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Show details for Air Emissions (RCRA)Air Emissions (RCRA)
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09/10/2014RESPONSE TO QUESTIONS ON PROCESSED CATHODE RAY TUBE (CRT) GLASS USED AS ALTERNATIVE DAILY COVERMemo
 Description: Grinding and stabilizing cathode ray tube (CRT) glass, a D008 hazardous waste, is considered treatment. Treatment of hazardous waste generally requires a RCRA Part B permit; however, a permit would not be required for treatment of CRT glass if such treatment is conducted by the generator of the hazardous CRT glass in compliance with applicable 40 CFR 262.34 generator requirements, as well as the Part 268 land disposal restrictions (LDRs), and the treatment is not thermal treatment. EPA Method 1311 must be used on CRT glass to determine compliance with the LDR treatment standards, and any underlying hazardous constituents in the CRT glass must be treated to attain the universal treatment standards in 268.48. If CRT glass is not excluded as a solid waste under 261.2(e)(1)(ii) or 261.4(a)(22), then that CRT glass would be subject to solid and hazardous waste regulations at the point of generation. The point of generation for CRT glass would be when a person decides to discard the glass and it becomes a solid waste, and the person making the decision is the generator of solid waste. CRT glass that has been treated in accordance with LDRs and that no longer exhibits hazardous characteristics may be disposed in a municipal or Subtitle D landfill, including use of treated CRT glass as alternative daily cover.
 
04/09/2008CLEANUP OF SOLID WASTE LANDFILLSMemo
 Description: Discussion of the value of diversion of compostable wastestreams for alternative processing as an alternative to solid waste landfills.
 
02/26/2008LANDFILL INFORMATION SOURCESMemo
 Description: Waste News maintains a listing of the 10 largest municipal solid waste landfills and largest landfills by State. All of the inventories are available on the web at http://www .wastenews.com/rankings/landfills_st2006.html. Information on municipal landfills within individual states can be found by contacting the Association of State and Territorial SoIid Waste Management Officials (ASTSWMO). 444 North Capitol St., NW Suite 315 Washington, DC. 20001 ASTSWMO maintains a listing on their individual State solid waste contacts on their web-site at: http://www.astswmo.org/resources_stateagencylinks.htm.
 
09/01/2006Solid Waste Management and Greenhouse Gases: A Life-Cycle Assessment of Emissions and Sinks; 3rd EditionPublication
 Description: This report examines how municipal solid waste management and climate change are related. Management of municipal solid waste presents many opportunities for greenhouse gas emission reductions. Source reduction and recycling can reduce emissions at the manufacturing stage, increase forest carbon storage, and avoid landfill methane emissions. Combustion of waste allows energy recovery to displace fossil fuel-generated electricity from utilities, thus reducing greenhouse gas emissions from the utility sector and landfill methane emissions. Diverting organic materials from landfills also reduces methane emissions.
 
06/14/2004MOVEMENT OF MUNICIPAL SOLID WASTE FROM CANADA INTO MICHIGANMemo
 Description: All municipal solid waste (MSW) must be disposed of in a MSW landfill that is licensed and regularly inspected. Landfills must comply with requirements including responsible siting, safe operation and design, regular ground water monitoring, corrective action, closure and post-closure care. U.S. Customs Service visually inspects trucks importing waste for suspicious leaks and uses x-ray and radiation monitoring equipment.
 
03/12/2004DISPOSAL OF CANADIAN MUNICIPAL SOLID WASTE IN MICHIGAN LANDFILLSMemo
 Description: Canada is permitted to send trash to the U.S. by international law. Imported waste is managed according to U.S. regulations. Landfills are licensed and inspected by the state. Federal RCRA requirements and state regulations have rules to make landfill owners prevent leaks into the soil and water, cover the waste every day, and operate the landfills under careful controls.
 
03/01/2004States May Issue Permit Variances for Municipal Solid Waste Landfills (Fact Sheet)Publication
 Description: This fact sheet discusses EPA's proposed modifications to the federal criteria for municipal solid waste landfills (MSWLF) to allow EPA-approved states to issue research, development, and demonstration (RD&D) permits to MSWLF. The purpose of this action is to stimulate the development and use of safe, new alternative operational processes for disposal of municipal solid waste in landfills.
 
12/16/2003DISPOSAL OF CANADIAN MUNICIPAL SOLID WASTE IN NEW YORK LANDFILLSMemo
 Description: Shipments of municipal solid waste (MSW) between the U.S. and Canada occur routinely. The U.S. has a well-established regulatory system to determine what can be responsibly managed in landfills. Properly permitted and compliant MSW landfills enable solid waste disposal that appropriately minimizes the risk to public health and the environment.
 
11/01/2002DISPOSAL OF WASTEWATERS AND THE LIQUIDS IN LANDFILLS PROHIBITIONQuestion & Answer
 Description: Wastewaters treated to meet land disposal restrictions (LDR) treatment standards must also satisfy the liquids in landfills prohibition in Sections 264/265.314 prior to landfill placement. The LDR treatment standards and liquids in landfills prohibition are independent and mutually exclusive requirements.
 
06/15/2002Environmental Fact Sheet: EPA Proposes Rule To Allow States To Issue Research Development and Demonstration Permits For Municipal Solid Waste LandfillsPublication
 Description: The Environmental Protection Agency (EPA) is proposing this action to add new provisions to the Criteria for Municipal Solid Waste Landfills (MSWLFs) that will allow approved states to issue research, development and demonstration (RD&D) permits for landfill operations.
 
09/14/2001STORAGE OF TOXIC MATERIALS IN AMERICAMemo
 Description: The Solid Waste Disposal Act and subsequent amendments include provisions to regulate the generation, treatment, storage, and disposal of hazardous waste. In most cases, hazardous waste must be treated before being placed in a secure landfill. Hazardous waste disposal facilities must receive permits from EPA, which include security features.
 
04/01/2000Environmental Fact Sheet: EPA Requests Information on Bioreactor Landfills and Performance of Alternative Liners for Landfills When Leachate is RecirculatedPublication
 Description: Announces that EPA is considering revisions to the Criteria for Municipal Solid Waste Landfills (40 CFR Part 258) with respect to the use of alternative liners when landfill leachate is recirculated and with respect to allowing the operation of landfills as more advanced bioreactors. Requests information from the public on these types of landfill processes.
 
11/01/1999Environmental Fact Sheet: Municipal Solid Waste Landfill Standards Available for CommentPublication
 Description: Announces EPA's review of MSW landfill standards under Section 610 of the Regulatory Flexibility Act.
 
09/24/1999MUNICIPAL SOLID WASTE LANDFILLSMemo
 Description: The number of municipal solid waste landfills (MSWLF) decreased from 8,000 in 1988 to 2,400 in 1996. In 1991, EPA created regulations on location, operation, design, and monitoring of MSWLFs. Handling trash is primarily the responsibility of state and local governments. The recycling of garbage increased by 67 percent between 1990 and 1996.
 
12/16/1998LANDFILL LEACHATE RECIRCULATION POLICYMemo
 Description: Leachate recirculation in municipal solid waste landfills (MSWLFs) is allowed in units that are constructed with a composite liner, but is not allowed in MSWLF units that are constructed with alternative liner designs. The statement in the “Solid Waste Disposal Facility Criteria - Technical Manual” indicating that the director of an approved state could allow leachate recirculation in MSWLF units constructed with alternative liner designs is incorrect. It is EPA’s intention to review and evaluate the technology of leachate recirculation and to propose a rule change in Fiscal Year 1999 if sufficient data is found to justify a change.
 
11/27/1998Environmental Fact Sheet: Procedures for Approving State Subtitle D Landfill Permitting ProgramsPublication
 Description: Describes EPA's requirements governing Subtitle D landfills, a major effort to improve the safety of solid waste landfills nationwide. Procedures allow states with approved permit programs flexibility in the way they choose to incorporate the federal requirements into their own solid waste management programs.
 
06/01/1998MONOFILLS EXEMPT FROM THE MINIMUM TECHNOLOGICAL REQUIREMENTSQuestion & Answer
 Description: RCRA contains no general statutory or regulatory definition of a monofill. RCRA Section 3004(o)(3) states that the minimum technological requirements (MTR) may be waived by the Administrator for any monofill under certain conditions. The unit must have at least one liner with no evidence of leakage, be located more than one-quarter mile from an underground source of drinking, and be in compliance with the applicable groundwater monitoring requirements (Section 3005(j)).
 
05/01/1998CRITERIA FOR MEETING THE SMALL, ARID, AND REMOTE MUNICIPAL SOLID WASTE LANDFILL EXCLUSIONQuestion & Answer
 Description: When determining whether a landfill meets the criteria for the small, arid, or remote landfill exemption, the amount of solid waste actually placed on the land (e.g., buried), must be counted toward the 20 tons per day average. Waste accepted for recycling or incineration need not be counted toward the average.
 
12/01/1997SITE-SPECIFIC FLEXIBILITY REQUESTS FOR MUNICIPAL SOLID WASTE LANDFILLS IN INDIAN COUNTRYMemo
 Description: The site-specific flexibility guidance is not intended to sanction illegal dumping activity or promote sub-standard landfill management practices on Indian lands; the document establishes a process to issue site-specific rules that provide owners and operators of municipal solid waste landfills (MSWLF) in Indian Country the same flexibility afforded to landfills in states with approved programs
 
09/18/1997DEFINITION OF “END OF OPERATING DAY” FOR MSWLFSMemo
 Description: States are responsible for issuing municipal solid waste landfill (MSWLF) permits, conducting site visits, enforcement, and all other implementation activities; owner and operators of MSWLFs in approved states should seek clarification on the definition of “end of an operating day” from their state agency.
 
09/01/1997Native American Network (September 1997)Publication
 Description: This issue of the Native American Network features the White Mountain Apache Tribe's efforts to close a former dump site and discusses two new EPA grant programs for Indian Country. Other articles include the formation of the Tribal Association on Solid Waste and Emergency Response (TASWER), EPA's Solid Waste Circuit Rider program, new flexibility for small landfills, expansion of the WasteWi$e program to tribal governments, Southern Ute Indian Tribe co-sponsors a solid waste round table with EPA, Tribal Operations Committee (TOC), and site-specific flexibility for landfills in Indian Country. Resources featured include grant resources for solid waste activities in Indian Country, publications on solid waste and mining waste management in Indian Country, and a tip sheet on the upcoming deadlines for municipal solid waste landfills.
 
08/01/1997Site-Specific Flexibility Requests for Municipal Solid Waste Landfills in Indian Country: Draft GuidancePublication
 Description: This document sets out a process designed to help owners and operators in requesting flexibility in federal municipal solid waste landfill (MSWLF) rules in Indian Country and to help EPA Regional offices in reviewing and processing such requests.
 
07/01/1997Geosynthetic Clay Liners Used in Municipal Solid Waste LandfillsPublication
 Description: Describes geosynthetic liners (GCLs), a new and innovative technology that meets federal performance standards of the Criteria for MSWLFs (40 CFR 258), used as a barrier system in MSWLF applications. Discusses GCL technology materials, hydraulic conductivity, shear strength and other characteristics, and testing. Lists available GCL products, their installation, and costs. Addresses performance factors and design and installation standards. Provides case studies. Includes references and sources of additional information.
 
07/01/1997Landfill ReclamationPublication
 Description: Describes landfill reclamation, a new and innovative technology that meets the federal performance standards of the Criteria for MSWLFs (40 CFR Part 258), used to expand MSWLF capacity and avoid the high cost of acquiring additional land. Discusses the reclamation process: excavation, soil separation (i.e., screening), and processing for reclamation of recyclable material or disposal. Lists steps in project planning: conduct a site characterization study, assess potential economic benefits, investigate regulatory requirements, establish a preliminary worker health and safety plan, and assess project costs. Discusses benefits and drawbacks. Provides case studies. Includes references and sources of additional information.
 
