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
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.
U.S. Environmental Protection Agency Region 2
290 Broadway, 21 East
New York, NY 10007