Comment submitted by P. Norton

Document ID: EPA-HQ-RCRA-2010-0742-0020
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: July 29 2011, at 12:00 AM Eastern Daylight Time
Date Posted: August 3 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: July 22 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: September 20 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80ecfc45
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This is comment on Proposed Rule

Definition of Solid Waste

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The current definiton of solid hazardous waste is too restrictive and does not promote recycling of solid materials that are contamiinated by hazardous chemicals. Additionally, the definiton does not allow % weight/weight contamination of hazardous chemical vs. non-hazardous component to be considered when characterizing the waste. Thus, contaminated solids that could go to recycling must be entirely managed as 100% hazardous waste. There are a plethora of tests (TCLP, etc.) that do not have a central decision-tree approach on which tests should be done under what circumstances to properly determine potential for hazardous solid waste recyclability. And, for mixed biological waste and hazardous waste, EPA has no definition whatsoever on how this waste should be managed; California does have a regulation on such mixed waste.

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