05/12/1997DISPOSAL OF FROZEN STRAWBERRIES CONTAMINATED WITH HEPATITIS A VIRUSMemo
 Description: The disposal of frozen strawberries contaminated with hepatitis A virus in a properly operated and maintained municipal solid waste landfill is appropriate and does not pose a risk of infection to disposal workers or the general public.
 
03/04/1997MUNICIPAL SOLID WASTE LANDFILLS AND OTHER WASTE MANAGEMENT METHODSMemo
 Description: No Congressional mandate exists for EPA to establish landfill standards that represent state-of-the-art technology. New landfills and lateral expansions of existing landfills must meet a performance standard based on releases to groundwater or be constructed with a liner and leachate collection system. Existing landfills may be lined or unlined (i.e., they are not required to retrofit liner systems). All landfill units must monitor releases, take corrective action in the event of a release, and meet post-closure care requirements. EPA requires financial assurance for all landfills by April 1997. The deadline may be extended for one year if the owner or operator has insufficient time to comply. Composting is a form of recycling. The solid waste management hierarchy considers source reduction to be the preferred solid waste management option, followed by recycling (including composting), combustion (with energy recovery), and landfilling. EPA has two on-going studies on resource recovery. An ORD study to develop a life-cycle inventory database and decision-support tool for solid waste managers and a study to develop a greenhouse gas emissions inventory for municipal solid waste.
 
03/01/1997Financial Responsibility for Municipal Solid Waste Landfills: An Introduction For Local Governments Publication
 Description: This document provides a brief overview of the requirements for owners and operators of MSW landfills to demonstrate financial responsibility for certain costs associated with their landfills, and enumerates the seven financial mechanisms that owners and operators may use to demonstrate financial responsibility. It also lists regional and headquarters MSW contacts.
 
02/01/1997DELAY OF CLOSUREQuestion & Answer
 Description: Owners and operators of hazardous waste surface impoundments, landfills, and land treatment units can delay the closure timetable beyond the 90-day period and allow the units to accept nonhazardous waste, if the units meet the conditions of Sections 264.113(d)/265.113(d). Owners or operators of tanks, containers, waste piles, and incinerators are not allowed to delay closure. These units must comply with all applicable closure standards before being able to accept nonhazardous waste.
 
01/01/1997LAND DISPOSAL RESTRICTION NOTIFICATION REQUIREMENTS FOR DECHARACTERIZED MIXED WASTE SENT TO AN ATOMIC ENERGY ACT LANDFILLQuestion & Answer
 Description: A generator treating prohibited characteristic mixed waste and rendering it nonhazardous must send a one-time notification and certification to EPA Region or authorized state if waste is sent to Atomic Energy Act (AEA) landfill; because 4004 prohibits open dumping of solid waste, the decharacterized waste can be sent to AEA landfill only if it meets Subtitle D criteria of Part 257 or 258
 
11/01/1996Environmental Fact Sheet: Assurance Mechanisms Finalized for Local Government Owners of MSWLFsPublication
 Description: The Local Government Financial Test was proposed December 27, 1993 in response to comments from local governments requesting flexibility in meeting the financial assurance requirements of the Solid Waste Disposal Criteria promulgated on October 9, 1991. The Test allows local governments to meet their financial assurance obligations for closure, postclosure care and corrective action pursuant to the Criteria by demonstrating their financial strength. The effective date for these financial assurance requirements is now April 9, 1997 (small, dry, or remote landfills have until October 9, 1997 to comply).
 
07/17/1996Reusable News (August/September 1996)Publication
 Description: This issue of Reusable News discusses the Full Cost Accounting Roundtable held by the International City/County Management Association, grants awarded by EPA's Jobs Through Recycling Program, an announcement of the second anniversary of the Waste Wi$e program, and information on reusing plastic packing peanuts and old mattresses. Also included in this issue is information on a meeting for industrial D Stakeholders, flexibility for small MSWLFs, closure and postclosure plans for MSWLFs and local governments, and managing solid waste on Tribal Lands. Additionally, several new documents are announced.
 
07/01/1996REGULATION OF LEACHATE COLLECTION SUMPSQuestion & Answer
 Description: Although a sump meets the definition of a tank, a leachate collection sump at a landfill is not subject to Subpart J tank standards because it is an integral part of the landfill liner system.
 
06/01/1996HAZARDOUS WASTE LIQUID-CONTAINING PUMPS AND THE LIQUIDS IN LANDFILLS PROHIBITIONQuestion & Answer
 Description: Owners and operators have three options for disposing of containerized liquids in landfills: remove liquid, add sorbent or solidify, or eliminate by other means. There is no requirement to dismantle pumps containing free liquids prior to disposal in a landfill under the liquid in landfill prohibition. There is no requirement to remove or sorb free liquids in containers such as pumps holding liquids for use other than storage.
 
05/30/1996List of Municipal Solid Waste LandfillsPublication
 Description: This document provides a list of municipal solid waste (MSW) landfills by state or territory.
 
05/30/1996STATUS OF MIXED COAL PRODUCTSMemo
 Description: Characteristic manufactured gas plant (MGP) wastes can be mixed with coal or other material in a generator accumulation unit until the characteristic is removed. The resulting mixture may be sent to a fossil fuel combustor provided the mixture is no longer characteristically hazardous. Combustion residues are exempt under the Bevill exemption for fossil fuel combustion wastes. If the mixture is sent to a landfill, it must meet land disposal restrictions (LDR) treatment standards regardless of whether the characteristic has been removed (SEE ALSO: 63 FR 28574; 5/26/98).
 
05/01/1996REVISIONS TO THE MUNICIPAL SOLID WASTE LANDFILL CRITERIA TO PROVIDE FLEXIBILITY TO STATES WITH EPA-APPROVED PROGRAMSMemo
 Description: The Land Disposal Program Flexibility Act of 1996 requires EPA to promulgate revisions to the municipal solid waste landfill (MSWLF) criteria to provide flexibility to states with approved programs to allow MSWLFs receiving less than 20 tons per day to use alternative frequencies for daily cover application and gas monitoring, and to allow alternative final covers and means to demonstrate financial assurance. The revisions must be promulgated by March 26, 1998. EPA is unable to predict a schedule for final rule promulgation. EPA believes small communities can carry out the current requirements without imposing a major resource burden (SEE ALSO: 62 FR 40708; 7/29/97).
 
02/27/1996CLARIFICATION OF THE ""MIXTURE RULE,"" THE ""CONTAINED-IN"" POLICY, LDR ISSUES, AND ""POINT OF GENERATION"" FOR U096Memo
 Description: U096 spilled on soil is subject to the contained-in policy. The contained-in policy does not specify levels at which contained-in determinations must be made. EPA leaves contained-in determinations to the discretion of the implementing agency. Under the Section 261.3(a)(2)(iii) mixture rule exemption, mixture of hazardous waste listed solely for exhibiting a characteristic (e.g., U096) and solid waste that no longer exhibits a characteristic can be disposed in a subtitle D landfill, but must still meet land disposal restrictions treatment standards (SEE ALSO: 268.3; 61 FR 18780; 4/29/96; 66 FR 27266; 5/16/01).
 
02/20/1996CLARIFICATION OF RCRA CORRECTIVE ACTION PROGRAM WITH REGARD TO TSD UNITSMemo
 Description: RCRA regulated units (surface impoundments, waste piles, land treatment units, and landfills) are solid waste management units (SWMUs). SWMUs are subject to RCRA corrective action authority (i.e., Sections 3004(u) or 3008(h)). Discusses integrated implementation of corrective action for releases to groundwater and other media from regulated units (SEE ALSO: Section 264.90(f) and 63 FR 56710; 10/22/98)). Dual authority is required when conducting cleanup at a regulated unit in a state authorized for RCRA groundwater requirements but not for corrective action. Changes necessary to comply with a corrective action order are exempt from the reconstruction limit. Closure need not be delayed to perform corrective action. EPA encourages coordination between closure and corrective action activities.
 
01/01/1996Environmental Fact Sheet: Proposed Procedures and Criteria for Determining Adequacy of State/Tribal Municipal Solid Waste Landfill Permitting ProgramsPublication
 Description: This fact sheet discusses the requirements for public involvement during the permit application process. It also describes the advantage of flexibility that a state or tribe will obtain with approval of their permitting program.
 
06/01/1995DESIGN CRITERIA EXEMPTION FOR SMALL, ARID, REMOTE MUNICIPAL SOLID WASTE LANDFILLSQuestion & Answer
 Description: Small municipal solid waste landfills (MSWLFs) in arid or remote areas (those that are exempt from MSWLF design criteria provided there is no groundwater contamination) must work towards compliance with design standards immediately upon the discovery of contamination.
 
05/15/1995Environmental Fact Sheet: Effective Date Delayed for Landfill Financial Assurance RequirementsPublication
 Description: This fact sheet summarizes a final rule under RCRA Subtitle D that delayed the effective date for compliance with financial assurance requirements for owners and operators of all municipal solid waste landfill facilities until April 9, 1997.
 
04/05/1995DELAY RULE FOR SUBTITLE D FINANCIAL ASSURANCEMemo
 Description: April 9, 1997 is the new deadline for municipal solid waste landfills to obtain financial assurance. This delay will allow the development of local government and corporate financial test mechanisms.
 
03/15/1995Report to Congress on Flow Control and Municipal Solid WastePublication
 Description: This report discusses flow controls, defined as legal authorities used by state and local governments to designate where municipal solid waste (MSW) must be taken for processing, treatment, or disposal. This report presents a comparative review of states with and without flow control authority, identifies the impact of flow control ordinances on protection of human health and the environment, and characterizes the impact of flow control on the development of state and local waste management capacity and on the achievement of state and local goals for source reduction, reuse, and recycling. Appendices include a summary of public comments on flow control; legal decisions concerning MSW flow controls; a summary matrix of state flow control authorities; flow control case studies; and technical analyses of waste generation, composting, recycling, waste-to-energy, and landfills.
 
03/07/1995APPLICABILITY OF THE HOUSEHOLD WASTE EXCLUSION TO LEAD-CONTAMINATED SOILMemo
 Description: Lead-contaminated soil at a residence is exempt household hazardous waste (HHW) if it is the result of routine stripping and painting or natural weathering of lead-based paint (LBP). LBP chips from stripping and repainting of residence walls by an owner or contractor are HHW. Construction, renovation, or demolition debris is not HHW (SUPERSEDED: See RPC# 7/31/00-01). Waste generated by home health care providers may be HHW. Media and debris contaminated by residential heating oil tanks are household hazardous waste (HHW). Covering residential soil containing hazardous waste with sod, mulch, or gravel does not constitute generation, treatment, or disposal of hazardous waste and triggers no Subtitle C obligations. HHW mixed with a regulated hazardous waste is subject to Subtitle C regulation. The Subtitle D regulations (Part 257 open dumping rules and Part 258 municipal solid waste landfill regulations) may not apply to household waste disposed on residential property.
 
02/15/1995Construction and Demolition Waste LandfillsPublication
 Description: Presents information on construction and demolition (C&D) waste landfills. Discusses the composition of C&D wastes, including any hazardous materials or constituents. Provides information on the quality of C&D landfill leachate, based on sampling data taken from landfills around the country. Contains a detailed summary of state regulations pertaining to C&D facilities. Identifies states that have regulations related to groundwater monitoring; corrective action; location restrictions; and facility design, operation, closure, and/or postclosure care; and provides the specifics of those regulations.
 
01/01/1995THE LIQUIDS IN LANDFILLS PROHIBITION AND SORBED FREE LIQUIDSQuestion & Answer
 Description: Wastes which contain free liquids and are containerized may be treated with a nonbiodegradeable sorbent and placed in a landfill. A non- containerized waste containing free liquids must be treated without absorbents before landfilling. Discusses chemical stabilization v. absorption criteria.
 
