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Document Record Detail
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| Full Document: |  |
| Title: | FUEL PELLETS AND THE DEFINITION OF SOLID WASTE WHEN BURNED IN A COMBUSTION UNIT IN ACCORDANCE WITH 40 CFR 241.3(B)(4) |
| RCRA Online Number: | 14828 |
| Date: | 11/14/2011 |
| To: | Rickrun |
| From: | Guerriero |
| Organization of Recipient: | James S. Rickrun Environmental Consulting |
| Description: | To be designated as a non-waste fuel under that section, the rule requires that processing of the non-hazardous secondary material (NHSM) meets the definition of processing in 40 CFR 241.2. Also, after processing, the NHSM must meet the legitimacy criteria in 241.3(d)(l) to be designated a non-waste fuel. Processing is defined in 241.2 as operations that transform discarded NHSMs into a non-waste fuel or non-waste ingredient, including operations necessary to: remove or destroy contaminants; significantly improve the fuel characteristics, e.g. sizing or drying of the material in combination with other operations; chemically improve the as-fired energy content; or improve the ingredient characteristics. Minimal operations that result only in modifying the size of the material by shredding do not constitute processing for purposes of the definition. The legitimacy criteria for fuels includes: 1) management of the material as a valuable commodity based on the following factors- storage prior to use must not exceed reasonable time frames and management of the material must be in a manner consistent with an analogous fuel, or where there is no analogous fuel, adequately contained to prevent releases to me environment; 2) the material must have meaningful heating value and be used as a fuel in a combustion unit that recovers energy; and 3) the material must contain contaminants at levels comparable to or less than those in traditional fuels which the combustion unit is designed to bum. The term contaminants is defined in 241.2 as constituents in the NHSM that will result in emissions of air pollutants under Clean Air Act Section 112(b) or the nine pollutants listed under Clean Air Act Section 129, including those constituents that could generate products of incomplete combustion. |
| Regulatory Citation(s) : | 241.2, 241.3(b)(4), 241.(d)  |
| Statutory Citation(s): | NA Read US Code 42, Chapter 82 |
| Topic(s): | Definition of Solid Waste |
| Approximate Number of Hardcopy Pages: | 6 |
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| EPA Publication Number: | NA |
| RPPC Number (if applicable): | NA |
| Official OSW Policy: | No |
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