6/11/2004
[RCRA 40 CFR 261.6] Recycling of Hazardous Wastes
As discussed in the Reg-of-the-Day (
Reg
of the Day June 9, 2004),
40
CFR 261.6 identifies the requirements for recycling of hazardous waste, and
paragraph (c)(1)
states that the recycling process is exempt from RCRA regulation.
Imagine a facility that uses two hundred gallons of isopropyl alcohol (IPA)
every week in a cleaning process, and then ships it off-site for recycling
or disposal. In either case, this spent IPA would be a hazardous waste. Every
month, on average, they purchase about 866 gallons of IPA, then pay transportation
and disposal costs for that 866 gallons.
Now imagine purchasing and installing a still to reclaim this IPA on-site.
Even if they only reclaim 75% of this spent IPA, they will be re-using 650
gallons a month, reducing the amount of product IPA purchased each month to
216 gallons. They will also save 75% on transporting and disposal costs. Factor
these savings into the cost of purchasing and installing a recycling unit,
and recycling of this IPA becomes less expensive.