12/15/1994Environmental Fact Sheet: Revisions Proposed to Post-Closure Landfill RequirementsPublication
 Description: This fact sheet describes changes proposed to the post-closure care regulations for hazardous waste landfills under RCRA. The regulations recommend elimination of existing post-closure permit requirements and expansion of states' RCRA programs to include corrective action authority for interim status facilities.
 
10/01/1994STATUS OF MUNICIPAL WASTE COMBUSTION (MWC) ASHQuestion & Answer
 Description: Municipal waste combustion (MWC) ash is subject to regulation if it exhibits a characteristic. Discusses the history of municipal waste combustion regulation. Ash from waste-to-energy facilities is a newly-identified waste for purposes of the land disposal restrictions (LDR). (SEE ALSO: 59 FR 29372; 6/7/94; 60 FR 6666; 2/3/95; RPC# 3/22/95-01)
 
09/30/1994List of Industrial Waste Landfills and Construction and Demolition Waste LandfillsPublication
 Description: Provides an estimate of the number of industrial and construction and demolition (C&D) waste landfills in the United States. Presents state summaries, including number of facilities; date of data; list of additional data available from the state list; and the name, address, and telephone number of the contact who provided the information. Contains the state lists of active industrial and C&D waste landfills, sorted by county, city, and name.
 
09/29/1994APPLICABILITY OF CERCLA TO MERCURY-CONTAINING LAMPS AND PCB-CONTAINING BALLASTSMemo
 Description: Disposal of fluorescent lamps in a hazardous waste landfill is exempt from CERCLA reporting, but not from CERCLA liability or response provisions. The disposal of fluorescent lamps or ballasts in a Subtitle D landfill or a TSCA landfill is not exempt from CERCLA release reporting requirements.
 
09/14/1994QUALIFICATIONS NECESSARY TO PERFORM ENVIRONMENTAL REMEDIATION TASKSMemo
 Description: Discusses the methods for demonstrating that someone is a qualified groundwater scientist. The principles of the qualified groundwater scientist definition can be applied to related scientific disciplines such as environmental engineering. RCRA does not regulate the contents of a professional engineering certification.
 
07/18/1994WASTE MINIMIZATION REQUIREMENTS OF SECTION 3002(B) OF RCRA FOR HAZARDOUS WASTE DISPOSAL FACILITIESMemo
 Description: The 3005(h) waste minimization and certification requirements apply to an owner of a landfill that generates and has a RCRA Subtitle C treatment permit for F039 leachate. If the owner is a large quantity generator (LQG) and sends the waste off-site, the owner is also subject to the 3002(b) waste minimization requirements. There is no statutory exemption from waste minimization certification for facilities generating remedial waste.
 
06/23/1994ON-SITE TREATMENT OF MANHOLE SEDIMENT WHICH MAY EXCEED THE TOXICITY CHARACTERISTIC FOR LEADMemo
 Description: A material must exceed a 60 mm particle size to meet the debris definition. Debris stabilization with lime, fly ash, or portland cement is considered microencapsulation or immobilization and must be disposed of in hazardous waste landfill if characteristic, or may be disposed of in nonhazardous landfill if not characteristic. Nonhazardous disposal is subject to Section 268.9 for land disposal restrictions (LDR) notification, but not the hazardous waste manifest.
 
06/09/1994APPLICABILITY OF RCRA TO VARIOUS PRODUCTS (E.G., CLINKER, FERTILIZER) PRODUCED BY A CEMENT KILN EQUIPPED WITH A RECOVERY SCRUBBERMemo
 Description: Product clinker and fertilizer that are produced using previously landfilled Bevill exempt cement kiln dust are not subject to Subtitle C as long as the products are commercial grade, do not contain hazardous constituents in excess of those found in comparable products, and have met applicable land disposal restrictions (LDR) treatment standards (SEE ALSO: RPC# 5/17/94-01; 60 FR 6666; 2/7/95).
 
05/27/1994IMPLEMENTATION STRATEGY OF U.S. SUPREME COURT DECISION CITY OF CHICAGO V. EDF FOR MUNICIPAL WASTE COMBUSTOR ASHMemo
 Description: The implementation strategy following the Supreme Court Decision states Section 3001(i) does not exempt ash from resource recovery facilities burning household and nonhazardous commercial wastes. Waste-to-energy facilities must set up programs to determine if ash is hazardous and must manage hazardous ash in an environmentally responsible manner. Discusses factors to consider in an enforcement response (SUPERSEDED: see RPC# 3/22/95-01).
 
03/01/1994Reusable News (Spring 1994)Publication
 Description: This issue of Reusable News announces the Jobs Through Recycling Initiative, linking environmental and economic priorities. Other articles include managing disaster debris, landfill permitting programs, markets for old corrugated containers, painting recycled, media buying-recycled campaign, waste prevention activities in New York City and Seattle, and the degradable ring rule.
 
02/09/1994ALTERNATE FINAL COVER DESIGNS FOR SUBTITLE D LANDFILLSMemo
 Description: A state with an approved Subtitle D program has the flexibility to consider site-specific factors when interpreting and applying the regulations. It is neither necessary nor expected that an approved state or tribe will seek EPA agreement or interpretation of specific Subtitle D requirements. 258 does not explicitly require the use of a synthetic membrane in the final cover if the unit has a synthetic membrane liner at the bottom of the unit.
 
12/15/1993Environmental Fact Sheet: Financial Assurance Mechanisms Proposed for Landfill OperatorsPublication
 Description: Summarizes EPA's proposal providing local government owners and operators of municipal solid waste landfills additional flexibility in meeting federal financial assurance requirements.
 
11/17/1993REGULATORY STATUS AND MANAGEMENT OF LIQUIDS AND ABSORBENT MATERIALS CONTAINING LIQUIDSMemo
 Description: The liquids in landfills prohibition applies only to hazardous waste landfills. Sorbents that are used to clean up non-listed waste are hazardous only if they are characteristic. Liquids must be absorbed prior to placement in municipal solid waste landfills. Used oil is presumed to be recycled until it is sent for disposal. Sorbents containing used oil that will be burned for energy recovery are subject to Part 279. Sorbents that are defined as used oil that will not be burned for energy recovery are managed under Part 279 until they are disposed, even if they are characteristic.
 
11/15/1993Solid Waste Disposal Facility Criteria: Technical ManualPublication
 Description: This document was updated in April 1998 with a new introduction. Addresses general applicability of the Part 258 criteria, location restrictions, operating requirements, design standards, groundwater monitoring and corrective action, and closure and postclosure care for landfills. Includes the regulatory language, a general explanation of the regulations and who must comply with them, key technical issues that may need to be addressed to ensure compliance with a particular requirement, and information sources. Written for municipal solid waste landfill owners and operators.
 
10/15/1993CLARIFICATION ON DISPOSAL OF SORBED MATERIALS IN HAZARDOUS WASTE LANDFILLS AND ON POZZOLANIC STABILIZATION OF SORBED MATERIALSMemo
 Description: Wastes treated with biodegradable sorbents cannot be placed in a landfill until after appropriate treatment. Chemical reagents such as pozzolanic stabilization and thermoplastic or organic binders are non- biodegradable sorbents and may be used to meet the liquid in landfill rule standards. Pozzolanic stabilization may not meet land disposal restrictions (LDR) treatment standards, but treatment that meets Part 268 standards generally meets Section 264.314(e) requirements.
 
10/12/1993APPLICABILITY OF THE PAINT FILTER LIQUIDS TEST TO SORBENTSMemo
 Description: Provides clarification on the performance of the paint filter liquids test (PFT, Method 9095). PFT is designed to verify that sorbed wastes do not contain free liquids for the purpose of the hazardous waste landfill regulations. PFT was not designed to evaluate the performance of one sorbent product relative to other sorbents. No wastes, whether sorbed or not, may be placed in a hazardous waste landfill if they release free liquids as determined by the PFT.
 
10/01/1993EFFECTIVE DATE DELAYED FOR CERTAIN MUNICIPAL SOLID WASTE LANDFILLSQuestion & Answer
 Description: Discusses the delay of the effective dates of municipal solid waste landfill criteria for certain landfills. Explains that the financial assurance effective date was extended to April 9, 1995. The groundwater monitoring exemption for very small, arid, and remote landfills has been removed.
 
09/15/1993Reporting on Municipal Solid Waste: A Local IssuePublication
 Description: Presents background information to assist print and broadcast media in understanding municipal solid waste (MSW) issues. Examines the role of federal, state, and local governments in MSW management; options for solid waste management (source reduction, recycling, incineration, and landfilling); and regulations for solid waste landfills. Includes information sources, major laws affecting MSW management, MSW management state-by-state, and compounds and metals for groundwater detection monitoring.
 
08/15/1993Environmental Fact Sheet: Controlling the Impacts of Remediation Activities in or Around WetlandsPublication
 Description: This fact sheet provides technical information useful in protecting wetlands from the potential negative impacts caused by more common technologies used to remediate hazardous waste sites. It also addresses waste excavation and surface reconfiguration, pumping and treating groundwater, and landfill capping and runoff diversions.
 
05/05/1993DISPOSAL OF SORBED LIQUIDS, PARTICULARLY "BIODEGRADABLE" SORBENTS IN WASTES DESTINED FOR HAZARDOUS WASTE LANDFILLSMemo
 Description: RCRA Section 3004(c)(2) prohibits the direct placement of liquids sorbed with biodegradable sorbents into hazardous waste landfills. Hazardous waste not landfilled may be absorbed by any type of sorbent.
 
03/15/1993Criteria for Solid Waste Disposal Facilities: A Guide for Owners/OperatorsPublication
 Description: This document provides owners and operators of municipal solid waste landfills basic information on the Subtitle D regulations, examining these regulations and issues of location, operation, design, groundwater monitoring, corrective action, closure, and financial assurance.
 
03/15/1993Safer Disposal for Solid Waste: The Federal Regulations for LandfillsPublication
 Description: Summarizes the federal regulations covering landfill location, operation, design, groundwater monitoring and corrective action, closure and postclosure care, and financial assurance. Gives owners/operators and local officials dates for compliance and additional sources of information.
 
03/05/1993U.S. WASTE MANAGEMENT PRACTICES FOR AUTOMOBILES AND AUTO SHREDDER RESIDUEMemo
 Description: Automobile shredder residue (ASR or fluff) and shredded appliances have the potential to exhibit characteristics, and may also contain PCBs above levels of regulatory concern. It is the generator's responsibility to determine whether ASR is hazardous waste before disposal. Provides the estimated ASR yearly generation. Most shredder residue is managed in solid waste (SW) landfills. Some states ban disposal of white goods (appliances) and autos from landfills or impose a consumer surcharge.
 
03/03/1993EPA’S MUNICIPAL SOLID WASTE ASSISTANCE PROGRAM AND THE SBA’S POLLUTION CONTROL LOAN PROGRAMMemo
 Description: EPA‘s Municipal Solid Waste Assistance program (Subtitle D) provides limited funding and grants to help solve solid waste problems at the local, Regional, and national levels. Funding is restricted to nonprofit organizations. The Small Business Administration’s (SBA) Pollution Control Loans program may assist in building pollution control facilities.
 
01/18/1993HAZARDOUS WASTE TESTING ISSUESMemo
 Description: EPA has no data that trivalent chromium oxidizes to hexavalent chromium in a landfill. The TCLP is based on co-disposal scenario. Methods 9010 and 9012 are suggested for a concentration of total cyanide and cyanide amenable to chlorination.
 
11/15/1992Environmental Fact Sheet: EPA Issues Final Rule Regarding Liquids in Hazardous Waste LandfillsPublication
 Description: This fact sheet discusses a final ruling addressing the biodegradability and compressibility of sorbed liquid wastes, and briefly describes the ruling with attention to EPA's commitment to finalizing a HSWA rulemaking on liquids in landfills.
 
