Does your site generate a recoverable waste you think should be excluded from RCRA treatment?
If so, it doesn’t hurt to make a case for it to EPA.
The agency allowed Blanchard Refining in Texas City to de-list residual solids it generates by reclamation of oil-bearing hazardous secondary materials (OBSMs).
The solids are F037 (primary oil/water/sludge) when reclaimed from OBSMs.
EPA agreed the solids aren’t hazardous and can be sent to a municipal solid waste landfill without the refinery having to comply with Resource Conservation and Recovery Act (RCRA) guidelines.
Other companies have alleviated RCRA duties for recoverable wastes, including Illini Environmental last year. Here is that story:
Commercial facilities can alleviate significant costs and compliance work if they don’t have to manage byproducts as hazardous waste.
EPA answered two facilities’ Resource Conservation and Recovery Act (RCRA) questions about their fuel wastes:
1) Illini Environmental asked if it could treat gasoline-contaminated water as a recoverable chemical product if the water contains more than 0.5 parts per million of benzene and has no free product.
EPA’s answer: Since the water can’t be re-sold or re-used, it’s still a hazwaste. No RCRA Section C exemption here.
2) VMS Environmental Development asked if biomass-derived fuel (BDF) made from solid waste qualifies as a nonhazardous secondary material (NHSM) if it’s used in a coal-burning unit.
EPA’s answer: If the BDF’s moisture content is 2% or lower and has an ash content of 25% or less (both verified by daily composite sampling), then it qualifies as an NHSM.