| | [No title] |
 | | Gerwert, when a material (e.g., an ignitron tube) is being sent for reclamation, it is necessary to determine what type of secondary material it is in order to define the material as a solid waste under Subtitle C of RCRA. |
 | | If the ignitron tube is considered a solid waste under 40 CFR Section 261.2(c), the unit would likely be a hazardous waste because the mercury component may exhibit the hazardous waste characteristic of EP toxicity. |
 | | The non-functional ignitron tubes from the welding equipment meet the definition of spent material and are solid waste under Subtitle C of RCRA when sent for reclamation (mercury recovery). |
| yosemite.epa.gov /OSW/rcra.nsf/Documents/FB58B06CC44A6647852566110067ACF9 (608 words) |