The Tech Box
August 22, 2023
The Resource Conservation and Recovery Act (RCRA) defines hazardous waste and sets regulations for its proper management. RCRA is our nation’s primary law governing the disposal of solid and hazardous waste. The F-List is a specific category under RCRA that includes wastes from certain standard industrial processes. Box plants may generate particular wastes that fall under the F-List category. The RCRA gives EPA the authority to control hazardous waste from cradle to grave, including generating, transporting, treating, storing, and disposing of hazardous waste.
Here are some examples of the potential F-List wastes generated in box plants from 40 CFR section 261.31:
1. F020: Spent solvents used in cleaning and degreasing operations. Including solvents like trichloroethylene or methyl ethyl ketone.
2. F022: Wastes from solvent distillation or distillation bottoms from solvent distillation or other units that use trichloroethylene.
3. F028: Unused paints or paint wastes containing certain heavy metals such as lead, chromium, or cadmium.
4. F034: Wastes from wood preserving operations, which may include treatment solutions containing arsenic, chromium, or copper.
5. F038: Wastes from non-specific source wood preserving operations, similar to F034 but from non-specific sources.
The goal of RCRA is:
Box plants must adequately identify and manage these F-List wastes to ensure compliance with RCRA regulations, including proper storage, labeling, and disposal.
When reporting F-List wastes, your facility may be required to submit a hazardous waste report (also known as the Biennial Report) to the Environmental Protection Agency (EPA) or your state regulatory agency. (Find examples of Biennial Reports here). This report provides detailed information about the types and quantities of hazardous wastes generated and information on treatment, storage, and disposal facilities used.
You should consult your state regulatory agency or an environmental consultant to determine specific reporting requirements and deadlines. You may also need to keep thorough records of waste generation, shipments, and disposal for documentation and potential future inspections.
Overall, proper management and reporting of F-List wastes from box plants are crucial to ensure compliance with RCRA regulations and to protect the environment and human health. RCRA F-List Waste Reporting is done biennially in even years, and the forms are filed by March 1. For a list of forms and instructions, follow this link to the RCRAInfo Web.
Chase Kammerer is the Technical Services Manager at Fibre Box Association (FBA). If you have technical questions about the corrugated industry, you can reach him directly at email@example.com.