Non-Permit Treatment - Elementary Neutralization

RCRA §260.10 defines an elementary neutralization unit (ENU) as a device which is: (1) used for neutralizing wastes that are hazardous only because they exhibit the corrosivity characteristic defined in §261.22, or they are listed in Subpart D of Part 261 for this reason; and (2) meets the definition of tank, tank system, container, transport vehicle, or vessel in §260.10.

Laboratories managing hazardous waste in an elementary neutralization unit as defined above, are considered to have a permit-by-rule per §270.1(c)(2)(v). Thus, all wastes managed in an ENU are exempt from Subtitle C regulation while they remain in the unit. Once the waste is removed from the unit it becomes fully subject to all applicable federal, state, and local regulations. Generators should insure that wastes meet pH parameters and other discharge limits prior to disposal in a POTW sewer system.