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EXCLUSIONS FROM REGULATION AS SOLID WASTEOne presentation in a series that briefly explains the Federal exclusions from full regulation for certain materials under the Resource Conservation and Recovery Act (RCRA).

40 CFR 261.4(a)(11)

This presentation: 40 CFR 261.4(a)(11):Splash Condenser Dross Residue

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PRESENTED BY:

Daniels Training Services815.821.1550www.DanielsTraining.comInfo@DanielsTraining.com

A different kind of training.

40 CFR 261.4(a)(11)

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40 CFR 261.4(a)• Paragraph ‘a’ of section 261.4 identifies 25 materials excluded from regulation as a solid waste.

• If a material does not meet the definition of a solid waste, it cannot be a hazardous waste.

40 CFR 261.4(a)(11)

Solid Waste

Hazardous Waste

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Splash Condenser Dross Residue“The treatment of steel production pollution control sludge generates a zinc-laden residue, called a dross. This material, generated from a splash condenser in a high temperature metal recovery process, is known as a splash condenser dross residue. Because this material contains 50 to 60 percent zinc, it is often reclaimed, reused, or processed as a valuable recyclable material. Since facilities commonly handle this material as a valuable commodity by managing it in a way that is protective of human health and the environment, EPA excluded this residue from the definition of solid waste.”

40 CFR 261.4(a)(11)

2011 RCRA Orientation Manual

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“The following materials are not solid wastes for the purpose of this part…”• Non-wastewater splash condenser dross residue.If…• From the treatment of K061 hazardous waste in high temperature metals recovery units.

And…• Shipped in drums (if shipped off-site).• Not land disposed at any point before recovery.

40 CFR 261.4(a)(11)

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More to Consider (1)…

Waste Code

Description Reason for Listing

K061 Emission control dust/sludge from the primary production of steel in electric furnaces

Toxic (T)

40 CFR 261.4(a)(11)

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More to Consider (2)…• (40 CFR 260.10): Sludge means any solid, semi-solid, or liquid waste generated from a municipal, commercial, or industrial wastewater treatment plant, water supply treatment plant, or air pollution control facility exclusive of the treated effluent from a wastewater treatment plant (emphasis mine).

40 CFR 261.4(a)(11)

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More to Consider(3)…• The splash condenser dross residue exclusion applies when the material is used as a source of zinc in zinc recovery operations.

40 CFR 261.4(a)(11)

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More to Consider (4)…• Common recycling methods for splash condenser dross residue:• Sent off-site for further reclamation.• Reused on-site in the high temperature metal recovery process.

• Reprocessed on-site by the high temperature metal recovery process.

40 CFR 261.4(a)(11)

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More to Consider (5)…• Check with your State as it may not recognize this Federal exclusion.

40 CFR 261.4(a)(11)

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40 CFR 261.4(a)(11) Verbatim:(a) Materials which are not solid wastes. The following materials are not solid wastes for the purpose of this part:…• (11) Nonwastewater splash condenser dross residue from the treatment of K061 in high temperature metals recovery units, provided it is shipped in drums (if shipped) and not land disposed before recovery.

40 CFR 261.4(a)(11)

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Got Questions About RCRA or HazMat Transportation?

I provide:Annual RCRA Training for Hazardous Waste PersonnelandTriennial HazMat Employee Training

Public Seminar or Onsite Training

Daniels Training Services815.821.1550Info@DanielsTraining.comwww.DanielsTraining.com

40 CFR 261.4(a)(11)