Full Document:
RCRA Online Number: 14900
Title: APPLICABILITY OF “GENERATOR-CONTROLLED EXCLUSION” TO SECONDARY MATERIALS MANAGED IN HALOGEN ACID FURNACE
Document Date: 2018-01-26
To: King
From: Johnson
Organization of Recipient: Breazeale, Sachse & Wilson, L.L.P.
Description: Materials being processed in a halogen acid furnace (HAF) are not eligible for the “generator-controlled exclusion” in 40 CFR 261.4(a)(23) and instead are considered to be inherently waste-like materials per 40 CFR 261.2(d)(2). The letter also describes the history of regulating halogen acid furnaces and burning for energy recovery.
Regulatory Citation(s): 260.10, 261.4(a), 266.100(d), 261.2
Statutory Citation(s): 3004(q) Read US Code 42, Chapter 82
Official ORCR Policy: Yes
Associated Topic(s):
Boilers,
Burning,
Exclusions (RCRA),
Hazardous Waste,
Hazardous Waste Recycling,
Incineration,
Recycling,
Solid Waste,
Treatment |