Full Document:
RCRA Online Number: 14086
Title: REGULATORY STATUS OF BURNING SULFUR-CONTAINING SECONDARY MATERIALS TO PRODUCE VIRGIN SULFURIC ACID
Document Date: 1997-05-23
To: Clay
From: Cotsworth
Organization of Recipient: Don Clay Associates
Description: The heating value of sulfur-containing material inserted in a sulfuric acid regeneration furnace determines if the activity is burning for energy recovery or reclamation. Materials with a heating value greater than 5000 Btu/lb are generally considered to be burned as a fuel rather than for metals recovery or as an ingredient. 5000 Btu/lb is not a regulatory threshold for the purposes of the definition of solid waste, but there is a strong presumption that secondary materials above 5000 Btu are burned for energy recovery and therefore are solid wastes (e.g., as in the case of characteristic by-products recycled by being burned). The section 261.4(a)(7) exclusion applies only to spent sulfuric acid and does not include other sulfur-containing materials.
Regulatory Citation(s): 261.2(c)(2), 261.2(c)(3)
RPPC Number: 9494.1997(01)
Official ORCR Policy: Yes
Associated Topic(s):
Boilers,
Burning,
Combustion of Hazardous Waste,
Exclusions (RCRA),
Hazardous Waste,
Hazardous Waste Recycling |