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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)(15)

This presentation: 40 CFR 261.4(a)(15):Condensates From Kraft Mill Steam Strippers

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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)(15)

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40 CFR 261.4(a)

• Paragraph ‘a’ of section 261.4 identifies 26 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)(15)

Solid Waste

Hazardous Waste

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Condensates From Kraft Mill Steam Strippers

“The kraft process, the most commonly used pulping process today, utilizes various chemicals to break down wood into pulp. This process generates overhead gases that are condensed and often recycled as fuel. To encourage the recycling of these condensates, EPA excluded them from the definition of solid waste provided the condensate is combusted at the mill that generated it.”

40 CFR 261.4(a)(15)

2011 RCRA Orientation Manual

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• Condensates derived from overhead gases.

“The following materials are not solid wastes for the purpose of this part…”

40 CFR 261.4(a)(15)

If…

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“The following materials are not solid wastes for the purpose of this part…”

• Overhead gases are from kraft mill steam strippers.

40 CFR 261.4(a)(15)

And …

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“The following materials are not solid wastes for the purpose of this part…”

• Steam strippers are used to comply w/ 40 CFR 63.446(e).

40 CFR 261.4(a)(15)

And…

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“The following materials are not solid wastes for the purpose of this part…”

• Condensates are combusted at the mill where they were generated.

40 CFR 261.4(a)(15)

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More to Consider (1)…

40 CFR 261.4(a)(15)

• 40 CFR 63.446• Under the Clean Air Act.

• Specific to the Kraft pulping process.

• §63.446(e) requires treatment of “each pulping process condensate”.

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More to Consider (2)…

• Check with your State as it may not recognize this Federal exclusion.

40 CFR 261.4(a)(15)

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40 CFR 261.4(a)(15) Verbatim:

(a) Materials which are not solid wastes. The following materials are not solid wastes for the purpose of this part:

…

(15) Condensates derived from the overhead gases from kraft mill steam strippers that are used to comply with 40 CFR 63.446(e). The exemption applies only to combustion at the mill generating the condensates.

40 CFR 261.4(a)(15)

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Got Questions About RCRA or HazMat Transportation?

I provide both:

RCRA Training for Hazardous Waste Personnel

And…

HazMat Employee Training

Seminar, Webinar, or Onsite

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

40 CFR 261.4(a)(15)

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