REGULATORY STATUS OF ABSORBENT MATERIAL WHEN MIXED WITH HAZARDOUS WASTE PRIOR TO INCINERATION
RCRA Online Number:
11694
Date:
09/04/1992
To:
MacBeth
From:
Lowrance
Organization of Recipient:
Sidley and Austin
Description:
Mixing sawdust with hazardous waste prior to incineration is part of the incineration treatment train and is generally considered regulated treatment. Mixtures of hazardous waste and absorbent or sawdust may be hazardous waste via the derived-from rule (SEE ALSO: 66 FR 27266; 5/16/01). Absorbing or mixing listed hazardous waste with sawdust does not make the waste nonlisted. The determination of whether the entire volume of the mixture of absorbent material and hazardous waste is counted against the incinerator’s maximum permissible hazardous waste inventory or mass feed limits is made by the state or Region.
