The Exclusion from Regulation as a Solid Waste for Kraft Mill Steam Strippers 40 CFR 261.4(a)(15) excludes condensates from Kraft Mill steam strippers 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.

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).
40 CFR 261.4(a)(15) @DanielsTraining 1
This presentation: 40 CFR 261.4(a)(15):
Condensates From Kraft Mill Steam Strippers

2. PRESENTED BY:
Daniels Training Services
815.821.1550
www.DanielsTraining.com
Info@DanielsTraining.com
A different kind of training.
@DanielsTraining 240 CFR 261.4(a)(15)

3. 40 CFR 261.4(a)
• Paragraph ‘a’ of section 261.4 identifies 26
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.
40 CFR 261.4(a)(15) @DanielsTraining 3
Solid
Waste
Hazardous
Waste

4. Condensates From Kraft Mill Steam Strippers
“The kraft process, the most commonly used
pulping process today, utilizes various chemicals
to break down wood into pulp. This process
generates overhead gases that are condensed
and often recycled as fuel. To encourage the
recycling of these condensates, EPA excluded
them from the definition of solid waste provided the
condensate is combusted at the mill that
generated it.”
40 CFR 261.4(a)(15) @DanielsTraining 4
2011 RCRA Orientation Manual

5. • Condensates derived from overhead gases.
“The following materials are not solid
wastes for the purpose of this part…”
40 CFR 261.4(a)(15) @DanielsTraining 5
If…

6. “The following materials are not solid
wastes for the purpose of this part…”
• Overhead gases are
from kraft mill steam
strippers.
40 CFR 261.4(a)(15) @DanielsTraining 6
And …

7. “The following materials are not solid
wastes for the purpose of this part…”
• Steam strippers are
used to comply w/ 40
CFR 63.446(e).
40 CFR 261.4(a)(15) @DanielsTraining 7
And…

8. “The following materials are not solid
wastes for the purpose of this part…”
• Condensates are
combusted at the mill
where they were
generated.
40 CFR 261.4(a)(15) @DanielsTraining 8

9. More to Consider (1)…
40 CFR 261.4(a)(15) @DanielsTraining 9
• 40 CFR 63.446
• Under the Clean Air
Act.
• Specific to the Kraft
pulping process.
• §63.446(e) requires
treatment of “each
pulping process
condensate”.

10. More to Consider (2)…
• Check with your State
as it may not recognize
this Federal exclusion.
40 CFR 261.4(a)(15) @DanielsTraining 10

11. 40 CFR 261.4(a)(15) Verbatim:
(a) Materials which are not solid wastes. The
following materials are not solid wastes for the
purpose of this part:
…
(15) Condensates derived from the overhead
gases from kraft mill steam strippers that are used
to comply with 40 CFR 63.446(e). The exemption
applies only to combustion at the mill generating
the condensates.
40 CFR 261.4(a)(15) @DanielsTraining 11

12. Got Questions
About RCRA or
HazMat
Transportation?
I provide both:
RCRA Training for
Hazardous Waste
Personnel
And…
HazMat Employee
Training
Seminar, Webinar, or
Onsite
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815.821.1550
Info@DanielsTraining.com
www.DanielsTraining.com
12@DanielsTraining40 CFR 261.4(a)(15)
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