Ecology home > HWTR home > DW Annual Report > Frequently Asked Questions > General Reporting Questions > What are the special reporting requirements? > Recycling Credit (optional)

Recycling Credit (optional)

What are recycling credits?

Recycling credit is the percentage of a recurrent waste reclaimed in an off-site recycling process performed by a TSDR facility. Recycling credits reduce the amount of your waste that Ecology will use to calculate whether you must prepare a Pollution Prevention Plan and/or pay a Pollution Prevention Planning Fee.

Who can obtain the recycling credit?

Generators qualify for recycling credits on their GM Form if:

• You generated 2,640 pounds or more of recurrent waste and the dangerous waste residuals of recurrent waste (rather than non-recurrent waste); and
• You sent all or part of this waste off-site to a TSDR facility for recycling.

Ecology does not count waste recycled on-site for Pollution Prevention Planning. To obtain guidance from Ecology on counting dangerous waste generated versus dangerous waste recycled, see Ecology Publication # 98-414, Counting Dangerous Waste under the Dangerous Waste Regulations.

How do recycling credits work?

Ecology calculates a generator's recurrent wastes each year to find out if the generator must prepare a Pollution Prevention Plan and/or pay the Pollution Prevention Planning Fee.

If you generated at least 2,640 pounds of recurrent waste in a year, you meet the threshold for preparing a Pollution Prevention Plan, according to the Dangerous Waste Regulations, WAC 173-307-010. You may also be required to pay a Pollution Prevention Planning Fee based on the amount of recurrent waste you generated.

Recycling credits let you deduct portions of your recycled waste from the total amount of recurrent waste you generated. This deduction has several benefits:

• If you fall below the 2,640-pound Pollution Prevention Plan threshold you will not have to prepare a Pollution Prevention Plan or pay the associated Pollution Prevention Planning Fee; or
• If you do not drop below the 2,640-pound threshold, you may still reduce the total amount of the Pollution Prevention Planning Fee that you are required to pay. Refer to Ecology publication #03-04-019, The Twelve (12) Most Frequently Asked Questions About Recycling Credits.

How do I obtain the recycling credit?

If you sent a recurrent waste stream off-site to receive one of the qualifying types of recycling management (see below, What type of management is considered recycling?), you must contact your TSDR facility to learn what percentage of your waste stream was recycled. Contact the TSDR facility and ask for written documentation, attesting to the percentage of your waste stream that was recycled. The TSDR facility must include in the documentation the identification of the waste stream recycled (by waste description and waste form), the Management Method Code indicating the type of management the waste received, and the percentage recycled during the reporting year. An authorized representative of the TSDR facility must sign and date the documentation provided to you. See Management Method Codes.

How to report recycling credit on the GM Form

 Use the information the TSDR facility provides to complete your GM Form for the waste stream.

• B-4 iv - Enter the percent of the waste stream that was recycled by the TSDR facility.
• Use whole numbers, (i.e., if 20 percent of the waste was recycled, enter 20 not .20).
• Round off fractions, two digits are the maximum allowable value. Do NOT enter the % symbol.
• Leave this question blank if no credit is being claimed (do not enter 0 or x).

Note: Claims for 100 percent recycling credit will be denied, because all recycling processes leave residue.

Remember that recycling percentage information is specific to the waste stream and TSDR facility combination, as illustrated in the following examples:

• You sent the waste stream to two different TSDR facilities during the reporting year. Only one of the facilities recycled the waste. You may only apply the recycling percentage to the amount of the waste stream that went to the facility where the recycling activity occurred.
• You sent the waste stream to two different TSDR facilities during the reporting year. Both facilities performed some type of recycling process on the waste. Facility A reclaimed 20 percent. Facility B reclaimed 30 percent.
  • You may apply the 20 percent credit only to the amount of waste that went to Facility A for management.
  • You may apply the 30 percent credit only to the amount of waste that went to Facility B for management.

What type of management is considered recycling?

Only certain types of management constitute recycling for purposes of obtaining the recycling credit. The qualifying management types are listed below, by Management Method Code. See Management Method Codes.

The following are examples of how Management Method Codes may be assigned to common off-site recycling activities.

• You contract with a TSDR to manage organic spent solvents. The TSDR manages the solvents through solvent distillation. Use Management Method Code H020 solvents recovery.

• You generate a lacquer thinner that you send off-site for distillation. Use Management Method Code H020, solvents recovery.

• You generate a metal-bearing sludge, which is dried to produce a filtercake. You send the filtercake off-site to a metal smelter for smelting. The appropriate Management Method Code is H010, metals recovery.

• You generate a contaminated ammonia-based etchant in the process of printed circuit board manufacture. You send the etchant off-site to a company that vaporizes the liquid and then recovers the metal through further processing. Assign Management Method Code H010, metals recovery.