The document discusses federal exclusions from solid waste regulation under the Resource Conservation and Recovery Act, specifically focusing on pulping liquors (black liquor) that are reclaimed in a recovery furnace and reused in the pulping process. It emphasizes that these materials are not considered solid waste unless accumulated speculatively or recycled by other methods. Additionally, it advises checking state regulations as they may differ from federal exclusions.

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)(6) @DanielsTraining 1
This presentation: 40 CFR 261.4(a)(6):
Pulping Liquors

2. PRESENTED BY:
Daniels Training Services
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www.DanielsTraining.com
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A different kind of training.
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40 CFR 261.4(a)(6)

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.
40 CFR 261.4(a)(6) @DanielsTraining 3
Solid
Waste
Hazardous
Waste

4. Pulping Liquors
“Pulping liquor, also called black liquor, is a
corrosive material used to dissolve wood chips for
manufacturing of paper and other materials. To
promote waste minimization and recycling, EPA
excluded pulping liquors from the definition of solid
waste if they are reclaimed in a recovery furnace
and then reused in the pulping process. If the
liquors are recycled in another way, or are
accumulated speculatively, they are not excluded.”
40 CFR 261.4(a)(6) @DanielsTraining 4
2011 RCRA Orientation Manual

5. “The following materials are not solid
wastes for the purpose of this part…”
• Pulping Liquor (aka:
Black Liquor) that is:
1. Reclaimed in a
pulping liquor
recovery furnace
and
2. Then reused in the
pulping process.
• Unless it is
accumulated
speculatively.
40 CFR 261.4(a)(6) @DanielsTraining 5

6. More to Consider(1)…
40 CFR 261.4(a)(6) @DanielsTraining 6

7. More to Consider(2)…
• Exclusion does not
apply if Pulping Liquor
is recycled or
reclaimed by any other
method.
• Check with your State
as it may not recognize
this Federal exclusion.
40 CFR 261.4(a)(6) @DanielsTraining 7

8. 40 CFR 261.4(a)(6) Verbatim:
(a) Materials which are not solid wastes. The
following materials are not solid wastes for the
purpose of this part:
…
(6) Pulping liquors ( i.e., black liquor) that are
reclaimed in a pulping liquor recovery furnace and
then reused in the pulping process, unless it is
accumulated speculatively as defined in § 261.1(c)
of this chapter.
40 CFR 261.4(a)(6) @DanielsTraining 8

9. Got Questions
About RCRA or
HazMat
Transportation?
I provide:
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Training for
Hazardous Waste
Personnel
and
Triennial HazMat
Employee Training
Public Seminar or
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Info@DanielsTraining.com
www.DanielsTraining.com
9
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40 CFR 261.4(a)(6)