Strategy:  Classify a RCRA Hazardous Waste Stream as a Comparable Fuel.

Candidates:  Clean, Energetic Waste Stream.

Potential Cost Savings:  $50,000 to Greater than $1,000,000 per Year.

Facilities generate wastes that are often classified as hazardous under the RCRA regulations. As hazardous waste, the management of the waste remains subject to stringent and costly regulations from the point of generation through the ultimate point of disposal. The RCRA regulations also include the RCRA Comparable Fuels Exclusion that allows facilities to greatly reduce their regulatory and financial burdens by reclassifying certain hazardous waste as a comparable fuel. By classifying a hazardous waste as a comparable fuel, facilities benefit by minimizing their RCRA cost, liability, and regulatory burden.

To classify a hazardous waste as a comparable fuel, the facility must demonstrate that the hazardous waste stream meets the definition of a comparable fuel. This demonstration must be supported by waste analysis data that accurately characterizes the physical and chemical composition of the waste stream. The RCRA Comparable Fuel Exclusion is self-implementing. Thus, Agency approval is not required. However, the facility must establish a sampling and analysis program, preferably a feedstream analysis statistical program, to continually demonstrate compliance with the comparable fuel exclusion definitions.

The return on investment for a RCRA Comparable Fuel Program is significant waste management cost savings for the facility. RCRA Comparable Fuel Programs are smart compliance strategies.