Agglomerated drosses are solid chunks of metal in a physical state that does not allow them to be easily crushed, split, or crumbled (Memo, Bussard to Reilly; February 13, 1998 (RCRA Online #14195)).
Processed scrap metal includes, but is not limited to, scrap metal which has been baled, shredded, sheared, chopped, crushed, flattened, cut, melted, or separated by metal type (i.e., sorted), and, fines, drosses and related materials which have been agglomerated (40 CFR §261.1(c)(10)). Dross that has not been agglomerated is a by-product, not scrap metal.
Agglomerated drosses from any source, not just scrap metal processing, can be classified as processed scrap metal and, if recycled, are excluded from the definition of solid waste (Memo, Bussard to Reilly; February 13, 1998 (RCRA Online #14195 )).
These memoranda are available in the at the RCRA Online database.
What are agglomerated drosses that qualify as processed scrap metal in 40 CFR §261.1(c)(9)?
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