What kind of “reasonable efforts” must generators make for intermediate facilities and for reclaimers?
Under the regulations, a generator makes reasonable efforts by addressing a series of questions for each reclamation facility and any intermediate facility to which hazardous secondary materials are sent. The questions include an evaluation of the facility’s environmental compliance history, technical capacity for safely managing and recycling the hazardous secondary material as well as any residuals generated, and notifications to appropriate authorities, including whether the facility has financial assurance. Such inquiries, which can be thought of as a kind of “environmental due diligence,” are currently conducted as a normal business practice by many generators. Under the new rule, generators do not have to make “reasonable efforts” if they ship materials to a RCRA permitted reclamation facility. We believe that RCRA permits provide adequate assurance that reclamation facilities will manage and reclaim excluded materials safely and legitimately.
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