printreg,July,2004Recycling Haz Waste

printreg, July, 2004
Recycling Haz Waste

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From:Debra Jacobson(
Date:Wed, 14 Jul 2004 11:23:03
The following is a discussion about the RCRA regulations for on-site haz. waste recycling activities. Keep in mind that many state and local governments require equipment operating permits and operator training and certification for these (and other similar) types of equipment.
Deb Jacobson


RCRA 40 CFR 261.6

Recycling Hazardous Waste Many generators are under the impression that to recycle their hazardous waste on-site would require a RCRA permit. They would like to use a distillation unit or other type of recycling process to reclaim their wastes for further use, but they consider the permit application process to be time and cost prohibitive.

In fact, recycling of hazardous waste is less restricted than many people think. According to 40 CFR 261.6, generators can recycle their own hazardous wastes on-site without a permit if they comply with applicable rules while accumulating the waste prior to recycling, including any on-site accumulation time limits:

1. The recycling process itself is exempt from RCRA regulations. see 40 CFR 261.6(c)(1)

2. This can result in significant reductions in (a) waste disposal quantities and costs, (b) product purchasing costs, and (c) generator status [40 CFR 261.5(d)(3)]

3. As an added bonus, if the hazardous waste is hard piped directly to the recycling unit, instead of being stored in containers or tanks initially, it need not be counted toward generator status, not even the first time it is generated. [40 CFR 261.5(c)(3)]

4. Certain types of recycling units are subject to 40 CFR Part 265, Subparts AA and BB to control the organic emissions [40 CFR 261.6(d)], and generators must ensure they comply with other regulations that may affect this process, such as any Clean Air Act and Alcohol, Tobacco, and Firearms regulations for the operation of a distillation unit. [27 CFR Part 29]

40 CFR 261.6(c)(1) states that facilities that store recyclable materials before they are recycled must comply with all applicable TSDF regulations, including permitting. What this means to a generator is that while storing the hazardous waste prior to recycling, all generator management rules must be followed, including any applicable time limits (e.g., 90 days for large quantity generators and 180 days for small quantity generators; there are limited provisions that allow an extension in these time limits). A permit would only be required if you exceeded these time limits or accepted waste from off-site.

A hazardous waste generator can recycle his own hazardous waste on-site without a RCRA permit. The actual recycling process itself is excluded from regulation, with the possible exception of the need to comply with the air emission standards at 40 CFR 265 Subparts AA and BB.

Supart AA:

Subpart BB:

Source: "reg of the day" listserv operated by Tammy Silverthorne @ the Environmental Resource Center

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