Memo Detail

Full Document:PDF Link
RCRA Online Number: 11471
Title: OFF-SPEC COMMERCIAL CHEMICAL PRODUCTS AT BOTTLING FACILITY
Document Date: 1989-09-28
To: Simon, HQ
From: Barnes
Organization of Recipient: EPA
Description: Product solvent that is discarded because it was contaminated with another product while being containerized is an off-specification CCP and is a P-listed or U-listed waste if the solvent is listed in 261.33. RCRA waste codes and regulations applicable to wastes do not necessarily correspond to DOT hazardous material descriptions. Wwastes are defined as hazardous under RCRA, in part, based on characteristics, such as ignitability (D001) and corrosivity (D002).
Regulatory Citation(s): 261.21, 261.22, 261.33
RPPC Number: 9441.1989(49)
Official ORCR Policy: Yes
Associated Topic(s): Characteristic Wastes, Chemicals (RCRA), Containers, Corrosive Wastes, Hazardous Waste, Solvents