Frequent Questions

What are the regulatory requirements for owners and operators of recycling facilities that immediately recycle hazardous waste without prior storage?

The RCRA Subtitle C requirements for owners and operators of facilities that recycle materials without prior storage are outlined in 40 CFR Section 261.6(c)(2) . Owners and operators of these facilities must obtain an EPA ID number and follow guidelines for the use of the manifest and the reporting of manifest discrepancies (Section 261.6(c)(2)(i)-(ii)). In addition, recycling units at facilities otherwise subject to RCRA permitting must comply with the air emission standards in Part 264/265, Subparts AA and BB (Section 261.6(d)).  Aside from the air emission requirements, the recycling process itself is exempt from Subtitle C requirements (Section 261.6(c)(1)).

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