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Diane,
I seem to recall a Federal Register notice on Lan Ban that made a statement
that these catalysed scraps are inert and do not exhibit the haz waste
characteristics.
Refer to the Federal Register, Vol 62, No. 91 dated May 12,
1997 (pages 25998-26008). The EPA revised the Land Disposal Restrictions
to allow on-site polymerization of small quantities of polyester/styrene
monomers and MEK peroxide wastes which can be reacted together to create
fiberglass scraps. The notice says that the scraps are then inert and do not
exhibit the hazardous waste characteristics of toxicity, ignitability,
corrosivity, or reactivity. EPA stated in the FR that this treatment can
occcur at the site of generation without having to obtain a RCRA permit if
certain conditions are met. This means you can polymerize the waste and dispose
of it in a landfill. Each state would have to adopt that before it is
effective.
However, some years back in Washington state said that
although that state allowed landfilling after polymerization, the facilities
should have counted the waste as dangerous waste, which would effect their
generator status. So that when a facility is operating with Treatment by
Generator status they must count the waste prior as dangerous befor catalyzing
and report the amount catalyzed on the annual generator report. I'm not sure if
that has changed any or not.
>>> "Buxbaum.Diane@epamail.epa.gov" <Buxbaum.Diane@epamail.epa.gov> 12/19/01 12:38PM >>> This is a message I received from one of our enforcement team. There is a conflict right now because of an enforcement action, but it has been suggested that try to help the facility as much as possible. This is an educational facility and has art classes. They need sources of information on defining this type of waste and how to safely and legally dispose of it. Can anyone provide the information or sources? diane buxbaum The Physical Plant people are telling them that they have to dispose of all catalyzed and thermoset(?) resin items (fiberglass-like stuff) as hazardous waste. As a result, they have to curtail the modelling that their students do. However, this professor is trying to determine if catalyzed/thermoset plastic resins (hardened, that is) are treated the same for disposal as would the liquid ingredients that create it. From a waste determination standpoint, I know the answer would be that they'd have to coinsider it. But from a practical perspective, I don't know the post-reaction chemistry well enough to know what would be hazardous, as well as what might be leachable. Have you looked into this for any reason? Are there any good sources on art wastes that you can refer him to? I won't have time to look into it for a few weeks, so I'm hoping you can handle it. It seems like there must be some good reference out there, but I don't know of any. Diane D. Buxbaum, M.P.H. Environmental Scientist U.S. Environmental Protection Agency Region 2 DECA/CAPSB 290 Broadway, 21 East New York, NY 10007 phone: 212-637-3919 fax: 212-637-4086 email: buxbaum.diane@epa.gov |