Full Document:
RCRA Online Number: 14102
Title: REGULATORY STATUS UNDER RCRA OF COPPER ETCHANTS
Document Date: 1996-10-24
To: Weiner
From: Cotsworth
Organization of Recipient: Heller, Ehrman, White, and McAuliffe
Description: Spent copper etchants used as ingredients in the production of tri-basic copper chloride (TBCC) are not solid wastes under the use/reuse exemption unless the etchants are being reclaimed. Mixing residue from TBCC manufacturing with additional chemicals to produce fresh etchant is not exempt use/reuse if the activity involves reclamation. If both activities are steps in one industrial process, reclamation in the second step (fresh etchant production) would disqualify the whole process from the use/reuse exemption. A determination on whether these operations are one industrial process or two sequential processes is site-specific.
Regulatory Citation(s): 261.2(e)(1), 261.1(c)(5)
RPPC Number: 9442.1996(03)
Official ORCR Policy: Yes
Associated Topic(s):
Hazardous Waste,
Hazardous Waste Recycling |