11/01/1992MUNICIPAL SOLID WASTE LANDFILL CRITERIAQuestion & Answer
 Description: If only one of three municipal solid waste landfill cells continues to receive waste after October 9, 1991, only that cell must comply with the cover requirements if it closes before October 9, 1993. If the cell continues to receive waste after October 9, 1993, it would need to comply with the Part 258 requirements. Each landfill cell is a separate unit.
 
10/01/1992MUNICIPAL SOLID WASTE CHARACTERIZATIONQuestion & Answer
 Description: Discusses the general 1990 statistics about municipal solid waste generation and disposition in the U.S. (SEE ALSO: current Municipal Solid Waste in The United States Facts and Figures).
 
09/04/1992STATUS OF FLUORESCENT LAMPS UNDER RCRAMemo
 Description: CESQG or household hazardous waste (HHW) fluorescent light bulbs may be land disposed in Subtitle D landfill regardless of characteristic properties. Land disposal restrictions (LDR) do not apply to D009 mercury-containing fluorescent light bulbs that pass the extraction procedure (EP) test (SUPERSEDED: see 63 FR 28556; 5/26/98). The bulbs are subject to LDR because they exhibit the EP toxicity characteristic and toxicity characteristic (TC), and could be considered debris per 268.45.
 
07/01/1992LINERS AND LEAK DETECTION SYSTEMS FOR HAZARDOUS WASTE LANDFILLS, SURFACE IMPOUNDMENTS, AND WASTE PILESQuestion & Answer
 Description: Summary of the minimum technological standards (RCRA 3004(o)) for new, replacement, and lateral expansions of landfills, surface impoundments, and waste piles completed after July 29, 1992.
 
06/17/1992REGULATORY DETERMINATION FOR SOIL BEING STOCKPILED AT THE SOUTHERN PACIFIC TRANSPORTATION COMPANY (SPTCO)Memo
 Description: Whether the use of soil as landfill liner cover constitutes use in a manner constituting disposal is a site-specific determination that must be made at the Regional level.
 
03/15/1992Environmental Fact Sheet: Final Cover Requirements for Municipal Solid Waste LandfillsPublication
 Description: This fact sheet discusses a rulemaking that announces cover requirements for municipal solid waste landfills receiving waste after October 9, 1993. The rule also notifies landfills that stop receiving waste between October 9, 1991, and October 9, 1993, to comply with the federal requirements for the final cover.
 
01/15/1992Environmental Fact Sheet: EPA Releases Final Rule on Liners and Leak Detection SystemsPublication
 Description: This fact sheet summarizes new requirements mandated by HSWA. The requirements institute minimum standards for double liners, leachate collection and removal systems, leak detection systems, and construction quality assurance programs at hazardous waste surface impoundments, landfills, and waste piles.
 
12/20/1991PUBLIC HEARINGS ON PETITION TO DELIST WASTE FROM APTUS, INC.Memo
 Description: EPA is not required to hold public hearing on delisting petitions. As of 1991, EPA has never held delisting hearings. Proposed delistings must be published in the Federal Register. EPA does not designate specific disposal sites for delisted wastes, but assumes disposal in an unlined solid waste landfill.
 
11/08/1991SUBTITLE D AND PULP AND PAPER MILL SULDGEMemo
 Description: No additional regulations are warranted under Subtitle D for landfills and surface impoundments receiving unlisted, dioxin-containing sludge from chlorine and chlorine derivative bleached pulp and paper mills.
 
09/15/1991Environmental Fact Sheet: Municipal Landfill Regulations Mean Safer Disposal of Solid WastePublication
 Description: This fact sheet discusses a rulemaking that establishes comprehensive, protective standards for managing the nation's solid waste burden. The rule specifies location provisions and design, operating, and closure requirements for landfills. In addition, the rule offers incentives for increasing source reduction and recycling nationwide.
 
09/15/1991Environmental Fact Sheet: Small Communities and the Municipal Landfill RegulationsPublication
 Description: This fact sheet discusses the stablishment of comprehensive, protective standards for the disposal of municipal solid waste at approximately 6,000 landfills and the effort to reduce the impacts of these regulations on small communities.
 
06/21/1991POSITION PAPER ON SPENT ABSORBENT MATERIALSMemo
 Description: CESQGs may dispose of hazardous waste in a sanitary or municipal solid waste landfill as long as the landfill is permitted, licensed, or registered by the state to manage municipal or industrial solid waste (SEE ALSO: 261.5(g)(3)). An absorbent and waste mixture containing a free liquid phase with a flash point less than 140 F is D001. A sorbent and waste mixture with no free liquid is D001 only if it qualifies as an ignitable solid. DOT hazard classes do not correspond directly to RCRA characteristics. The deliberate mixing of hazardous waste and absorbents to render waste nonhazardous may be treatment subject to permitting (SEE ALSO: 264.1(g)(10)) and 268.3). If an absorbent is mixed with waste that is listed solely for exhibiting a characteristic, the mixture is not hazardous waste if it does not exhibit the characteristic (SEE ALSO: 66 FR 27266; 5/16/01). A mixture of absorbent and used oil is subject to Part 266, Subpart E (SUPERSEDED: See Part 279) if destined for energy recovery.
 
05/01/1991REGULATION OF MUNICIPAL WASTE COMBUSTION (MWC) ASHQuestion & Answer
 Description: The Clean Air Act Amendments of 1990 established a two-year exemption for characteristic combustion ash from municipal waste incinerators. The two-year moratorium covered fly and/or bottom ash from both energy recovery and municipal incinerators (SUPERSEDED: October 1, 1994, MRQ, “Status of Municipal Waste Combustion (MWC) Ash”; 59 FR 29372; June 7, 1994; 60 FR 6666; February 3, 1995, and RPC# 3/22/95-01).
 
03/26/1991SUBSURFACE FATE AND TRANSPORT MODELMemo
 Description: EPA‘s Composite Model for Landfills (EPACML) is a subsurface fate and transport model developed for national regulatory purposes, not site-specific use. EPA is proposing to use EPACML in delisting petitions. EPA discourages application of the model to site-specific corrective actions.
 
01/15/1991Environmental Fact Sheet: Yard Waste CompostingPublication
 Description: This document presents EPA's recommendation for composting yard wastes instead of putting them in landfills and provides how-to information.
 
12/20/1990THIRD THIRD LAND DISPOSAL RESTRICTIONS FINAL RULEMemo
 Description: Lab packs going for incineration can be packed in fiber drums, not just metal drums. Discusses the definition of inorganic solid debris. Empty containers may be hazardous if characteristic. A treatment facility must support the determination that waste meets the treatment standard with analytical data. Piped transfers from a recycling facility to an off-site TSDF is subject to land disposal restrictions (LDR) notification (SEE ALSO: 62 FR 25997; May 12, 1997).
 
12/11/1990ASBESTOS/LEAD/SOIL/DEBRIS AS INORGANIC SOLID DEBRISMemo
 Description: Inorganic solids debris is defined as nonfriable wastes contaminated with characteristic metals that do not pass through a 9.5-mm sieve tray. Debris qualifying for a national capacity variance can be disposed of without meeting land disposal restrictions (LDR) treatment standards in a Subtitle C landfill meeting minimum technical requirements (MTR) (SUPERSEDED: see Section 268.35(e)(1)).
 
12/01/1990LDR REQUIREMENTS DURING NATIONAL CAPACITY VARIANCES (NCVS)Question & Answer
 Description: Restricted wastes that are granted a national capacity variance are still subject to recordkeeping and analysis requirements and any applicable California list restrictions (3004(h)(2)) (SUPERSEDED: California list removed, see 62 FR 25997; May 12, 1997). Any landfill or surface impoundment holding such waste must meet minimum technology requirements.
 
11/20/1990LDR RULES REGARDING ALTERNATIVE TREATMENT STANDARDS FOR LAB PACKSMemo
 Description: A person who incinerates lab packs may use fiber drums in place of metal outer containers. Fiber or wood boxes or other containers that do not meet the DOT specifications for fiber drums may not be used as outer containers for lab packs.
 
11/15/1990Test Method 9096: Liquid Release Test (LRT) ProcedurePublication
 Description: Provides information designed to determine whether or not liquids will be released from sorbents when subjected to overburden pressures in landfill.
 
09/26/1990SUBTITLE C IMPERMEABLE CAP REQUIREMENT FOR ON-SITE CONTAINMENT OF WOOD PRESERVING WASTESMemo
 Description: EPA grants ARAR waiver of landfill impermeable cap requirement for waste treated to land disposal restrictions (LDR) variance from treatment standard. The consolidation of wastes within an area of contamination (AOC), not replacement unit, does not trigger minimum technological requirements (MTR).
 
08/08/1990LAB PACKS - LAND DISPOSAL RESTRICTIONS ASPECTSMemo
 Description: P046, P111, and U163 may be incinerated in lab packs. Lab packs destined for incineration in fiber drums are not required to be placed in metal containers.
 
06/14/1990PERSONAL PROTECTIVE GEAR DISPOSALMemo
 Description: Lead-contaminated personal protective equipment (PPE) or gear is subject to land disposal restrictions (LDR). Hazardous waste eligible for a national capacity variance may be disposed without treatment in a minimum technological requirement (MTR) landfill or surface impoundment if the waste is below California list prohibition levels (SUPERSEDED: California list removed, see 62 FR 25997; 5/12/97).
 
06/04/1990REGULATORY INTERPRETATION OF OBJECTION TO CLEAN-CLOSURE EQUIVALENCY PETITION FOR STEEL ABRASIVES, INC.Memo
 Description: All landfills, surface impoundments, waste piles, and land treatment units that received waste after July 26, 1982 are subject to post-closure permitting and Part 264 Subpart F standards unless the owner demonstrates that closure under the previous Part 265 standards met Part 264 closure by removal standards (SUPERSEDED: See 63 FR 56711; October 22, 1998). Under RCRA 3005(i), EPA has the authority to revisit interim status clean closures and require post-closure permits if closure does not meet closure by removal standards of Part 264. In order to demonstrate clean closure, an owner generally should remove “hot spots” of contamination.
 
05/09/1990INDUSTRIAL WASTE DISPOSAL IN PROXIMITY TO WETLANDSMemo
 Description: Historical discussion on location restrictions for municipal solid waste landfills, and EPA’s intent to evaluate industrial waste landfills, characterize wetlands, and develop location standards for hazardous waste management facilities.
 
03/29/1990MUNICIPAL WASTE COMBUSTION ASHMemo
 Description: Municipal combustion ash exhibiting a characteristic of hazardous waste would be subject to Subtitle C regulation. Ash generated by energy recovery facilities are not specifically exempt from Subtitle C regulation (SEE ALSO: 3/22/95-01; 59 FR 29372; June 7, 1994, 60 FR 6666; February 3, 1995 and 10/1/94-02).
 
02/22/1990D001 CHARACTERISTIC WASTES - LAND DISPOSAL RESTRICTIONSMemo
 Description: Waste cannot be disposed of unless treated to land disposal restrictions (LDR) treatment standards, disposed in no-migration unit, or subject to exemption or variance from treatment standards. D001 ignitable waste must be treated to treatment standard before disposal. There are special requirements for ignitable wastes placed in a surface impoundment, landfill, waste pile, and land treatment unit.
 
02/16/1990EXPORTATION OF MUNICIPAL WASTE TO CENTRAL AMERICAMemo
 Description: EPA has no authority to control the export of municipal solid waste. The export of hazardous waste is regulated. New requirements for municipal solid waste exports are predicted as result of Basel Convention and pending legislation (SEE ALSO: 61 FR 16290; 4/12/96 and 57 FR 20602; 5/13/92).
 
02/15/1990Environmental Fact Sheet: The Facts on Degradable PlasticsPublication
 Description: Explains EPA's Report to Congress on methods to manage and control plastic wastes. Degradable plastics are engineered by photodegradation and biodegradation. Discusses how degradable plastics fit into solid waste solutions of reducing waste, landfilling, recycling, and incineration.
 
