Avoiding the RCRA Net, 1995 Environmental Conference Proceedings

Kevin J. Finto

Hunton & Williams

Charles A. Perry

Hunton & Williams

Until recently, the paper industry operated under the belief that the hazardous waste management requirements imposed by the Resource Conservation and Recovery Act (RCRA) did not apply to wastes generated in the pulp and paper making process. This belief was fostered in large part by the exclusion to the definition of hazardous waste afforded to pulping liquors (i.e., black liquor) that are reclaimed but not accumulated speculative1y. l/ In the 1990s, EPA, and in particular EPA Region IV (the Southeastern United States), has confronted the industry with new dimensions of the RCRA regulatory net. Given the site specific nature of RCRA problems, it is not possible to list, much less describe, all possible RCRA-related pitfalls or defenses that might arise at a pulp and paper mill. This paper discusses in general how RCRA might apply to paper industry wastes, and how mills can minimize the burden imposed through examination of some basic regulatory definitions and exemptions.