Full Document:
RCRA Online Number: 14095
Title: REGULATORY DETERMINATION ON THE STATUS OF CERTAIN MANUFACTURING WASTES
Document Date: 1997-07-24
To: Colby
From: Bussard
Organization of Recipient: Colby and Nance
Description: Warfarin tablets meeting a commercial chemical product (CCP) listing are still considered listed CCPs when tested by crushing or dissolving. The de minimis mixture rule exclusion in Section 261.3(a)(2)(iv)(D) applies to discharges of CCPs from rinsing and cleaning personal protective equipment (PPE). Discarded equipment meeting the definition of debris which is contaminated with a listed waste must be managed as a hazardous waste (HW) until it no longer contains the HW. Contaminated equipment can be washed using the alternative debris treatment standards to the point where it is no longer considered to contain a HW. Whether air filters from a manufacturing process meet a listing depends on site-specific factors. Air filters used in the production of a P or U listed commercial chemical product (CCP) do not fall within the scope of the Section 261.33 listings prior to the material (warfarin) becoming a CCP. Once the material meets the listing description (becomes a CCP), particles captured in the filters are a listed CCP when disposed (USE WITH CAUTION: see 56 FR 7200; 2/21/91). Air filters are regulated as a solid waste mixed with a listed hazardous waste. Air filters may qualify as hazardous debris and may be washed so as to no longer contain a listed hazardous waste.
Regulatory Citation(s): 261.3(a)(2), 261.3(f)(1)
RPPC Number: 9441.1997(06)
Official ORCR Policy: Yes
Associated Topic(s):
Chemicals (RCRA),
Chemicals (RCRA),
Hazardous Waste,
Land Disposal Restrictions,
P-wastes,
Treatment,
U-wastes |