10/05/1989DEFINITION OF A LIQUID AS IT APPLIES TO IGNITABLE AND CORROSIVE WASTES; LIQUID AS IT APPLIES TO IGNITABLE OR CORROSIVE WASTESMemo
 Description: The definition of liquid depends on the specific regulatory application for ignitable (D001), corrosive (D002), and extraction procedure (EP) (SUPERSEDED: see 261.24). For toxic wastes, liquid is defined as the material expressed from the waste in Step 2 of Method 1310. Liquids produced from paint filter test are generally also liquids under Method 1310 (SEE ALSO: 60 FR 3092; January 13, 1995). Only wastes containing a liquid component are subject to the flash point test (ignitability (D001)) and the pH test (corrosivity (D002)). Method 9095 is used to determine if a waste is prohibited from disposal in a landfill for containing free liquids. Method 9096 is a draft procedure for determining if adsorbents contain releasable liquids. Adsorbents containing releasable liquids are prohibited from disposal in a landfill by HSWA.
 
09/14/1989STATUS OF SOLID WASTE EXPORT GATHERINGMemo
 Description: Discussion of EPA estimates of quantities of solid waste exported for disposal or recycling.
 
07/20/1989LIQUID, FREE LIQUID, RELEASABLE LIQUID DEFINITIONSMemo
 Description: Liquid for purposes of corrosivity (D002) determined by Method 1310 (extraction procedure (EP)). The definition of free liquid applies to the prohibition of liquids in landfills. Definition of releasable liquid applies to absorbent materials that might release liquids (SEE ALSO: current Sections 264.314(e), and 265.314(f)).
 
05/16/1989DELAY OF CLOSURE PERIOD FOR HWM FACILITIESMemo
 Description: Under limited circumstances, landfills, surface impoundments, and land treatment units may remain open after the final receipt of hazardous waste in order to receive nonhazardous waste.
 
05/05/1989PLACEMENT OF STABILIZED WASTES THAT DO NOT MEET LAND RESTRICTION REQUIREMENTSMemo
 Description: Waste must meet treatment standards before it is placed in a land disposal unit. A land disposal restrictions (LDR) equivalent method variance may be granted if the technology is equivalent or better than best demonstrated available technology (BDAT). A no-migration variance must be based on the period that the waste is hazardous. Bulk or non-containerized liquid hazardous waste must pass the paint filter liquids test prior to placement in a landfill.
 
04/01/1989GENERATOR CLOSURE/FINANCIAL REQUIREMENTSQuestion & Answer
 Description: LQGs must comply with 265.111 and 265.114. SQGs need only comply with the applicable accumulation unit closure requirements. Generator tanks which cannot meet the closure performance standards must close as a landfill and comply with 265, Subparts G and H.
 
10/19/1988MULTIPLE EXTRACTION PROCEDURE, METHOD 1320Memo
 Description: For the multiple extraction procedure (Method 1320), the weight of the wet material remaining after each extraction procedure (EP), not the original dry weight, is used to calculate the 20:1 liquid to solid ratio. Method 1320 is trying to predict the effect on the waste in a landfill that is subject to rain for a long period of time.
 
05/31/1988DEADLINES APPLICABLE TO PROPOSED DELAY OF CLOSURE REGULATION, GUIDANCEMemo
 Description: The proposed delay of closure rule (53 FR 20738; 6/30/88) would allow owners and operators of landfills and certain surface impoundments to delay closure to receive nonhazardous waste. Units which have lost interim status are not eligible for a delay of closure. Owners of units who wish to delay closure must obtain a permit or permit modification. Surface impoundments that are not retrofitted to meet the minimum technological requirements are subject to special requirements if the owner wishes to delay closure. Units that delay closure remain subject to Subtitle C. Units remain subject to the closure plan submission deadlines despite the proposed delay of closure rule (53 FR 20738; 6/30/88). Because the proposed rule is less stringent than the existing closure regulations, authorized states are not required to adopt the new provisions. Interim status units that cease receiving hazardous waste on 11/8/88 may continue to receive nonhazardous wastes until the closure plan is approved as well as during the closure period provided it does not impede closure.
 
05/12/1988DEMONSTRATING EQUIVALENCE OF PART 265 CLEAN CLOSURE WITH PART 264 REQUIREMENTSMemo
 Description: Under 270.1(c), owners of interim status surface impoundments and waste piles who clean closed under the old Part 265 closure standards may demonstrate equivalency with the 264 closure standards. Discusses the contents of the demonstration equivalency and the procedures for submittal. If an attempt at a closure equivalency demonstration does not meet the 264 standards, the owner must submit a Part B permit application. Addresses the acceptability of specific information supporting equivalency demonstrations. An owner of an interim status landfill where waste was removed at closure can reclassify it as a waste pile and demonstrate clean closure equivalency, or the owner may request a shortened post-closure care period (SEE ALSO: 63 FR 56711; 10/22/98).
 
05/11/1988REDESIGNATION OF SURFACE IMPOUNDMENTS AS LANDFILLS DURING INTERIM STATUSMemo
 Description: An interim status surface impoundment that does not meet the minimum technological requirements must be retrofitted or closed by 11/8/88 pursuant to 3005(j). The redesignation of a unit as a landfill does not meet either criterion in 270.72(c) for changes during interim status.
 
05/02/1988SPENT PICKLE LIQUOR CORROSIVITYMemo
 Description: Spent pickle liquor generated by a steel fabricator is not K062 since the facility is not in SIC codes 331 or 332. Nonlisted spent pickle liquor is corrosive if it corrodes 1020 steel at a rate of >0.25 inches/year. Nonlisted sludge from a pickling tank is D002 if pH of the sludge is < 2. The 264.314 liquids in landfills ban does not apply to nonhazardous waste disposal facilities.
 
05/01/1988LAND DISPOSAL RESTRICTIONS - DISPOSAL OF WASTES GRANTED A VARIANCEQuestion & Answer
 Description: Restricted wastes that are granted a capacity variance may be disposed of in landfills or surface impoundments only if the facility is in compliance with the minimum technological requirements (MTR). These wastes may also be disposed of in land treatment facilities that are not in compliance with MTR (SUPERSEDED: 268.8 removed, see 61 FR 15599; 4/8/96).
 
05/01/1988RETROFITTING INTERIM STATUS SURFACE IMPOUNDMENTSQuestion & Answer
 Description: The conversion of an interim status surface impoundment into a landfill without triggering permitting would have to be approved under 270.72(c) (SUPERSEDED: See 270.72(a)(1)), and could not amount to “reconstruction” under 270.72(e) (SUPERSEDED: See 270.72(b)) under changes during interim status. An impoundment converted to a landfill in these circumstances would be an existing unit. If waste is removed and replaced, then the unit would be a replacement unit and would have to meet the minimum technology requirements (MTR) (3004(o)). If the waste addition exceeded the level in the Part A, then the unit would be an expansion subject to MTR.
 
03/30/1988SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTSMemo
 Description: Samples taken from turbid groundwater may not be valid. Proper well development requires that wells be clay and silt free. Discusses the use of polyvinyl chloride (PVC) in well construction, the calculation of purge volume, and Part 264, Appendix IX. An accelerated groundwater monitoring schedule can be used to bring a facility into compliance. The maintenance of a groundwater monitoring network may include the redevelopment of a well. Well maintenance should be included as a permit condition. Replacement units (e.g. landfills and surface impoundments) must be retrofitted to meet the minimum technological requirements. If a proposed alternative to a double liner does not meet the requirements of 264.221(c), the location characteristics or operating practices must compensate for the deficiency. A redundant flexible membrane bottom liner may be equivalent to the 3004(o)(5)(B) interim statutory design, thus meeting the 3004(o)(1) minimum technological requirements. Addresses the use of the Hydrologic Evaluation of Landfill Performance (HELP) model v. Moore’s Equation for calculating leachate volume when designing a collection system, the proposed modifications to the cap design to reduce erosion potential, and the use of a test plot to support alternative landfill design cover. A high-density polyethylene liner must be supported by a stable base. An owner of a petroleum refinery undertaking a land treatment demonstration must fully characterize the waste, including addressing the Skinner List constituents in the waste analysis plan. A properly conducted land treatment demonstration should include an evaluation of the waste degradation, transformation, and immobilization, as well as a toxicity study. A land treatment unit cannot accept sludges containing high concentrations of water if the soil moisture conditions cause saturation of the unit. Discusses the selection of principal hazardous constituents for a land treatment unit. An owner of a land treatment unit who has not demonstrated satisfactory treatment of hazardous constituents may need to close the unit. Addresses the presence of a high water table at a land treatment unit and the possible responses. An owner of an existing interim status land treatment unit may be eligible for an immediate full-scale permit if the land treatment demonstration addresses all of the necessary requirements. In states that are authorized for the RCRA base program but not for the HSWA provisions, construction cannot begin at a new facility until both the state and EPA permits are issued. The land disposal restrictions (LDR) program is a self-implementing portion of HSWA, superseding the permit as a shield provision. Permit content should be edited for applicability, importance, clarity, and precision prior to issuance. A minimum detection limit (MDL) can be used to establish background as a groundwater protection standard. Any component required in a RCRA facility investigation (RFI), such as monitoring releases not requiring immediate response, should be included as a permit condition. Monitoring wells installed as part of a HSWA corrective action may be designated as point of compliance wells. Permits containing corrective action conditions for groundwater treatment programs must specify methods of handling groundwater containing hazardous waste and must include pumping and removal requirements. Air stripping may not be an appropriate treatment method for groundwater contaminated with methyl isobutyl ketone. A permit or 3008(h) order should address the air emissions from treatment units such as an air stripper. Includes criteria for the referral of facilities to the Agency for Toxic Substances aND DISEASE REGISTRY (ATSDR) UNDER 3019. Emerging technologies, such as in-situ bio-reclamation, should be demonstrated as effective in pilot-scale field studies prior to approval. 264 Subpart F compliance monitoring standards should be applied to the verification monitoring at solid waste management units (SWMUs) during corrective action. A HSWA corrective action pe
rmit may include a technical feasibility clause discontinuing the program once contaminant levels can no longer be reduced. EPA discourages the approval of a waiver allowing the disposal of nonhazardous waste in a landfill that has lost interim status.
 
03/02/1988CLEANUP LEVELS FOR LEAD AND CADMIUM IN SOILS FOR CLEAN CLOSUREMemo
 Description: VERIFIED REFERENCE DOSES (RFDS) AND Carcinogenic Potency Factors (CPFs) can be used to set soil cleanup levels during clean closures of surface impoundments, waste piles, and land treatment units. Where no EPA-recommended health-based limit exists for a contaminant, a soil cleanup level may be based on background levels or by data developed by the owner to support a health-based limit. If the cleanup level cannot be established, then clean closure cannot be achieved and the unit (i.e. surface impoundment, waste pile, or land treatment unit) must close as a landfill. Provides guidance for determining the background levels for lead in soil for clean closures of surface impoundments, waste piles, and land treatment units. Discusses how to determine background levels of lead in soil.
 
02/22/1988LETTER TO STATE ENVIRONMENTAL COMMISSIONERS: SUBTITLE D STATE SOLID WASTE MANAGEMENT PLANSMemo
 Description: RCRA 4005(c)(1) requires states to develop and implement permit programs for facilities that manage hazardous waste from CESQGs and households. EPA requests states to review and update municipal solid waste (MSW) management plans.
 
02/10/1988VERTICAL EXPANSION AT U.S. ECOLOGY'S TRENCH 10, BEATTY, NEVADA FACILITYMemo
 Description: Landfill vertical expansion is limited by federal, state, and local permits in effect prior to HSWA. Vertical expansion after 11/8/84 constitutes a new unit that is subject to the minimum technological requirements (MTR). When there is no elevation limit in the permit, consider the slope of the cover at closure.
 
