Auto Recycling Plain Language Guide to Regulations
Solid/Hazardous Waste Management
1. How to Comply. Determine If Your Waste is Hazardous
What
is Hazardous Waste?
This may seem like a simple question, however the answer is somewhat
complicated because of special rules and exemptions. The definition
begins with an explanation of a "solid waste." A solid waste is any
solid, liquid, or contained gaseous material that is discarded by
being disposed of, burned or incinerated, or recycled. (There are
some exceptions for recycled materials.) It can be the by-product
of a manufacturing process or simply a commercial product that you
use in your business--such as a cleaning fluid or battery acid--that
is being disposed of. Even materials that are recyclable or can be
reused in some way (such as burning used oil for fuel) may be considered
solid waste.
"Hazardous
waste" can be one of two types:
"Listed
waste." Your solid waste is considered hazardous if it appears on
one of four lists published in the Code of Federal Regulations (40
CFR Part 261) (Links to full text regulations).
Currently, more than 400 wastes are listed. Wastes are listed as
hazardous because they are known to be harmful to human health and
the environment when not managed properly.
"Characteristic
wastes." If your solid waste does not appear on one of the hazardous
waste lists, it still might be considered hazardous if it demonstrates
one or more of the following characteristics:
- It
catches fire under certain conditions. This is known as an "ignitable"
waste and it has a special RCRA waste code (
D001).
Examples are waste fuels, paints, and certain solvents.
- It
corrodes metals or has a very high or low pH. This is known as
a "corrosive" waste and it has a special RCRA waste code (
D002).
Examples are battery acid and certain cleaners.
- It
is unstable and explodes or produces toxic fumes, gases, and vapors
when mixed with water or under other conditions such as heat or
pressure. This is known as a "reactive" waste and it has a special
RCRA waste code (
D003).
Examples are certain cyanides or sulfide-bearing wastes.
- It
is harmful or fatal when ingested or absorbed, or it leaches toxic
chemicals into the soil or ground water when disposed of on land.
This is known as a "toxic" waste. Toxic
wastes have special waste codes (D004 to D0043), depending
on the contaminant present. For example, lead contaminated waste
has the code D008. Examples are wastes that contain high concentrations
of heavy metals, such as contaminated oils.
You can
determine if your waste is toxic by having it tested using the
Toxicity
Characteristic Leaching Procedure (TCLP), or by simply knowing
that your waste is hazardous by definition.
What
is NOT Hazardous Waste
RCRA regulations include a number of exceptions that are important
to auto recycling facilities. These exceptions are found in 40 CFR
261.4 (Link to full text regulations).
The following are not solid or hazardous wastes:
- Used
oil filters that have been gravity hot drained or other method
to remove oil.
- Used
oil that is properly managed and recycled.
- Lead-acid
batteries that are properly managed and recycled.
- Wastewater
discharges from auto recycling facilities that are regulated under
the
Clean
Water Act
- Domestic
sewage discharged to a
POTW
- Secondary
materials that are reclaimed and returned to the original process
in which they were generated (certain provisions must be met)
- Shredded
circuit boards being recycled (certain provisions must be met,
see 40 CFR 261.4 (a)(14))
- Commercial
chemical products, when recycled.
Common
Auto Recycling Hazardous Wastes
There are a number of hazardous wastes commonly generated by auto
recycling. These include:
- waste
fuel
- battery
acid (removed from battery)
- sump
sludges
- spent
solvents
- fluids
collected from vehicle crusher
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