Full Document:
RCRA Online Number: 14888
Title: SCRAP METAL RECYCLING
Document Date: 2017-02-24
To: Bryant
From: Johnson
Organization of Recipient: Bergeson & Campbell PC
Description: Scrap tantalum anodes, wire, pellets, and pins meet the definition of scrap metal found at 40 CFR 261.1(c)(6) and would not be subject to RCRA hazardous waste regulation when recycled under the solid waste exclusion found at 40 CFR 261.4(a)(13) (if processed) or under the hazardous waste exemption found at 40 CFR 261.6(a)(3)(ii) (for all other materials). Tantalum powders would only meet the definition of scrap metal if they have been "agglomerated" in such a way that the agglomerated powders physically resemble other types of scrap metal (i.e., bits and pieces of metal parts). Non-agglomerated tantalum powders would not meet the definition of scrap metal. (EXPORT REQUIREMENTS DISCUSSED IN MEMO SUPERSEDED: 40 CFR 262 Subparts E and F removed, See 40 CFR 262 Subpart H and 81 FR 85696; 11/28/2016)
Regulatory Citation(s): 260.43, 261.1, 261.4, 261.6
Official ORCR Policy: Yes
Associated Topic(s):
Exclusions (RCRA),
Recycling,
Scrap Metal |