02/03/1988PCB-CONTAMINATED WASTES, STABILIZATION OFMemo
 Description: Bulk liquid waste treated with absorbents or adsorbents must be tested with the paint filter liquids test (PFT) (3004(c)(1)) (SEE ALSO: 1RPC# 1/17/93-02). When a waste passes the PFT, it may be disposed in a landfill. When a waste fails the PFT, further chemical stabilization is required. Provides guidance on the level of adequacy for chemical treatment.
 
02/02/1988CLOSURE REQUIREMENTSMemo
 Description: EPA recognizes the inconsistencies between the tank and container closure requirements and plans to revise Subpart I to ensure consistency. The 3/19/87 clean closure guidance (52 FR 8704) should be applied to closure by the removal of wastes from any RCRA unit. EPA plans to allow interim status and permitted landfills to defer closure to manage nonhazardous wastes. Characteristic waste must be managed as hazardous unless it no longer exhibits any of the four characteristics. Discusses the more protective clean closure action levels v. hazardous waste identification levels. Listed wastes and any waste residues or contaminated soil or debris removed during closure are hazardous unless delisted. The concentrations of total organic carbon (TOC) and total organic halogens (TOX) cannot be used to determine if decontamination wastewater is hazardous.
 
02/01/1988CLEAN CLOSURE OF INTERIM STATUS SURFACE IMPOUNDMENT AND WASTE PILEQuestion & Answer
 Description: Surface impoundments, waste piles, landfills, and land treatment units which received waste after 7/26/82 or certified closure after 1/26/83 must either have post-closure permits or demonstrate that clean closure was equivalent to Part 264 closure (270.1(c)) (SEE ALSO: 63 FR 56711; 10/22/98). Post-closure permits for these units would include Part 264 groundwater monitoring, unsaturated zone monitoring, corrective action and post-closure care.
 
01/01/1988DISPOSAL OF MIXED RADIOACTIVE AND HAZARDOUS WASTEQuestion & Answer
 Description: Radioactive mixed waste is not regulated until a state is authorized for mixed waste. A mixed waste landfill is a solid waste management unit (SWMU), and 3004(u) would apply to the unit. If a mixed waste disposal unit was inactive prior to the date chosen to be interim status by the state, the unit might not be subject to RCRA unless it was subsequently managed (active management) or unless the state “grandfathered” such units. If the unit is active on the interim status date, the facility must submit a Part A permit application. A state RCRA program can be broader in scope than the federal program.
 
12/17/1987CLOSURE AND POST-CLOSURE ISSUES FOR INTERIM STATUS SURFACE IMPOUNDMENTSMemo
 Description: EPA may extend the time allowed for the closure of a surface impoundment to allow groundwater corrective action so that the owner can achieve clean closure. Units closing by removal under Part 265 (e.g. surface impoundments, waste piles, and land treatment units) must obtain post-closure permits unless the owner demonstrates equivalence with 264.228, 264.280(e), or 264.258 closure by decontamination standards (SEE ALSO: 63 FR 56711; 10/22/98). The owner of an interim status landfill that has closed by removal and has not triggered groundwater assessment does not have to monitor groundwater for the full list of Appendix VIII or IX constituents. Groundwater evaluation conducted as part of the 265 clean-closure demonstration should establish constituents that could reasonably be expected to exist at the impoundment. A surface impoundment that has triggered groundwater assessment may not be able to clean close.
 
10/29/1987UCAPCO APPLICATION FOR A VARIANCE UNDER 3004(C)(2) OF RCRAMemo
 Description: Variances from the minimum technological requirements (MTR) may be obtained if an alternate system can prevent the migration of any hazardous constituents into the groundwater. The term groundwater is not limited to only groundwater beyond the waste management area (surface impoundment, waste pile, landfill).
 
10/26/1987SURFACE IMPOUNDMENT DELISTING PETITIONS, USE OF VHS MODELMemo
 Description: The vertical horizontal spread (VHS) model is used to evaluate wastes in landfills and surface impoundments for purposes of delisting petitions. The organic leachate model (OLM) is also used.
 
09/16/1987SW-846 METHODS MANUALMemo
 Description: The use of SW-846 methods is generally not required except for quality assurance/quality control procedures and determining if the waste is characteristic. Discusses sampling, analysis for delisting petitions, incinerator trial burns, and determining if bulk or containerized waste contains free liquids prior to disposal in a landfill.
 
09/03/1987DELISTING REGULATORY STANDARDS FOR FREONMemo
 Description: Discusses the use of the organic leaching model (OLM) and vertical and horizontal spread (VHS) model used to assess the hazard posed by the disposal of freon (trichloro thifluoroethane) in a landfill for the purposes of delisting.
 
09/01/1987SUBTITLE D PROGRAMS ON INDIAN LANDSQuestion & Answer
 Description: State Subtitle D standards do not apply to Indian lands. Tribes are subject to federal guidelines in Part 257 (SUPERSEDED: See current Part 258).
 
08/21/1987LISTING MUNICIPAL LANDFILLS ON THE NPLMemo
 Description: Nothing precludes a closed municipal solid waste landfill from being placed on CERCLA NPL even if EPA cannot document that the landfill received hazardous waste in the past.
 
08/03/1987JOINT NRC-EPA GUIDANCE ON AN APPROACH FOR COMMERCIAL MIXED LOW-LEVEL RADIOACTIVE AND HAZARDOUS WASTE DISPOSAL FACILITIESMemo
 Description: Provides joint Nuclear Regulatory Commission (NRC) - EPA guidance on a conceptual design approach for commercial mixed low-level radioactive and hazardous waste disposal facilities (i.e. landfills).
 
07/16/1987CASE-BY-CASE EXTENSION PETITION, INFORMATION REQUIREDMemo
 Description: Includes an overview of the requirements that facilities must meet to receive a case-by-case extension to the effective date of the land disposal restrictions (LDR). A surface impoundment or landfill managing waste during an extension must meet the minimum technological requirements (MTR).
 
04/08/1987CLOSURE REQUIREMENTS FOR THE DISPOSAL OF STORAGE TANKSMemo
 Description: Owners or operators that are unable to remove or decontaminate a tank system must close it as a landfill. Tank system components that do not contain hazardous waste are not subject to Subtitle C requirements;. Follow NFPA guidelines when abandoning a tank system in place.
 
03/30/1987SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTSMemo
 Description: A native soil foundation does not constitute a liner for the purposes of the 3005(j)(2) waiver. A 264.282 compatibility demonstration applies to both hazardous and nonhazardous waste. Addresses HSWA waste minimization requirements (3002(b)) and the application of sludge to land treatment units. The identification of principal hazardous constituents for land treated wastes must include all constituents that may enter the waste stream. A land treatment unit performance evaluation must include the unit’s ability to treat and degrade organic constituents, as well as its ability to immobilize heavy metals. Provides guidance on the frequency of soil pore liquid sampling at land treatment units (unsaturated zone monitoring) and guidance on screening groundwater monitoring wells. QA/QC methodology at a land treatment unit should include verification of the organic constituent analysis by gas chromatography/mass spectroscopy (GC/MS). Includes guidance on the content of construction quality assurance plans. A person who conducts quality assurance measures for surface impoundments, waste piles, and landfills should be independent of the construction contractor. Discusses the use of Method 9090 for compatibility testing of liner materials with waste or leachate. All man-made materials that contact waste or leachate should be subjected to the immersion test portion of 9090. A sample of waste or leachate used in compatibility testing must be representative of the actual waste or leachate managed in the surface impoundment, waste pile, or landfill. A concrete pad cannot be equivalent protection. If the design slope of a final landfill cover exceeds 3-5%, the applicant must demonstrate that soil erosion will not be excessive and may need to perform a slope stability analysis. Waste and soil settlement must be included in calculations for the final landfill cover design to be substituted for a waste pile liner as equivalent protection under 3015(a). A flexible membrane liner should not be used in a final cover when the landfill is unusually deep and slopes are steep. Clean, not contaminated, soil should be used for the final cover. A leachate collection system design should be based on realistic infiltration rates. Geogrid and geotextile materials used in place of conventional drainage materials for a landfill must have an equivalent drainage capacity of a one-foot layer of compacted sand. Berms constructed of manufactured slag should not contain hazardous constituents. For landfills, the use of a composite primary liner below the primary synthetic liner is allowable. An owner of a land treatment unit who cannot establish vegetative cover may use an alternate closure procedure. A facility cannot extend closure in order to receive nonhazardous waste (SUPERSEDED: see current 264.113(d)). Addresses the role of the Agency for Toxic Substances and Disease Registry (ATSDR) in exposure information and evaluation. The review of Exposure Information Reports should be coordinated with ongoing RCRA Facility Assessments.
 
03/18/1987REACTIVE CHARACTERISTICS OF DISCHARGED LI/SO2 BATTERIESMemo
 Description: Based on the supplied data, EPA agrees that Li/SO2 (lithium-sulfur dioxide) batteries are unlikely to exhibit the reactivity characteristic when they are fully discharged to zero volts. Fully-charged and duty-cycle Li/SO2 batteries are reactive. The generator is responsible for the hazardous waste determination. The placement of ignitable (D001) or reactive (D003) waste into a landfill is prohibited unless it is treated, rendered, mixed before, or immediately after, placement in the landfill so that it is no longer characteristic (SEE ALSO: Part 268).
 
03/11/1987REPLACEMENT UNIT, DEFINED - WASTE CONSOLIDATION FROM SEVERAL IMPOUNDMENTSMemo
 Description: A replacement surface impoundment or landfill is a unit that is taken out of service, emptied by removing waste, and reused. A replacement unit must meet minimum technological requirements before reuse. An impoundment may change to a landfill during interim status, but becomes a replacement unit under changes during interim status (SEE ALSO: 270.72(b)).
 
03/01/1987SUBTITLE D SURVEYQuestion & Answer
 Description: EPA can use RCRA 3007 to obtain information from Subtitle D facilities that are using the statutory definition of hazardous waste in 1004(5).
 
02/01/1987LIQUIDS IN LANDFILLSQuestion & Answer
 Description: Liquids which have been stabilized by the addition of absorbents must have a compressive strength of 50 p.s.i. before being placed in landfills (SUPERSEDED: see 264.314, 57 FR 54452; 11/18/92).
 
01/20/1987BULK LIQUID HAZARDOUS WASTE SOLIDIFICATION REQUIREMENTSMemo
 Description: Provides guidance on determining an adequate binding level for chemically stabilizing bulk liquid waste. An owner or operator of a landfill is responsible for meeting the bulk liquid provisions (3004(c)(1)). A generator or client of a landfill is not responsible (SEE ALSO: RPC# 11/17/93-02).
 
12/31/1986SPECIAL MATERIALS DISPOSED OF IN LANDFILLS: BATTERIES, CAPACITORS, LAB PACKSMemo
 Description: Batteries and capacitors are exempt from the landfill containerized liquid requirements. They do not need to be 90% full, crushed, or shredded before disposal (SEE ALSO: Part 273).
 
12/30/1986CONTAINERIZED AND BULK HAZARDOUS LIQUIDS IN RCRA LANDFILLSMemo
 Description: Any absorbent, biodegradable or non-biodegradable, may be used for the treatment and disposal of free liquids in a landfill (SUPERSEDED: see 57 FR 54452; 11/18/92, and RPC# 11/17/93-02).
 
12/15/1986DRY TOLUENE AND CARBON TETRACHLORIDE, SAFE DISPOSAL OFMemo
 Description: “Dry” toluene and carbon tetrachloride could be mobilized by other liquids in a landfill when disposed as regular trash .
 
12/04/1986STANDARDS AGAINST WHICH 3004(O)(2) EQUIVALENCY PETITION SHOULD BE COMPARED - DOUBLE LINERMemo
 Description: The minimum technological requirement (MTR) (3004(o)) equivalency demonstration for landfills is evaluated against the interim statutory double-liner design (SEE ALSO: 57 FR 3462; 1/29/92).
 
