Pros of not hitting the hazardous waste manifest by shipping to a VRE


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Not hitting the hazardous waste manifest and shipping to a verified recycling exclusion (VRE) facility has benefits such as it reduces costs, risk of fines or penalties for not meeting requirements, preventing the environmental risk of contamination, and helping in keeping up with federal law.

Not shipping as hazardous waste and shipping to a verified recycling exclusion (VRE) facility has benefits such as reduced cost, reduced risk of fines or penalties for not meeting regulatory requirements, exclusion from Hazardous waste taxes, and increased volumes for sustainability reporting.

Does The Verified Recycling Exclusion (VRE) apply since EPAs 2018 DSW rule?

Time, money, and  risk reduction

One benefit of not shipping on a Hazardous Waste Manifest and shipping it to a verified recycling facility is that you can save time, money, and disposal risk reduction.

You can reduce the risk of hazardous waste fines by shipping to a verified recycling exclusion (VRE) facility. Once declared a Hazardous Secondary Material (HSM) it is no longer held to the 90-day requirements, only speculative accumulation allowing the customer to hold material for at least one year. HSM is not taxed, nor is it tracked like hazardous waste.

When HSM is processed at Thermaldyne the residuals of processing are new waste or product, thus releasing the material of potential Hazardous waste codes it would have carried through had it not gone to a VRE Facility.  This reduces significantly the disposal risk as opposed to sending your material to a RCRA part B facility that is not a VRE.  Because VRE residuals are a new point of generation, waste determinations often render them non-hazardous, allowing Generating Facilities to ship these residuals without carrying through hazardous waste codes to any destination within or outside the United States.

Keeping up with federal and state law

In 2018 The VRE regulations were replaced With the Transfer Based Exclusion (TBE) Regulations. It is important to note that in states where the TBE regulations are in effect, facilities may ship their HSM to VRE facilities in other states.

Each State has specific notification requirements for facilities wishing to utilize the VRE all based around the EPA notification requirements Feel free to contact us regarding your state's specific requirements. 

Conditions to VRE regulations

Because VRE residuals are a new point of generation, waste determinations often render them non-hazardous, allowing Generating Facilities to ship these residuals without carrying through hazardous waste codes to any destination within or outside the United States.

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ABOUT THERMALDYNE

Thermaldyne, an environmental solutions company, uses innovative technologies to reclaim oil-bearing materials in a sustainable, clean, and efficient manner to save companies time, money, and resources. The plant design separates materials into treated water, reclaimed oil, and recyclable solids. Thermaldyne’s team is composed of professionals with decades of experience in environmental management and the oil and gas industries.

Thermaldyne offers refineries access to the largest thermal desorption and separation plant in the USA. Focused solely on treating refinery materials, our services are designed to help your plant increase its sustainability by diverting your oil bearing materials from landfills to our plant, where they will be treated using our compliant, clean and efficient reclamation processes.


References

Hazardous Waste Manifest System - https://www.epa.gov/hwgenerators/hazardous-waste-manifest-system