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Home My WebLink AboutDSHW-2024-006626Hazardous Secondary Materials & Recycling Judy Moran, Environmental Scientist jmoran@utah.gov (385) 499-0184 In the beginning… Secondary Materials Any materials that are not the primary products from manufacturing and other industrial sectors. Secondary Materials Spent Material Sludge By-product Scrap Metal By -Products vs. Co-Products By -Product •Residual in nature •Not intentionally produced •Not separately produced •Needs further processing Co-Product •Highly processed •Intentionally produced •Ordinarily used as a commodity •No further processing necessary SECONDARY MATERIAL DISCARDED HAZARDOUS WASTE Hazardous Secondary Material (HSM) 1 2 3 Reclamation Processing to recover a usable product Wastes are processed to recover usable products when distinct components of the material that are of value are recovered. Regeneration Wastes are regenerated when they are processed to remove contaminants in a way that restores them to their usable original condition. Generator: Any person whose act or process produces hazardous secondary materials at the generating facility. Generating Facility: All contiguous property owned, leased, or otherwise controlled by the hazardous secondary material generator. Intermediate facility: any facility that stores hazardous secondary materials for more than 10 days Hazardous Secondary Material terms Speculative Accumulation A material is “accumulated speculatively” if it is accumulated before being recycled. A material is not accumulated speculatively, if: ○The material is potentially recyclable and has a feasible means of being recycled. ○During the calendar year commencing on January 1 the amount of material that is recycled, or transferred to a dierent site for recycling, equals at least 75 percent by weight or volume of the amount of that material accumulated at the beginning of the period. Solid Wastes Use constituting disposal (261- 2(c)(1)) Energy Recovery/fuel (261-2(c)(2)) Reclamation (261- 2(c)(3)) except as provided in 261- 4(a)(17), 261-4(a)(23), 261-4(a)(24) or 261- 4(a)(27) Speculative accumulation (R315- 261-2(c)(4)) Spent materials SOLID WASTE SOLID WASTE SOLID WASTE SOLID WASTE Sludges (listed in R315- 261-31 or 261-32) SOLID WASTE SOLID WASTE SOLID WASTE SOLID WASTE Sludges exhibiting a characteristic of hazardous waste SOLID WASTE SOLID WASTE NOT SOLID WASTE SOLID WASTE By-products (listed on 261- 31 & 261-32) SOLID WASTE SOLID WASTE SOLID WASTE SOLID WASTE By-products exhibiting a characteristic of hazardous waste SOLID WASTE SOLID WASTE NOT SOLID WASTE SOLID WASTE Commercial chemical products listed in 261-33 SOLID WASTE SOLID WASTE NOT SOLID WASTE NOT SOLID WASTE Scrap metal that is not excluded under 261- 4(a)(13) SOLID WASTE SOLID WASTE SOLID WASTE SOLID WASTE Is Your HSM a Solid Waste When Recycled? No -not a solid waste when recycled R315- 261 -2(e) ○Used as ingredients without being reclaimed ○Used a eective substitutes ○Returned to the original process without being reclaimed or placed on the land Yes -a solid waste when recycled ○Used in a manner constituting disposal ○Burned for energy recovery or to make fuel Sham Recycling Useful Contribution Valuable Product or Intermediate Managed in a Protective Manner Legitimate Recycling R315-260 -43 Excluded scrap metal. [R315-261 -4(a)(13)] Hazardous secondary materials generated and reclaimed under the control of the generator. [261- 2(a)(2)(ii) and 261-4(a)(23)] Hazardous secondary materials transferred to another person for the purpose of reclamation [261- 4(a)(24)] Solid Waste Exclusions R315-261 -4(a) Scrap Metal Excluded Scrap Metal R315-261 -4(a)(13) ●PROCESSED scrap metal ●Unprocessed HOME scrap metal ●Unprocessed PROMPT scrap metal Exempt Scrap Metal R315-261 -6(a)(3)(ii) Scrap metal that is not already excluded from the definition of solid waste is exempt from hazardous waste regulations if sent for RECYCLING/RECLAMATION Solvent Recycling Hazardous secondary materials generated and reclaimed under the control of the generator. R315-261-4(a)(23) Management Label “Hazardous Waste” Indication of the hazards Keep container closed Recordkeeping Notification Waste Counting May be handled only by the generator, transporter, any intermediate facility and one or more reclaimers Cannot be a spent lead- acid baery Transfer -Based Exclusion R315-261 -4(a)(24) 1 2 3 Must be legitimately recycled 4 May not be speculatively accumulated Send to RCRA permied treatment facilities or take reasonable eorts to verify legitimate recycling Recordkeeping Transfer -Based Exclusion Generator Requirements 1 2 3 Comply with emergency preparedness and response requirements4 Materials must be contained in units Notify the Director Documentation of ClaimsR315-261 -2(f) ●Not a solid waste ●Conditionally exempt What are you claiming? ●Director’s authority ●Support for your position What about co- products and by- products?●Contracts ●Equipment How do you demonstrate the claim? Questions? Thank you hps://deq.utah.gov/division-waste-management-radiation-control Judy Moran Environmental Scientist PHONE (385) 499-0184 EMAIL jmoran@utah.gov