12/01/1986EXISTING UNITS AND MIMIMUM TECHNOLOGY STANDARDSQuestion & Answer
 Description: Removing waste from a landfill, stabilizing it, and replacing it is not reuse or replacement of a landfill provided it is part of closure and no new waste is added. The landfill is still an existing unit and is not subject to the minimum technology standards of section 3004(o) (SEE ALSO: 57 FR 3464-3465; 1/29/92).
 
10/01/1986CORRECTIVE ACTION FOR NEW FACILITIESQuestion & Answer
 Description: The section 3004(u) corrective action authority covers all facilities seeking permits, including facilities at which no authorized hazardous waste management activity has taken place. Solid waste management units (SWMUs) include landfills, dumps, units in which RCRA-exempt wastes have been stored or disposed.
 
09/01/1986HAZARDOUS WASTE TANK CLOSURE AND POST-CLOSUREQuestion & Answer
 Description: If the owner or operator closing a hazardous waste tank after 1/12/87 cannot remove and decontaminate all soil, etc. he/she must close the tank as a landfill, and comply with the post-closure and financial responsibility requirements. EPA may issue a section 3008(h) corrective action order if necessary.
 
08/07/1986LINER/LEACHATE COLLECTION SYSTEM COMPATIBILITYMemo
 Description: HDPE (high density polyethylene) is not a universal material for a liner and leachate collection system for surface impoundments, waste piles and landfills. Different HDPE material varies in physical and chemical properties. A liner and leachate collection system must be chemically resistant to waste in a landfill. This memo provides suggestions for testing landfill components.
 
06/27/1986MUNICIPAL WASTE INCINERATOR ASH MANAGEMENTMemo
 Description: Municipal waste combustion (MWC) ash may exhibit a hazardous waste characteristic and, therefore, be subject to Subtitle C. Residues that do not exhibit a characteristic may be disposed of in a Subtitle D landfill (SEE ALSO: RPC# 3/22/95-01, 59 FR 29372; 6/7/94, 60 FR 6666; 2/3/95 and RPC# 10/1/94-02).
 
06/11/1986PROHIBITION ON THE PLACEMENT OF BULK LIQUID HAZARDOUS WASTE IN LANDFILLS - STATUTORY INTERPRETIVE GUIDANCEMemo
 Description: A discussion of the prohibition on the placement of bulk liquid hazardous waste in landfills, and statutory (3004(c)) interpretive guidance.
 
06/02/1986PAINTING CONTRACTOR WASTES-SMALL QUANTITY GENERATORMemo
 Description: Methylene chloride is a listed waste (F002) when used as a solvent and can be toxic. Muriatic acid is likely to be corrosive (D002) but not toxic. Generators who produce greater than 100 kg/mo are subject to regulation. CESQGs may dispose of hazardous waste in any state approved landfill.
 
05/27/1986RESIDUES FROM MUNICIPAL WASTE RESOURCE RECOVERY FACILITIES; MUNICIPAL WASTE COMBUSTION RESIDUES-ASH AND SLUDGEMemo
 Description: Municipal waste combustion (MWC) ash may exhibit the toxicity characteristic. Hazardous ash disposed in landfills is subject to all hazardous standards. EPA has authority under CAA and RCRA to control dust. RCRA is the primary authority for groundwater protection at active landfills (SEE ALSO: RPC# 10/1/94-02; 59 FR 29372; 6/7/94; 60 FR 6666; 2/3/95; RPC# 3/22/95-01).
 
05/01/1986TREATMENT WITHOUT A PERMITQuestion & Answer
 Description: Dilution is treatment, but the treatment in an accumulation tank or container under section 262.34 does not require a permit (SEE ALSO: 268.3, 268.7(a)(4)). A characteristic waste treated so it no longer exhibits a characteristic can be disposed of in a Subtitle D landfill (SEE ALSO: 268.9).
 
04/27/1986BAN ON USE OF LIQUIDS IN LANDFILLSMemo
 Description: Contact runoff from the active portion of landfill is a liquid hazardous waste because it is mixed with hazardous leachate (SEE ALSO: 61 FR 18779; 4/29/96). The placement of nonhazardous liquids on a landfill to meet requirements such as wind dispersal or dust suppression are not prohibited (3004(c)(3)).
 
04/21/1986LIQUIDS FOR WIND DISPERSAL CONTROL AT HAZARDOUS WASTE LANDFILLS, USE OFMemo
 Description: Nonhazardous liquids used for wind dispersal control at hazardous waste landfills are not subject to the section 3004(c)(3) liquid restrictions. The liquid restrictions cover treatment, storage, and disposal, not the use of a nonhazardous liquid for compliance with the technical requirements (SEE ALSO: current 264.301, 265.301).
 
04/02/1986CLOSURE OF A DOE SURFACE IMPOUNDMENT THAT LOST INTERIM STATUSMemo
 Description: A waste from a surface impoundment that lost interim status may be removed, treated, and placed back in the unit at closure. The replacement of waste from the same surface impoundment for closure does not constitute reuse. When unable to remove all constituents from the unit the owner or operator should follow section 265.310 closure as a landfill requirements.
 
03/26/1986ABOVE-GROUND LAND EMPLACEMENT FACILITIES, N.J. LAWMemo
 Description: Above ground long-term storage or disposal is land disposal. Section 3004(c)(1) prohibits the addition of absorbent to bulk liquid hazardous waste for disposal in a landfill. Section 3004(c)(2) allows the addition of non-biodegradable absorbent to containerized hazardous liquid (SEE ALSO: RPC# 11/17/93-02), current 264.314, 265.314).
 
03/14/1986SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTSMemo
 Description: The owner of a landfill applying for the liner exemption must show that the unit prevents migration of hazardous constituents. The bulk treatment for hazardous liquids cannot include absorption. Bulk liquids that have been chemically stabilized must pass the paint filter liquids test. Guidance on filtering groundwater prior to analysis. Brass bailers should not be used when sampling groundwater for metals. Guidance on the use of mathematical models when aquifers have unique features. The definition of a solid waste management unit (SWMU) includes the areas with routine and systematic releases. The use of surface water limits as Alternate Concentration limits (ACLs). Guidance on determining the potential point of exposure for ACL applications. The use of modeling information in establishing ACLs. ACL guidance allows grouping of hazardous constituents. Activated carbon filtration may not be appropriate for pentachlorophenol (PCP)-contaminated groundwater. Corrective action programs for regulated land disposal units must be part of a facility’s permit. The owner of a facility who counterpumps contaminated groundwater during corrective action must handle the contaminated groundwater as a hazardous waste, the Part B application must include groundwater management procedures.
 
03/06/1986GASEOUS EMISSIONS FROM LANDFILLSMemo
 Description: the EPA has authority under RCRA sections 3004(n) and 4004(a), and CAA to regulate gaseous emissions for hazardous and nonhazardous waste landfills (refer to CAA regulations for additional information).
 
03/03/1986CONSTRUCTION OF A NEW LANDFILL CELL AND THE OMNIBUS PROVISIONMemo
 Description: The construction of a new landfill cell at an interim status facility does not require a permit if the unit was detailed in an original Part A application. The landfill cell must have a double liner and a leachate collection system. A set of guidance on the location criteria and vulnerable groundwater for TSDFs. The omnibus permitting authority (3005(c)(3)) applies to permit conditions, and gives EPA a right to impose additional requirements on the construction of a new landfill cell at an interim status facility that is otherwise exempt from changes during interim status provisions (i.e., does not need to submit modified Part A).
 
01/31/1986RCRA CORRECTIVE ACTION PROCEDURES AND AUTHORITIESMemo
 Description: Discusses the procedures for terminating interim status. The applicability of corrective action to land disposal units receiving hazardous wastes after 7/26/82. The applicability of and authorities for corrective action and monitoring requirements for facilities undergoing closure with continuous releases. Guidance on fuels as a hazardous wastes (SEE ALSO: 59 FR 55778; 11/8/94).
 
12/13/1985LAND DISPOSAL UNIT CLOSURE - CLARIFICATION OF PROPOSED AND PROMULGATED RULESMemo
 Description: A land disposal unit that closes prior to the effective date of any regulation listing or characterizing a waste in the unit as hazardous is not regulated under Subtitle C (active management). The same unit located at an interim status facility or a facility seeking a permit may be subject to portions of HSWA. Under 3004(o)(1)(A), landfill and surface impoundment permits must require the installation of liners, leachate collection systems, and groundwater monitoring systems (minimum technological requirements (MTR)). Section 3005(j) requires interim status surface impoundments in existence on 11/8/84 to be in compliance with MTR (3004(o)) by 11/8/88. A surface impoundment that becomes regulated after 11/8/84 due to a new listing or characteristic is subject to the minimum technological requirements (MTR) four years from date of a new listing or characteristic (3005(j) and 3004(o)(1)). A land disposal unit that is not required to obtain a RCRA permit and not otherwise subject to HSWA does not have to be retrofitted under 3004(o).
 
12/05/1985PROHIBITION ON PLACING LIQUIDS IN LANDFILLMemo
 Description: The addition of absorbent to a bulk liquid hazardous waste intended for disposal violates RCRA (SEE ALSO: 11/17/93-02). The land disposal definition for the land disposal restrictions (LDR) includes landfills (3004(k)). An authorized State must permit the landfill under RCRA to be a RCRA landfill, a deviation under state law does not constitute a RCRA permit.
 
11/14/1985SURFACE IMPOUNDMENT RECEIVING LEACHATE, REGULATION OFMemo
 Description: A surface impoundment accepting landfill leachate exhibiting a characteristic is a hazardous waste facility.
 
10/18/1985SOLIDTEK LANDFILL/LINER DESIGNMemo
 Description: Discusses the landfill bottom liner permeability requirement for a three-foot recompacted clay bottom liner. A composite bottom liner design is more protective (SUPERSEDED: see 57 FR 3462; 1/29/92).
 
10/01/1985PERSONNEL TRAINING DURING POST-CLOSUREQuestion & Answer
 Description: Personnel training may not be required during post-closure if the owner or operator of an interim status surface impoundment or landfill is no longer actively managing hazardous waste. The owner must address all of the information requirements of 270.14 and 270.17 in post-closure permit application.
 
09/20/1985ABSORBENTS FOR CONTAINERIZED LIQUID HAZARDOUS WASTES, USE OFMemo
 Description: The statute prohibiting disposal of liquids in biodegradable sorbents in landfills (3004(c)(2)) is not effective until the regulations are promulgated (SEE ALSO: 57 FR 54452; 11/18/92).
 
09/01/1985NON-HAZARDOUS LIQUIDS BANQuestion & Answer
 Description: The ban on nonhazardous liquids in landfills applies to any waste that is liquid or contains free liquids as determined by the paint filter liquids test (Method 9095). Nonhazardous liquid solidified with absorbents can be land disposed if no free liquids (SUPERSEDED: See 264.314, 265.314).
 
08/07/1985LIQUID HAZARDOUS WASTES IN LANDFILLSMemo
 Description: The paint filter liquids test is used to verify no free-standing liquid. A definition of free-standing liquid vs. free liquid. Eliminate free-standing liquid before placement in landfill (3004(c)(1)). Stabilization of liquid on manifested solid is treatment requiring permit unless it meets addition of absorbent exemption.
 
