Strategy:  Apply RCRA Regulatory Exclusions to Hazardous Wastes, Hazardous Waste Management Activities, and/or Units

Candidates:  Materials such as Recyclable Materials, Used Oil, Universal Wastes, and Certain Other Materials. Units such as Wastewater Treatment Units, Elementary Neutralization Units, Closed-Loop Recycling Units, and Totally Enclosed Treatment Facilities.

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, however, include many exclusions for certain types of waste and waste management units that allow facilities to greatly reduce their regulatory and financial burdens by taking advantage of these exclusions. Exclusions for a particular type of waste may allow the waste to be excluded from regulation as a solid waste and/or hazardous waste. The exclusions for certain types of hazardous waste management units may allow those units to operate without a RCRA permit. By utilizing these exclusions, facilities can benefit by minimizing their RCRA cost, liability, and regulatory burden.

CS2 Inc.’s RCRA regulatory experts are well versed in the exclusions that are available for waste and waste management units. We can assess your waste, waste management units, and operations to identify the exclusions that are right for your facilities.