Prior to the creation of the Resource Conservation and Recovery Act (RCRA), many of the nation’s water, soil and air resources were polluted due to the improper management of solid and hazardous wastes generated by industry. Because these wastes were not regulated prior to RCRA, facilities were free to dispose of their wastes whenever and wherever they wanted.
The Environmental Protection Agency (EPA) realized that in order to prevent further contamination, these practices needed to be stopped. Rules created under RCRA required waste generators to make solid and hazardous waste determinations and properly manage their wastes. It even established cradle-to-grave liability, which makes each generator responsible for their wastes after disposal.
One of the main goals under RCRA is to encourage generators to look for opportunities to reuse, reclaim and recycle wastes instead of disposing of them. The EPA offers solid and hazardous waste exemptions to encourage facilities to recycle eligible wastes [40 CFR 261.4].
The EPA provides 26 specific solid waste exemptions and 17 hazardous waste exemptions [40 CFR 261.4]. Here are five common exemptions that could apply to your facility:
Many different types of industries use wipes to either apply or remove solvents. Properly managing reusable and disposable wipes allows them to be washed and reused OR to be disposed of in a manner that does not cause substantial environmental harm.
Click here to learn whether your wipes are eligible for exclusion.
Non-Terne-Plated Oil Filters
Used oil filters that have been gravity hot drained by puncturing, crushing or dismantling to remove the used oil can be recycled with scrap metals.
Industrial Wastewater Discharges
Pipelines, storm drainage systems and other any other paths that wastewater may take when leaving an industrial facility are called “point sources.” Any facility that discharges pollutants from a point source is subject to Clean Water Act Regulations. These regulations require facilities to obtain an NPDES permit from the EPA that specifies the amounts of a contaminant that may be discharged.
Click here to learn more about NPDES permits and keeping waterways clean.
Excluded Scrap Metals
The small bits and pieces of metal, bolts, shavings and other scraps that are left over when producing or repairing metal objects are highly recyclable. A top example of this is used aerosol cans. When these small turnings are collected and recycled, they are exempted from solid waste regulation.
Click here to find out what you need to do so your aerosol cans are eligible for exemption.
Sometimes, when items are produced or repaired, there are leftover materials (by-products, sludges, etc.) that are not a useful part of the finished product. These are “secondary materials.” Often, these leftovers can be recycled and reused again in the process to make additional products. The facility may not speculatively accumulate the materials and must manage them as a commodity in order to be eligible for the exemption. The secondary materials may be used in the same process; by the same facility or transferred to another facility for reclamation.