Managing Hazardous Secondary Materials
Forms, definitions, rules, and guidance. Requirements for managing, shipping, exporting HSM and notifying TCEQ.
On this page:
- Definition and Rules
- Management Requirements
- Notification Requirements and Forms
- Interstate Travel
- Exporting HSM
- Non-waste Determination and Variance
- TCEQ Guidance
- EPA Guidance
Definition and Rules
HSM are specific types of waste that, if recycled, may be excluded from the definition of solid waste. There are three types of HSM exclusions:
- Generator Controlled Exclusion (40 Code of Federal Regulations (CFR) 261.4(a)(23) ),
- Transfer Based Exclusion (40 CFR 261.4(a)(24) )
- Remanufacturing Based Exclusion (40 CFR 261.4(a)(27) )
A description of HSM exclusions can be found at Solid Waste: Hazardous Secondary Materials.
Management Requirements
Facilities managing HSM must maintain records of shipments and documents that the recycling is legitimate and beneficial and that there is a known market for the material. These recordkeeping and recycling requirements apply to:
- HSM generators - those who create HSM
- HSM reclamation facilities - those who recycle HSM
- HSM intermediate facilities - those who store HSM for more than 10 days but do not recycle it
For more detailed requirements on managing HSM, see the Hazardous Secondary Material section in our guidance document, “Can I Recycle Some of My Industrial or Hazardous Wastes?” (RG-240).
Notification Requirements and Forms
If you are an HSM generator, intermediate facility, or reclamation facility, you must notify TCEQ prior to managing HSM.
- An EPA ID number is required for managing HSM. To obtain an EPA ID number, send a completed Site Identification Form (EPA 8700-12)
to the IHW Registration and Reporting Program. We cannot process your notification until the EPA ID number is issued. You can skip this step if you already have an EPA ID number.
- Complete and submit the following group of forms:
-
- Waste Permits Division Correspondence Cover Sheet (TCEQ-20714) - Indicate "HSM Exclusion Notification," in Table 2, under “Other”
- TCEQ Core Data Form (TCEQ-10400)
- Copy of Site Identification Form ( EPA Form 8700-12) – form can be found at the end of the document
- HSM specific form ( Addendum to the Site Identification Form: Notification of Hazardous Secondary Material Activity ) - form can be found at the end of the document
- Only applicable for Facility Codes 07 and 08 – Closure Cost Estimate (state rule only ) and Financial Assurance. See TCEQ Guidance below for information about creating Closure and Post-Closure Cost Estimates (TG-10).
Submit an electronic copy of the forms listed above to IHWPER@tceq.texas.gov, and mail a hard copy to:
Texas Commission on Environmental Quality
Industrial and Hazardous Waste Permits Section
MC-130
PO Box 13087
Austin, Texas 78711-3087
Once received by TCEQ, HSM notifications can take up to 12 calendar days to process for Facility Codes 01 through 06, and up to 60 days for Facility Codes 07 and 08.
Interstate Travel
The requirements for handling and shipping HSM between states differ depending on which version of 40 CFR Section 261.4(a)(24) the generating and receiving state has adopted. Texas has adopted the 2018 Transfer Based Exclusion.
Where is the 2018 Definition of Solid Waste Rule in Effect?
The table explains how states with different adoptions of 40 CFR 261.4(a)(24) would affect HSM management. Refer to the table on page five of the document at the following link:
Status of HSM Shipments Depends on which Version of 40 CFR 261.4(a)(24) Has Been Adopted | Receiving State | |
2018 Transfer-Based Exclusion | ||
Generating State | ||
No Exclusion | Shipments are Hazardous Waste | |
2015 Verified Recycler Exclusion | Shipments Excluded if sent to RCRA Permitted Recycler | |
2018 Transfer-Based Exclusion | Shipments are Excluded |
Exporting HSM
- HSM exports are allowed with notice and consent by EPA under 40 CFR 261.4(a)(25) .
- HSM exported from the United States must be reclaimed at a reclamation facility located in a foreign country.
- You must notify EPA at least 60 days before the initial shipment. Notification may cover 12 months or a lesser period.
Non-waste Determination and Variance
To apply for a non-waste determination or a variance, please contact the IHW Permits Section at IHWPER@tceq.texas.gov.
TCEQ Guidance
- Guidance to assist those who recycle nonhazardous industrial waste, hazardous waste, or hazardous secondary material (RG-240)
- Texas regulations for how to manage HSM (30 TAC 335 Subchapter V)
- Financial Assurance Requirements (30 TAC 335.703)
- Cost Estimate Requirements (30 TAC 335.704)
-
For Facility Codes 07 and 08 –
Guidance for creating Closure and Post-Closure Cost Estimates (TG10)
(Note: in places where it indicates “waste,” replace with “HSM.”)
EPA Guidance
- EPA Definition of Solid Waste Final Rule
- Hazardous Secondary Material Requirements and the Definition of Solid Waste
- HSM Container Label example
- HSM Recycling Checklist (Checklist includes description of HSM, recycling process, accumulation start date, legitimate recycling, speculative accumulation limits, exclusions, etc.)