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:


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 Source  Doc:

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 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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