Full Document:
RCRA Online Number: 14195
Title: CLARIFICATION OF THE REGULATORY STATUS OF AGGLOMERATED DROSSES
Document Date: 1998-02-13
To: Reilly
From: Bussard
Organization of Recipient: California Department of Toxic Substances Control
Description: Agglomerated drosses (from any source, not just scrap metal processing) can be classified as processed scrap metal and, if recycled, are excluded from the definition of solid waste. Agglomerated drosses are solid chunks of metal in a physical state that does not allow them to be easily crushed, split, or crumbled. Dross which has not been agglomerated is by-product, not scrap metal. Agglomerated drosses used in a manner constituting disposal are excluded scrap metal being recycled and thus not solid waste. Drosses that have not been agglomerated are solid wastes when used in a manner constituting disposal.
Regulatory Citation(s): 261.2(c)(1), 261.1(c)(6)
Official ORCR Policy: Yes
Associated Topic(s):
Exclusions (RCRA),
Hazardous Waste Recycling,
Identification of Hazardous Waste |