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Exclusion for shipping metals laden waste for recycling?

I have found a facility that takes electropolishing sludge containing heavy metals and strips out the nickel for recycling. They said there is an exclusion for sludge going for recycling that allows it to be shipped as non-hazardous material. But, they never can quote a chapter and verse of the CFR. Any ideas?

Is there enough nickel in stainless steel pickling sludge to warrant this type recycling?

Todd Turner
- Monroe, Louisiana
2004

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Haz waste exemptions by recycling: 40CFR261.6(c)(2) for wastes recycled on site, without storage. Metal containing waste is generally going to be subject to the same regulation as waste which is disposed. There are some exceptions, for example storage time, but until and unless your recycler can show you clearly where in the regulations there are exemptions, you should continue to treat waste treatment sludge as hazardous waste. Is is unlikely that there is enough nickel or chromium in waste pckle solution to make recalimation economically viable.

Jeffrey Holmes, CEF
Spartanburg, South Carolina
2004