A new rule by the U.S. EPA on the definition of solid waste could save U.S. PCB manufacturers millions of dollars as well as encourage recycling.
Signed on Oct. 7, the EPA's new definition of solid waste (DSW) rule removes regulatory barriers that inhibited recycling of manufacturing wastes, known also as secondary materials. In the final rule, the DSW was revised to exclude secondary materials from the Resource Conservation and Recovery Act (RCRA) hazardous waste regulations if they're recycled according to specific requirements.
The requirements call for the generating facility to provide proper documentation of shipments of secondary materials and to answer a series of questions in order to ensure proper recycling of secondary materials. In earlier drafts of the DSW rule, secondary materials would be exempt from RCRA hazardous waste regulations only if the secondary material was recycled at a generation site. The recycling of copper from wastewater sludge exemplifies why off-site recycling is critical for the electronics industry to benefit from the new rule; sludge is recycled at smelting facilities, not at PCB manufacturing facilities.
Another change in the rule allows for middlemen, or brokers, to aggregate amounts of secondary materials without becoming RCRA treatment, storage and disposal facilities (TSDFs). Small and medium-sized businesses do not produce enough secondary materials to deal directly with a smelting facility. By allowing a middleman to aggregate small amounts of secondary materials, small and medium-sized businesses can take advantage of the rule's exclusion and recycle their secondary materials outside of RCRA hazardous waste regulations.
In addition, the final DSW rule allows for ordinary business records to be used as appropriate forms of record-keeping for shipping secondary materials. This allows records that are already produced to be used instead of requiring new additional ones.
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