What you do with stuff at your facility is completely dependent on how that stuff is defined by the law and regulations in the state you are in.
The problem is, and always will be, how one party "sees" the definition.
Let's look at it this way. Let's say that we have rule that if a dress is white and gold you get to drive a limousine directly to the prom. If the dress is blue and gold, you must do 25 chores before you can go to the prom, and if you do not do those chores I am going to take money out of your bank account to punish you.
White and gold dress - easy trip to the prom. Blue and gold dress, lots of chores ahead of you and possible fines if you don't do them.
So, what color is this dress?
Reddit had a whole bunch of posts on this issue. I see blue and gold. My wife sees white and gold.
The point here is how one "sees" the definition as either meeting, or not meeting, the stuff they have at their site.
If you get the definition wrong, that is, you see a white and gold dress and go directly to the prom,but the same dress is seen as blue and gold by some authority, well you went to the prom without doing those chores. It starts the domino effect whereby the initial determination creates the large fines that get imposed.
You can see the same type of domino effect in play in my series of posts on Air Product's claim that the sulfuric acid they produced was a product and not a waste. Get it wrong and all those things you were supposed to do for a hazardous waste were never done, because you said it was not a hazardous waste.
What a wacky world we find ourselves in.
So on to the boring stuff of definitions and regulations. This is how the sausage is made. If you can't stomach that part, well, stop reading here and enjoy this picture of a cat.
Next post: Part 3