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Document Record Detail

Full Document:
RCRA Online Number:11468
To:Ullrich, Region 5
Organization of Recipient:EPA
Description: Iron sulfate by-product reclaimed from K062 that is used as an effective substitute for a CCP becomes an unregulated product unless it is to be used on the land. If it is used in a manner constituting disposal, it must meet the land disposal restrictions (LDR) treatment standards prior to placement on the land. K062 that is reclaimed is not eligible for the 261.4(a)(7) exclusion because this activity does not involve the production of virgin sulfuric acid. K062 that is being reclaimed before reuse is not eligible for the 261.2(e) exclusion from the definition of solid waste. Closed-loop recycling only applies to wastes that are piped, not trucked. Secondary materials stored in a closed-loop system are not solid wastes, however, wastes from the management of these secondary materials are solid wastes and are subject to Subtitle C. Non-product residues derived from K062 reclamation are still K062.
Regulatory Citation(s) : 261.2(c)(3), 261.2(e), 261.3(c)(2), 261.4(a)(7), 261.4(a)(8), 266.20(b) EXIT disclaimer
Statutory Citation(s):NA Read US Code 42, Chapter 82 EXIT disclaimer
Topic(s):Disposal; Exclusions (RCRA); Hazardous Waste; Hazardous Waste Recycling; Land Disposal Restrictions; Mining Waste; Special Wastes; Treatment; Storage
Approximate Number of Hardcopy Pages:6
EPA Publication Number:NA
RPPC Number (if applicable): 9441.1989(48)
Official OSW Policy:No


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