CC-11-024: RCRA – Proposed Rule – Definition of Solid Waste
The July 22, 2011 edition of the Federal Register contained an EPA proposal to revise certain exclusions from the definition of solid waste for secondary materials intended for reclamation that might otherwise be considered hazardous waste under Subtitle C of the Resource Conservation and Recovery Act (RCRA). EPA’s proposal, if promulgated as currently written, would add significant administrative and management requirements to the current exemption of recovered “spent pulping liquors” from Subtitle C requirements. This memo will be of interest to chemical pulp mills producing spent pulping liquors subject to the current RCRA exemption.