probably
exhibit ignitability and should be designated as EPA Hazardous Waste No. D001.
Solvent mixtures from the cleaning of pumps, lines, and tanks at printing
facilities are not- currently covered by the solvent listings in 40 CFR 261.31.
They are hazardous if they exhibit one or more of the characteristics of
hazardous waste. In authorized States, however, the State rules, rather than
the Federal rules, apply.
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9443.08
— m
> ^
NO/ 2 3 -
(i.e., ignitability , reactivity, EP toxicity and corrosivity) . i
In'your particular case, waste ink containing HEK, MIBK, toluene, ^
xylene, and acetone will probably exhibit ignitability . Should «
this be the case, these wastes arc doomed hazardous waste and,
as such, should be designated as EPA Hazardous Waste Number 0001.
Solvent mixtures from the cleaning of punps, lines and
tanks, as described in your letter, are not currently covered by
the solvent listings in 40 CPR 261.31. Therefore, they are
hazardous wasto only if they also exhibit one or more "of the
characteristics of hazardous waste. Within the next few months,
the Agency will propose to amend the listing to include certain
solvent mixtures. Thus, many of these solvents will be brought
under Subtitle C control.
If your waste management activities occur in a State that
has been authorized under RCRA, then the State rules, rather than
the Federal rules, apply.
We recommend that you consult with the appropriate States
to determine whether they in.torpret their listing as covering
solvent mixtures. Agency data indicate that New York State
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interprets thoir listing as applying.to solvent mixtures as well
as single solvents. In addition, it is within the authorized
State's discretion to determine the appropriate classification
for wastes thflt«are both listed and exhibit a characteristic.
Should you have questions, or require additional information,
please contact Jacqueline Sales, of ray staff, at (202) 382-4807."
Sincerely,
Eileen Claussen
Characterization and Assessment Division
Office of solid Waste
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