40 cfr 261.4(a)(11) The splash condenser dross residue exclusion from definition as a solid waste
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The Splash Condenser Dross Residue for Recycling Exclusion from Regulation as a Solid Waste 40 CFR 261.4(a)(11) excludes Splash Condenser Dross Residue recycled for its zinc content from regulation as a solid waste - and thus as a hazardous waste - if the requirements of the regulations are met. This presentation briefly summarizes the requirements of this RCRA exclusion from regulation.
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40 cfr 261.4(a)(11) The splash condenser dross residue exclusion from definition as a solid waste
- 1. 40 CFR 261.4(a)(11) @DanielsTraining 1 EXCLUSIONS FROM REGULATION AS SOLID WASTE One presentation in a series that briefly explains the Federal exclusions from full regulation for certain materials under the Resource Conservation and Recovery Act (RCRA). This presentation: 40 CFR 261.4(a)(11): Splash Condenser Dross Residue
- 2. 40 CFR 261.4(a)(11) @DanielsTraining 2 PRESENTED BY: Daniels Training Services 815.821.1550 www.DanielsTraining.com Info@DanielsTraining.com A different kind of training.
- 3. 40 CFR 261.4(a)(11) @DanielsTraining 3 40 CFR 261.4(a) • Paragraph „a‟ of section 261.4 identifies 25 materials excluded from regulation as a solid waste. • If a material does not meet the definition of a solid waste, it cannot be a hazardous waste. Solid Hazardous Waste Waste
- 4. 40 CFR 261.4(a)(11) @DanielsTraining 4 Splash Condenser Dross Residue “The treatment of steel production pollution control sludge generates a zinc-laden residue, called a dross. This material, generated from a splash condenser in a high temperature metal recovery process, is known as a splash condenser dross residue. Because this material contains 50 to 60 percent zinc, it is often reclaimed, reused, or processed as a valuable recyclable material. Since facilities commonly handle this material as a valuable commodity by managing it in a way that is protective of human health and the environment, EPA excluded this residue from the definition of solid waste.” 2011 RCRA Orientation Manual
- 5. 40 CFR 261.4(a)(11) @DanielsTraining 5 “The following materials are not solid wastes for the purpose of this part…” • Non-wastewater splash condenser dross residue. If… • From the treatment of K061 hazardous waste in high temperature metals recovery units. And… • Shipped in drums (if shipped off-site). • Not land disposed at any point before recovery.
- 6. 40 CFR 261.4(a)(11) @DanielsTraining 6 More to Consider (1)… Waste Description Reason Code for Listing K061 Emission control dust/sludge from Toxic (T) the primary production of steel in electric furnaces
- 7. 40 CFR 261.4(a)(11) @DanielsTraining 7 More to Consider (2)… • (40 CFR 260.10): Sludge means any solid, semi-solid, or liquid waste generated from a municipal, commercial, or industrial wastewater treatment plant, water supply treatment plant, or air pollution control facility exclusive of the treated effluent from a wastewater treatment plant (emphasis mine).
- 8. 40 CFR 261.4(a)(11) @DanielsTraining 8 More to Consider(3)… • The splash condenser dross residue exclusion applies when the material is used as a source of zinc in zinc recovery operations.
- 9. 40 CFR 261.4(a)(11) @DanielsTraining 9 More to Consider (4)… • Common recycling methods for splash condenser dross residue: • Sent off-site for further reclamation. • Reused on-site in the high temperature metal recovery process. • Reprocessed on-site by the high temperature metal recovery process.
- 10. 40 CFR 261.4(a)(11) @DanielsTraining 10 More to Consider (5)… • Check with your State as it may not recognize this Federal exclusion.
- 11. 40 CFR 261.4(a)(11) @DanielsTraining 11 40 CFR 261.4(a)(11) Verbatim: (a) Materials which are not solid wastes. The following materials are not solid wastes for the purpose of this part: … • (11) Nonwastewater splash condenser dross residue from the treatment of K061 in high temperature metals recovery units, provided it is shipped in drums (if shipped) and not land disposed before recovery.
- 12. 40 CFR 261.4(a)(11) @DanielsTraining 12 Got Questions About RCRA or HazMat Transportation? I provide: Annual RCRA Training for Hazardous Waste Personnel and Triennial HazMat Employee Training Public Seminar or Daniels Training Services Onsite Training 815.821.1550 Info@DanielsTraining.com www.DanielsTraining.com
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- The Splash Condenser Dross Residuefor Recycling Exclusion from Regulation as a Solid Waste40 CFR 261.4(a)(11) excludes Splash Condenser Dross Residue recycled for its zinc content from regulation as a solid waste - and thus as a hazardous waste - if the requirements of the regulations are met. This presentation briefly summarizes the requirements of this RCRA exclusion from regulation.