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Spent carbon status depends on use.
Activated carbon is very useful because it can be used to filter organics, metals, and some other chemicals from liquids and gases. When activated carbon has adsorbed its capacity of the target chemicals, the spent activated carbon is often sent for offsite recycling. What is the status of this material when it is shipped offsite?
It depends. Spent activated carbon is normally considered a “spent material” and solid (potentially hazardous) waste when reclaimed. [§261.2(c)(3)] However, when the carbon is used for air or water pollution control, it is considered a “sludge ” under RCRA. In this case, if the spent carbon exhibits a hazardous characteristic but carries no listed hazardous waste codes, it is not a solid waste when reclaimed. If it carries listed codes, it would be a solid and hazardous waste when reclaimed. [RO 11143, see also RO 11089]
Many states have adopted the transfer-based exclusion in §261.4(a)(24–25). If you (and the receiving facility) can qualify for this exclusion, the spent carbon would not be a solid waste when reclaimed, regardless of its status above. But beware of interstate transport issues. Visit our website and find more compliance morsels.
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McCoy and Associates, Inc. makes no representation, warranty, or guarantee in connection with any guidance provided above. McCoy and Associates, Inc. expressly disclaims any liability or responsibility for loss or damage resulting from its use or for the violation of any federal, state, or municipal law or regulation with which such guidance may conflict. Any guidance above is general in nature related to the federal environmental regulations. Persons evaluating specific circumstances dealing with environmental regulations should review state and local laws and regulations, which may be more stringent than federal requirements. In addition, the assistance of a qualified professional should be enlisted to address any site-specific circumstances.
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