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Document Record Detail



Full Document:
Title:SALE AND SCRAPPING OF DOT'S MARITIME OBSOLETE VESSELS FROM THE NATIONAL DEFENSE RESERVE FLEET
RCRA Online Number:11862
Date:08/05/1994
To:Donovan
From:Shapiro
Organization of Recipient:The Law Offices of Jones and Donovan
Description: Purchasers of ships to be scrapped and sold abroad must determine when export rules apply. Vessels destined for scrap as well as any materials necessary for operating the ship are not discarded while the vessel remains intact because those materials continue to serve a useful purpose. Removal of a material from a ship's structure that is intended for discard is the point of generation. Section 106(a) of the Federal Facilities Compliance Act (FFCA) prohibits the storage of hazardous waste on a public vessel for longer than 90 days after the vessel is placed in reserve or is no longer in service without a RCRA storage permit. Materials from a dismantled ship that are to be recycled may be scrap metal.
Regulatory Citation(s) : 261.1(c)(6), 261.2(a), 261.2(b), 261.4(c), 261.6(c)(3), 262.11, 262.50 EXIT disclaimer
Statutory Citation(s):NA Read US Code 42, Chapter 82 EXIT disclaimer
Topic(s):Exports; Generators; Hazardous Waste; Hazardous Waste Recycling; Identification of Hazardous Waste; Large Quantity Generators (LQG); Permits and Permitting; Storage
Approximate Number of Hardcopy Pages:13
EPA Publication Number:NA
RPPC Number (if applicable): 9441.1994(21)
Official OSW Policy:No

 

 
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