08/01/1985MINIMUM TECHNOLOGICAL REQUIREMENTSQuestion & Answer
 Description: The design, construction, and operation of a surface impoundment and landfill liners meeting interim statutory design of 3004(o)(5)(B) should prevent migration of hazardous constituents as long as unit remains in operation, including post-closure (SUPERSEDED: See 264.221(c), 265.221(c))
 
07/10/1985REVISED DEFINITION OF SOLID WASTE PURSUANT TO HSWAMemo
 Description: Carbon regeneration facilities storing carbon before recycling need a permit for storage if they are an incinerator. If they are not an incinerator, they are exempt (may be BIF). Drum recyclers handling empty containers do not need a storage permit. The storage of non-empty containers would require at least a permit for hazardous waste storage. Spent activated charcoal or carbon is usually a spent material. If for pollution control, it would be a sludge. Carbon is hazardous waste (HW) if it contains a listed waste (contained-in policy) or exhibits a characteristic(SEE ALSO: 66 FR 27266; 5/16/01). Carbon is unlikely to exhibit a characteristic. Generators storing HW spent activated carbon are subject to accumulation time regulations. A closed municipal solid waste landfill (MSWLF) suspected of holding HW is subject to corrective action if the facility requires a permit or interim status and is subject to CERCLA.
 
07/01/1985DEFINITION OF EXISTING PORTIONQuestion & Answer
 Description: If a landfill has waste placed over fifty percent of the surface area, only the covered portion of the unit is an “existing portion,” not the whole unit.
 
05/29/1985BAN ON DISPOSAL OF LIQUIDS IN LANDFILLSMemo
 Description: RCRA section 3004(c) prohibits the disposal in landfills of containerized liquids absorbed in materials, that when compressed, release liquids. The use of chemical stabilization to convert a liquid to a solid is not the only option for dealing with bulk liquid hazardous waste.
 
05/10/1985CONTINUED LANDFILL DISPOSAL OF LAB PACKSMemo
 Description: Legislative history suggests that section 3004(c)(2) intended to allow the continued landfilling of lab packs in accordance with existing regulations.
 
05/01/1985LIQUIDS AND FREE LIQUIDS, DEFINITION OFQuestion & Answer
 Description: The paint filter test (method 9095) is used to determine if a material is a liquid under section 3004(c)(3) (Liquids in Landfills). EPA believes that Congress intended the term “liquid” in section 3004(c)(3) to encompass free liquids as well as liquids.
 
04/23/1985RCRA METHODS AND QA ACTIVITIES (NOTES)Memo
 Description: Delisting public meetings were held. SW-846 was updated. A discussion of the development of new methods, reevaluation of existing methods: 9022, 450.1, 8030, 8090, 8280. An overview of using gas chromatography/Fourier transform infrared protocol for semivolatile organics. Discusses the methods for compounds that do not use gas chromatograph. EPA is developing a sorbent pressure test method to determine if sorbents will release liquids under simulated landfill pressure.
 
04/01/1985HSWA MINIMUM TECH REQUIREMENTS FOR LINERS AND LEACHATE COLLECTION SYSTEMSMemo
 Description: Existing land-based units (surface impoundments, waste piles, and landfills) must be upgraded to meet minimum technological requirements (MTR) for double liners and leachate collection systems.
 
03/01/1985WASTE PILE LINERS - MTR (264.251)Question & Answer
 Description: The 3004(o) minimum technological requirements apply to landfills and surface impoundments, but not to waste piles. RCRA 3015(a) imposes liner and leachate collection requirements on new interim status waste piles, lateral expansions, and replacements. Expansions of interim status waste piles must be lined if they exceed the boundaries of the existing unit (3015(a)).
 
01/22/1985NONHAZARDOUS LIQUID WASTEWATERS AND SLUDGES IN SANITARY LF UNDER RCRA AND HSWA, DISPOSAL OFMemo
 Description: There are no federal regulatory provisions on the disposal of bulk or containerized nonhazardous liquid wastes in a nonhazardous solid waste landfill or a municipal solid waste waste landfill (MSWLF). Disposal of nonhazardous liquid waste in hazardous waste landfills is prohibited (SUPERSEDED: see 56 FR 50978; 10/9/91).
 
01/11/1985LANDFILL GAS CONDENSATE, REGULATION OFMemo
 Description: Landfill gas condensate from a landfill containing listed wastes is listed. Condensate from municipal waste or characteristic waste is hazardous only if it is characteristic. Condensate from household waste only is exempt. The household hazardous waste (HHW) exclusion applies to household hazardous waste being collected, treated, disposed, and its resulting residues.
 
01/01/1985TREATMENT SURFACE IMPOUNDMENTS LOSING INTERIM STATUS BECAUSE OF NON-COMPLIANCE WITH GWM AND FINANCIAL RESPONSIBILITY REQUIREMENTSQuestion & Answer
 Description: Owners and operators of interim status land treatment units were required to submit a Part B application, certify compliance with groundwater monitoring, and obtain financial assurance by 11/8/85 (3005(e)(2)). Land disposal units include all land-based hazardous waste management systems.
 
11/14/1984LEACHATE AND PRECIPITATION RUN-OFF AT LFS, WASTE PILES, AND LT UNITS, HAZARDOUS WASTE FROM MIXTURE OFMemo
 Description: Precipitation run-off (PRO) is not presumed to be a hazardous waste. Mixtures of hazardous waste leachate and PRO are hazardous. PRO from active portions of landfills/waste piles is presumed to be hazardous due to mixing with the leachate. PRO from closed portions of landfills is presumed to be nonhazardous. PRO from land-treatment units is presumed to be nonhazardous. PRO is a liquid which flows over and quickly off the land. PRO is excluded from the derived-from rule. PRO is hazardous if it exhibits a characteristic or is mixed with a hazardous waste. Leachate refers to liquid that has made significant contact with hazardous waste. Leachate from a characteristic waste is presumed hazardous until it is shown not to be hazardous. Under the mixture rule, waste mixtures containing a characteristic waste are like other solid waste and are hazardous if they exhibit a characteristic.
 
11/13/1984LIQUIDS IN LANDFILLS PROHIBITIONMemo
 Description: The statutory ban on disposal of bulk liquids in hazardous waste landfills does not prohibit disposal of liquids after proper chemical stabilization (SEE ALSO: RPC# 11/17/93-02; 57 FR 54452; 11/18/92).
 
11/12/1984PLACEMENT OF BULK LIQUIDS IN LANDFILLMemo
 Description: Solidification of a bulk or noncontainerized liquid in a pit at the bottom of an unlined landfill cell is prohibited. Treatment or stabilization of a liquid must occur before disposal.
 
10/01/1984WASTE DUMPED ON GROUND CONSIDERED STORAGE IN A WASTE PILEQuestion & Answer
 Description: If waste is dumped on the ground outside of a land treatment unit, the area should be regulated as a waste pile or landfill. EPA does not recommend dumping and spreading as an adequate land application procedure (SEE ALSO: 61 FR 18779; 4/29/96).
 
09/18/1984CLOSURE PLAN COMMENTS/ISSUES (CRUCIBLE STEEL)Memo
 Description: The requirement for a final cover at the closure of a landfill should not be delayed to allow continued disposal of nonhazardous waste. A delay of closure must be related to the need for extra time to complete closure activities or to a transfer of the operation to new parties (SUPERSEDED: see current 265.113(d)). A landfill’s final cover may be covered by nonhazardous waste only if it is necessary to the proposed use of the property and if it will not increase potential hazards.
 
09/10/1984DESIGN AND OPERATING STANDARDSMemo
 Description: The regulatory intent of the landfill liner requirement is the construction of a liner rather than relying on hydrogeologic forces. The regulations have no general provisions for waiving a specific section on a case-by-case basis. Land disposal facility liners must be synthetic.
 
08/01/1984LANDFILLS WITH EP TOXIC LEACHATE, REGULATION OFQuestion & Answer
 Description: Once leachate is collected, subsequent management is regulated if the leachate is a hazardous waste. If extraction procedure (EP) (SUPERSEDED: see 261.24) toxic leachate collected from a sanitary landfill is pumped back into the landfill, the landfill is subject to TSDF requirements (SUPERSEDED: see 258.28(a)(2)).
 
07/01/1984WASTE AS LIQUID OR SOLID, DETERMINATION OFQuestion & Answer
 Description: The phase of a waste should be determined just prior to landfill disposal. If a waste liquefies during transportation, it is proper to allow a shipment of containers to stabilize or solidify before performing the free liquids test (SEE ALSO: 40 CFR 268.3).
 
05/14/1984VARIANCE FROM 264 LANDFILL LINER & LEACHATE COLLECTION REQUIREMENTSMemo
 Description: A waiver from landfill liner and leachate collection requirements cannot be granted when the leachate enters groundwater, even when a nearby aquifer will not be contaminated.
 
04/10/1984RUN-OFF FROM ACTIVE PORTIONS OF HAZARDOUS WASTE MANAGEMENT UNITSMemo
 Description: Discussion of the regulatory status of precipitation runoff from active and inactive landfill units (derived-from rule, mixture rule). Discussion of distinctions between precipitation runoff and mixtures of precipitation with hazardous waste or hazardous waste leachate.
 
02/07/1984LINER DESIGN COMMENTS (CWM, EMELLE,AL)Memo
 Description: The regulatory intent of the landfill liner requirement is to construct a liner rather than rely on hydrogeologic forces.
 
10/21/1983LEACHATE FROM A MUNICIPAL LANDFILL, REGULATION OFMemo
 Description: Leachate from municipal landfills must be handled as hazardous if it is characteristic. The landfill is the generator of the waste. Nonhazardous leachate can be recycled into the landfill. Hazardous leachate must go to a TSDF or POTW unless the landfill is an exempt small quantity generator (SUPERSEDED: for landfill leachate recirculation, see 258.28) (SEE ALSO: 261.31 (F039 listing), 261.5, 262.34).
 
06/10/1983SPENT SOLVENT LISTINGS & LEACHATE FROM SANITARY LFS THAT RECEIVED HAZARDOUS WASTEMemo
 Description: Spent 1,1,1-TCE from a cleaning process is F002. Process waste containing TCE is not listed unless it is mixed with listed solvent, although it may be characteristic. Sanitary landfill leachate containing listed solvent is listed HW.
 
01/11/1983CLOSURE & POST-CLOSURE REQUIREMENTS REGARDING HAZARDOUS WASTE TREATMENT, STORAGE AND DISPOSAL FACILITIESMemo
 Description: Recontouring a final cover and adjusting in-place waste is not considered receipt of hazardous waste at a closed facility. Closure and post-closure plans are to account for vegetation and liquid inputs. Landfill closure standards require a final cover to minimze the migration of liquids through the closed landfill. Discussion of the addition of liquids during versus after closure (may be allowed during closure, including leachate recirculation, if part of closure plan). The recirculation of leachate during operation is not a closure activity. Receipt of hazardous waste after 1/26/83 causes impoundment or landfill to be a regulated unit, but redeposit of treated waste during closure does not make the unit regulated unit. If a landfill is a series of separately lined trenches, each trench is a separate waste management unit.
 
12/29/1982LAND DISPOSAL PERMIT STRATEGYMemo
 Description: Discusses the historical priorities for permitting of land disposal units (surface impoundments, waste piles, land treatment units, and landfills).
 
12/01/1982EXEMPTION FROM LINER REQUIREMENTS FOR EXISTING PORTIONSQuestion & Answer
 Description: The exemption from the liner requirements for existing portions of landfills, surface impoundments, and waste piles applies to bottom and side liners.
 
02/01/1982GROUNDWATER MONITORING AND LEAKING WASTE PILESQuestion & Answer
 Description: An interim status waste pile leaking hazardous leachate into the ground is out of compliance. The owner or operator can take remedial action or modify their Part A permit application, reclassifying the waste pile as a land treatment unit or landfill, for which groundwater monitoring would be required under changes during interim status.
 
03/12/1981INTERIM STATUS OF PROPOSED LANDFILL CELLSMemo
 Description: Proposed landfill cells included in a part A permit application may qualify for interim status.
 
05/01/1979Demonstrating Leachate Treatment Report on a Full-Scale Operating PlantPublication
 Description: This document discusses the results of a study on the operation of a full-scale sanitary landfill leachate treatment plant designed to provide a variety of chemical or physical and biological treatment sequence options.
 
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