Recycled materials hazardous waste determination

The hazardous waste identification process (as discussed in Chapter 1) describes how to determine whether a material is a solid and hazardous waste. How a material is regulated under RCRA (i.e., whether or not it is a solid and potentially a hazardous waste) when it is recycled depends on what type of material it is and what type of recycling is occurring. If the recycled material is not a solid waste, then it is not a hazardous waste and is not subject to RCRA Subtitle C requirements. However, if the material qualifies as a solid and hazardous waste, it is subject to RCRA Subtitle C jurisdiction. 

Hazardous waste identification begins with an obvious point in order for any material to be a hazardous waste, it must first be a waste. However, deciding whether an item is or is not a waste is not always easy. For example, a material (like an aluminum can) that one person discards could seem valuable to another person who recycles that material. U.S. EPA therefore developed a set of regulations to assist in determining whether a material is a waste. RCRA uses the term solid waste in place of the common term waste. Under RCRA, the term solid waste means any waste, whether it is a solid, semisolid, or liquid. The first section of the RCRA hazardous waste identification regulations focuses on the definition of solid waste. For this chapter, you need only understand in general terms the role that the definition of solid waste plays in the RCRA hazardous waste identification process. 

Materials that are recycled are a special subset of the solid waste universe. When recycled, some materials are not solid wastes, and therefore not hazardous wastes, but others are solid and hazardous waste, but are subject to less-stringent regulatory controls. The level of regulation that applies to recycled materials depends on the material and the type of recycling (Figure 13.2). Because some types of recycling pose threats to human health and the environment, RCRA does not exempt all recycled materials from the definition of solid waste. As a result, the manner in which a material is recycled will determine whether or not the material is a solid waste, and therefore whether it is... 

The second step is the modification of the production process, which includes the replacement of the raw material containing hazardous causahties, the optimization of the process, and the t5 e of raw material used. The determination of the sources of leaks and spills in the process, and the separation of hazardous from nonhazardous and recyclable waste should also he considered. The third part is the management of waste including its recycling and reuse. 

The first step of hazardous waste identification is determining whether a material is a solid waste. A solid waste is any material that is discarded. (The modifier solid is not indicative of the physical state of the material. That is, a solid waste may be in the liquid or gaseous phases as well as the solid phase.) A material is considered discarded when it is abandoned, recycled, or inherently waste-like. Abandonment occurs when a material is disposed of burned/ incinerated or accumulated, stored, or treated before, or in lieu of, abandonment. Recycling occurs when a material is used in a manner that resembles disposal (e.g., placed on the ground) burned to recover its energy reclaimed to recover a usable product or accumulated speculatively. In addition, a few specific materials have been designated inherently waste-like (e.g., certain dioxin-containing wastes) and are considered solid wastes when recycled in... 

Mention of trade names or commercial products does not constitute endorsement or recommendation for use by the Agency or the Publisher. Final determination of the suitability of any information or product for use contemplated by any user, and the manner of that use, is the sole responsibility of the user. The book is intended for information purposes only. The reader is warned that caution must always be exercised when dealing with plastic wastes, recycling materials or equipment which might be potentially hazardous, and expert advice should be obtained before implementation of recycling procedures. 

The precursor chemicals should be selected with care because potentially hazardous or toxic vapors may result. The exhaust system should be designed to handle any reacted and unreacted vapors that remain after the coating process is complete. Other waste effluents from the process must be managed appropriately. Retrieval, recycle, and disposal methods are dictated by the nature of the chemical. For example, auxiliary chemical reactions must be performed to render toxic or corrosive materials harmless, condensates must be collected, and flammable materials must be either combusted, absorbed, or dissolved. The extent of these efforts is determined by the efficiency of the process. ... 

---