Memo Detail

Full Document:PDF Link
RCRA Online Number: 11348
Title: CHLORDANE AND HEPTACHLOR PESTICIDE WASTE
Document Date: 1988-05-03
To: Wayland, HQ
From: Lowrance
Organization of Recipient: EPA
Description: CCPs (pesticides) must be discarded or intended for discard to be P- or U-listed hazardous waste. Materials are "discarded" when abandoned, applied to the land, or used to produce a fuel. Products containing small amounts of other chemicals as manufacturing impurities still have a sole ingredient. There is no percentage cutoff for active ingredient. An active ingredient performs the function of a product. Fillers, carriers, and propellants are not active ingredients. Chlordane product (U036) that contains small amount of heptachlor (P059 if CCP) has only one active ingredient (chlordane) because heptachlor is a manufacturing impurity. Technical grade means all commercial grades of chemical. There is no exact criteria define technical grade. Product purity varies from compound to compound.
Regulatory Citation(s): 261.2(b), 261.2(a), 261.33(d)
RPPC Number: 9444.1988(10)
Official ORCR Policy: Yes
Associated Topic(s): Burning, Chemicals (RCRA), Combustion of Hazardous Waste, Hazardous Waste, P-wastes, U-wastes