Full Document:
RCRA Online Number: 14852
Title: RCRA REGULATORY STATUS OF SPENT REFRACTORY BRICK
Document Date: 2015-07-17
To: Ware
From: Devlin
Organization of Recipient: Corhart Refractories
Description: In a particular process, treatment of spent, crushed hexavalent chrome bricks essentially regenerates the chromium back into trivalent chromium, and this treated material then becomes the feedstock to produce new trivalent chromium refractory bricks. Per 40 CFR 261.2(c)(4), regeneration of a secondary material is a form of reclamation, and the reclamation of particular types of secondary materials, such as spent materials, is subject to RCRA regulations. Furthermore, the RCRA regulations at 261.2(e) involving the direct use/reuse of a secondary material as an ingredient or as an effective substitute in a manufacturing process do not apply when the material is being reclaimed and therefore are not applicable in this situation.
Regulatory Citation(s): 261.24, 261.2, 261.1(c)(4)
Official ORCR Policy: Yes
Associated Topic(s):
Characteristic Wastes,
Exports,
Hazardous Waste Recycling,
Identification of Hazardous Waste |