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Document Record Detail

Full Document:
RCRA Online Number:14576
To:EPA Regional Senior Policy Advisors
Organization of Recipient:NA
Description: The Catoxid unit operates as a recycling unit designed to react secondary material feeds to produce a chemical intermediate used directly in the manufacture of EDC. The Catoxid unit is a manufacturing process and does not meet the definition of halogen acid furnace (HAF) (SEE ALSO: 56 FR 7139; 2/21/91). EPA views HAFs as utilizing combustion and as being designed as boilers or operated in a manner similar to boilers. Acid generation that occurs in a closed, controlled chemical manufacturing process is not considered the "production of acid" for purposes of the HAF definition. Secondary materials going to such units are not solid wastes pursuant to the use/reuse exclusion if the process is legitimate recycling. State regulations can be more stringent than the federal regulations.
Regulatory Citation(s) : 260.10, 261.2(e), 266.100 EXIT disclaimer
Statutory Citation(s):NA Read US Code 42, Chapter 82 EXIT disclaimer
Topic(s):Boilers; Burning; Combustion of Hazardous Waste; Industrial Furnaces; Recycling
Approximate Number of Hardcopy Pages:3
EPA Publication Number:NA
RPPC Number (if applicable): NA
Official OSW Policy:Yes


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