While RCRA specifically exempts some wastes when recycled, some recycling processes may still pose enough of a hazard to warrant some degree of regulation. However, due to the nature of the recycling process itself or the nature of the materials being recycled, these processes may require a specialized set of standards. These processes are as follows2:
1. Use constituting disposal: Use constituting disposal refers to the practice of recycling hazardous wastes by placing them on the land or using them as ingredients in a product that will be placed on the land. To be placed on the land, waste-derived products must (1) be made for the general public's use; (2) have undergone a chemical reaction so as to be inseparable by physical means; and (3) meet applicable LDR treatment standards. Once these waste-derived products meet these standards, they are no longer restricted from placement on the land. Materials that do not meet these criteria remain regulated. There are also special standards for hazardous wastes used to make zinc micronutrient fertilizers.
2. Precious metals reclamation: Precious metals reclamation is the recycling and recovery of precious metals (i.e., gold, silver, platinum, palladium, iridium, osmium, rhodium, and ruthenium) from hazardous waste. Because U.S. EPA found that these materials will be handled protectively as valuable commodities with significant economic value, generators, transporters, and storers of such recyclable materials are subject to reduced requirements.
3. Spent lead-acid battery reclamation: Persons who generate, transport, regenerate, collect, and store spent lead-acid batteries prior to reclamation, but do not perform the actual reclamation, are not subject to hazardous waste regulation. U.S. EPA established those provisions to encourage the recycling of these batteries. However, owners and operators of facilities that store spent batteries before reclamation, other than spent batteries that are regenerated (processed to remove contaminants and restore the product to a useable condition), are subject to regulation in a manner similar to hazardous waste TSDFs. Handlers of lead-acid batteries may also choose to manage them under the universal waste provisions. 4. Burning for energy recovery: The process of recycling hazardous waste by burning it for energy recovery may pose significant air emission hazards. Therefore, U.S. EPA established specific operating standards for units burning hazardous wastes for energy recovery. These units are known as boilers and industrial furnaces (BIFs).
Was this article helpful?