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Lucy Stanfield, U.S. EPA Region 5 |
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Indiana E-Scrap Meeting |
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September 9, 2003 |
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Putting “Resource Conservation” back into the
Resource Conservation and Recovery Act (RCRA) |
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2 goals: |
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Increase the national recycling rate to 35% by
2005 |
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Cut the generation of 30 priority chemicals in
hazardous waste in half by 2005 |
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Dioxins/furans, cadmium, lead, and mercury |
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Increase safe recovery and recycling |
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Minimize the potential for liability: |
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Understand your RCRA requirements |
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CERCLA and arrangers intent |
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Conduct due diligence on recyclers |
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Make sure donation programs truly need the
equipment |
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RCRA requires generator to make the waste
determination: |
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Knowledge of process, or testing |
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For the complete federal hazardous waste
requirements for generators, consult 40 CFR Parts 260-262 |
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Check with your State to see which Subtitle C
requirements are applicable to their activities |
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Households Exempt: Used computer monitors or
televisions generated by households are not considered hazardous waste and
are not regulated under federal regulations. |
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Donation or Resale Exempt: Monitors and
televisions sent for continued use (i.e., resold or donated) are not
considered hazardous waste. |
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Conditionally Exempt Small Quantity Generators: Businesses
and other organizations are not regulated under most federal requirements
if the facility discards less than 100 kilograms (about 220 lb.) of
hazardous waste, including used CRTs, per month. |
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These wastes must still go to a facility
authorized to receive solid waste. |
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Approx. 7-8 whole CRT monitors = 220 lbs. |
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Large Quantity Generators: Wastes from
facilities that generate more than 100 kilograms (about 220 lb.) of
hazardous waste per month are regulated under federal law when disposed.
CRTs sent for disposal from such facilities must be manifested as
“hazardous waste” and sent to a permitted hazardous waste landfill. |
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Used CRTs sent directly to glass processors or
recyclers |
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could under some circumstances be considered
spent materials undergoing reclamation, and could therefore be solid wastes |
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It could then potentially be a hazardous waste |
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CRT Rule (40 CFR 260, 261, 264, 268, 270, and
273): |
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To encourage greater reuse, recycling, and
management of cathode ray tubes |
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Finalized early 2004 |
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Many commenters concerned that regulatory relief
would encourage exports. EPA
looking at ways to address exports. |
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Other comments received on: |
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household exemptions, storage requirements,
human health implications, and lack of recycling standards |
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Approach: |
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CRTs sent to a collector or reseller for reuse
or repair will not be regulated (products, not waste). |
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Same with intact, off-spec CRTs sent for
recycling. |
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Used broken CRTs sent for recycling are
conditionally excluded from haz waste requirements if they comply with
universal waste-type packaging and labeling requirements for storage and
shipping. |
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Whole used circuit boards and shredded circuit
boards headed for recycling will continue to be exempt |
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40 CFR 261.4 (a)(13) and (14) |
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Households still exempt |
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Conditionally Exempt Small Quantity Generators
still not subject to most Subtitle C regulations |
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CRTs that are sent for potential reuse or repair
are commodities not waste |
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Intact, off-spec. CRTS sent for recycling are
not wastes |
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Used and unused CRTs sent for disposal will
remain regulated as a waste |
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Regional rule used for eCycling pilot |
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Partners: |
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DE, MD, WV, VA, PA |
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Sony, Panasonic, Sharp, Envirocycle Inc., Waste
Management Asset Recovery Group, Elemental Inc., Electronic Industries
Alliance |
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Polymer Alliance Zone of West Virginia |
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Pulled back due to adverse comments, awaiting
national rule change |
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Study currently being conducted by the
University of Florida puts greater emphasis on waste characterization |
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CPUs have failed the Toxicity Characteristic
Leaching Procedure (TCLP) for lead a majority of the time. |
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Maximum concentrations of contaminants for the
toxicity characteristic: 40 CFR 261.24 |
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Original generator is ultimately responsible for
the management of hazardous waste. |
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Critical importance: source of the hazardous
substances that are contributing to the release and parties responsible |
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Interpretations of intent and motive are made by
the Courts on a case-by-case basis. |
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Due Diligence: Questions to ask your selected
reuser, refurbisher, or recycler |
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Certification |
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International Association of Electronics
Recyclers has developed a standard www.iaer.org |
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Other groups developing Best Practices |
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Organization for Economic Cooperation and
Development, Basel Action Network |
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ISO standards, using Environmental Mgmt. Systems |
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The U.S. EPA has no certification program for
electronics recyclers |
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Although some advertise themselves as such: |
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“AN EPA APPROVED COMPUTER RECYCLING COMPANY” |
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“U.S. EPA FILES $111,199 COMPLAINT AGAINST
MANHATTAN COLLEGE FOR HAZARDOUS WASTE VIOLATIONS” |
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www.epa.gov/region02/news/2002/02074.htm |
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EPA Region 5 Electronics webpage |
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www.epa.gov/region5/solidwaste/electronics.htm |
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RCRA Hotline |
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www.epa.gov/epahome/cfr40.htm |
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1-800-424-9346 |
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