The Manufacturing Process Unit (MPU) Exclusion of 40 CFR 261.4(c)
In most situations a hazardous waste is generated as a recognizable by-product, spent material, sludge, or residue of a manufacturing process. Typically, the the moment a hazardous waste is generated (its point of generation) it is immediately contained in a hazardous waste management unit and becomes subject to the RCRA regulations. However, there are times when a hazardous waste’s point of generation may be within and/or part of a manufacturing process, such as in a process tank or pipeline. In this case, must it be managed as a hazardous waste while it remains in the process tank or pipeline? (more…)