Page 21 - North American Clean Energy March/April 2020 Issue

AJ Orben is Vice President, and Dwight Clark is Director of Compliance and Recycling Technology at We Recycle Solar, a single-source disposal provider for excess, recalled, and end-of-life solar products.
We Recycle Solar /// werecyclesolar.com
so determined. Waste determination is made by either the sampling and analysis of the waste stream (and comparison to regulatory levels), or by using generator knowledge (typically obtained from the OEM or recycler). If a representative sample of the waste exceeds the thresholds for a Hazardous Waste, the materials will be regulated at a much higher level than municipal waste.
Be sure to look for our article – Part 2 in the series – in the next issue, where we show you how to handle solar module waste. We’ll provide several practical steps to determine the need for regulatory requirements around the management of used solar modules.
What makes something a hazardous waste?
The EPA defines “Hazardous Waste” very specifically. It can even differ from state to state. To identify your solar panels as hazardous waste, you must complete a determination based on a “representative sample”. Misclassifying hazardous waste as non-hazardous can result in huge penalties. Conversely, over-classifying non-hazardous waste
as hazardous could squander valuable dollars, and unnecessarily increase your company's liability. The accuracy of hazardous waste characterization will also have a direct impact on effectiveness of mandated labeling, storage, segregation, and disposal requirements.
What Steps should an organization take in managing used solar components?
Develop a comprehensive program that provides the framework for meeting all legal requirements, and for directing staff on the day-to-day management of materials. In the US, most recycling is not regulated by the EPA, and there is no regulation in place regarding reuse.
Key Terms
Waste - A waste is any material that
is discarded. A material is discarded if it
is abandoned or relinquished, recycled,
or considered inherently waste-like. In general, a solar panel becomes a waste when the generator decides to discard
it, or when it’s removed and can no
longer be used for its intended purpose.
PV Equipment destined for reuse is not considered waste if it can still perform as initially intended. Therefore, PV equipment discarded due to early upgrades or excessive degradation is NOT considered waste. The EPA has numerous exclusions and exemptions from regulation as a
Solid Waste. Because these regulations
are complex, it’s important to use an experienced environmental professional in making these determinations.
Hazardous Waste - For a waste to be considered hazardous, it must meet these two conditions: 1) It must first be a waste; and 2) It must be deemed hazardous through a waste determination.
Waste Determination – The party that generates the waste must make the hazardous waste determination, and manage the waste as hazardous if
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North American Clean Energy
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