Analysis - The Institute for Southern Studies

2. Electroplating wastewater sludge: Listed hazardous waste (F006) that is recycled for its copper, zinc, and nickel content for use in the
commercial market. In 2007, approximately 35% of F006 material was recycled according to BRS data. These materials are clearly in
no way stigmatized in the marketplace.
3. Chat: Superfund cleanup waste with lead contamination is used in road construction in Oklahoma and the surrounding areas. In this
case, the very waste that has triggered an expensive Superfund cleanup is successfully offered in the marketplace as a raw material in
road building. The alternative costs of disposal in this case are a significant driver in the beneficial use of this material, and the
Superfund origin of the material has not prevented its use.
4. Used oil: Frequently a hazardous waste if disposed of, and is regulated under the RCRA subtitle C standards. While used oil that is
recycled is subject to a separate set of standards under subtitle C (and is not identified as a hazardous waste), “stigma” does not prevent
home do-it-yourselfers from collecting used oil, or automotive shops from accepting it and sending it on for recovery. Collected used
oil may be re-refined, reused, or used as a fuel in boilers, often at the site where it is collected. One large commercial used oil handler
reports managing 500 million gallons of used oil a year.
5. Spent etchants: Directly used as ingredients in the production of a copper micronutrient for livestock.
6. Spent solvents: Generated from metals parts washing are directly used in the production of roofing shingles.
And in all such cases, these materials are generally RCRA hazardous wastes before reclamation. Many materials widely used in homes today
can be classified as “hazardous” materials, and many come with warning labels. For example, motor oil comes with warning labels. Gasoline
would be a characteristic hazardous waste if disposed of, as would many common drain cleaners and household cleaners. Cathode ray tube
monitors for TVs and computers, as well as many fluorescent lamps are all hazardous wastes if disposed of. Fluorescent lamps (and CFLs) are
potentially hazardous when disposed of because of mercury. Mercury is an indispensable resource, and virtually all of the mercury used for
lamps and other uses in the U.S. is derived from discarded mercury or mercury products – that is, from hazardous waste. Even products as
unlikely as nicotine gum or dental amalgam would be a hazardous waste when disposed of. Consumers are generally comfortable with these
products, and their regulatory status does not discourage their use.
Differing Views About Prospect of Future “Stigma”
Stakeholders have also expressed the concern that standards-setting organizations might prohibit the use of CCR in specific products or
materials in their voluntary standards. Recently, the American Standards and Testing Materials (ASTM) International Committee C09, and its
subcommittee, C09.24, in a December 23, 2009 letter to EPA indicated that ASTM would remove fly ash from the project specifications in its
concrete standard if EPA determined that CCR were a hazardous waste. However, ASTM standards are developed through an open consensus
process, and current standards cover the use of numerous hazardous materials in construction and other activities. For example, ASTM
provides specifications for the reuse of solvents and thus, by implication, does not appear to take issue with the use of these recycled wastes,
despite their classification as hazardous wastes. 137
137 For example, see ASTM Volume 15.05, Engine Coolants, Halogenated Organic Solvents and Fire Extinguishing Agents; Industrial and Specialty Chemicals, at or
ASTM D5396 - 04 Standard Specification for Reclaimed Perchloroethylene.
158