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9451.1989(01) RECYCLING ACTIVITIES MAY 31989 Alan H. McLean Hughes Hubbard and Reed Madison Avenue New York, New York 10017 Dear Mr. McLean: This letter is in response to your letter dated March 2, 1989, requesting a written interpretation of aspects of the Resource Conservation and Recovery Act (RCRA) implementing regulations applicable to recycling activities (40 CFR Parts 124,264,265,266,268 and 270). It is my understanding that Environmental Technology Group's (ETG's) operation involves a mobile recycling unit that visits hazardous waste generator sites. Used solvents are pumped into the mobile unit through hoses connected to the generators' storage tanks or containers and a horizontal thin film evaporator is applied to reclaim reusable solvents. The reusable solvents are then pumped back into the generator's product tanks or containers. All rinsings and non-recoverable residues exiting from the mobile unit are placed in waste containers and remain on-site as the property of the generator. In your letter, you reached several tentative conclusions regarding the applicability of certain RCRA regulations to your process. I have discussed those Federal regulations below to clarify how they would apply to your activities. However, it should be noted that in states that are authorized to implement the RCRA program, the state regulations,rather than Federal regulations, are applicable. The state program can be broader-in-scope or more stringent than the Federal counterpart, so ETG should check all applicable state standards before deploying its mobile recycling units. The first question raised is,who is considered the generator of the residue or still bottom resulting from the recycling of the spent solventby ETG's units. EPA considers the original generator of the spent solvents and ETG to be RO 13280