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I <br />0 0 VN # 4 4 (0 <br />-----Original Message ----- <br />From: Charles Corcoran [mailto:CCorcora@dtsc.ca <br />Sent: Tuesday, April 27, 2004 5:19 PM <br />To: Anna Nguyen <br />Subject: RE: Wax <br />No. <br />This fact defines the material as a "secondary material" and, also as a <br />"waste" pursuant to 22 CCR 66261.2(d)(2)(A)(2), and a "solid waste" <br />pursuant to 40 CFR 261.2(c)(2)(B). Note, under the federal scheme the <br />material may be a byproduct, but the "use to produce a fuel" overrides <br />the exemption for "characteristic byproducts which are reclaimed." <br />This is, as I expected, consistent with my presumption regarding the <br />ultimate fate of the material. <br />That means you should document that <br />State or federal characteristic of <br />that determination in its files. <br />rles <br />the material does not exhibit any <br />a HW and the generator should retain <br />>>> "Anna Nguyen" 4/27/2004 4:54:15 PM >>> <br />Thank you, Charles, for your prompt reply and thorough analysis. Your <br />assumption are all correct. As to the fate of the waste wax, the waste <br />wax is ultimately sent to a recycler and eventually blended with waste <br />oils to create a fuel that can be burned in lieu of diesel or bunker <br />oil. Doesn't this fact also point a conclusion of non -hazardous waste? <br />-----Original Message ----- <br />From: Charles Corcoran [mailto:CCorcora@dtsc.ca.gov] <br />Sent: Tuesday, April 27, 2004 4:18 PM <br />To: Anna Nguyen <br />Subject: Wax <br />Hi. Here is the best I can do given the limited information I have. <br />The material in question is some sort of petroleum-based wax that is <br />generated from the manufacturing of artificial fireplace logs. Your <br />question is: "Would this wax be identified and regulated as hazardous <br />waste?" <br />In order to determine if the material (hereafter referred to as "wax") <br />were a solid waste or waste, one would have to know the fate of the <br />material. As we did not discuss the ultimate fate of the material, I <br />have presumed the wax will ultimately be disposed or will be burned, in <br />lieu of disposal. Based upon this presumption, the wax would be <br />identified as a waste and as a solid waste. <br />If it truly were a waste, to be identified as a hazardous waste, the <br />wax would have to exhibit at least one federal or state characteristic <br />of a hazardous waste, or be/contain a listed hazardous waste. For <br />