No. Under 40 CFR 261.4(a)(23) hazardous secondary materials may be reclaimed without a RCRA Part B permit, so long as certain criteria are met. For example, the reclamation must be done “under the control of the generator” or to a “verified reclamation center”. These exclusions have been enacted by EPA in order to tighten control over certain facilities that previously recycled hazardous secondary materials at non-RCRA Part B facilities invoking other prior rulings under “immediate processing” exemptions. Under the current rules, EPA requires any facility that recycles hazardous secondary materials, such as most solvents, to comply with keeping certain records and maintaining financial criteria to ensure the site does not end up as an abandoned or Superfund site.
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