Presentation to the AWMA Southern Section Annual Meeting. Greg Young moderated and Clark Spoden was a presenter along with Robert S. Nakamoto, P.E. CHMM, TDEC; Rick Whitson, P.E., TDEC; and Janet G. Evans, Eastman Chemical Company.

Overview / Background

• Threshold - materials that are not a solid waste are not subject to regulation under RCRA
• Key component - to be a waste subject to RCRA, the material must be "discarded"
• 2008 Rule - encourge recycling by expanding materials that are not considered "discarded"
• 2009 Sierra Club administrative petition - settlement agreement
• 2011 Rule - proposed amendments to 2008 Rule
• 12/31/2012 - 2011 Proposed Rule expected to have gone into effect