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Show details for Air Emissions (RCRA)Air Emissions (RCRA)
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12/01/2007RCRA Orientation Manual 2008Publication
 Description: This document updates the 2003 RCRA Orientation Manual (EPA530-R-06-003). This updated manual provides introductory information on the solid and hazardous waste management programs under the Resource Conservation and Recovery Act (RCRA). Designed for EPA and state staff, members of the regulated community, and the general public who wish to better understand RCRA, this document constitutes a review of the RCRA program and is not a substitute for RCRA or its implementing regulations.
 
02/16/2007TURNOVER OF HAZARDOUS WASTES STORED IN GENERATOR ACCUMULATION TANKSMemo
 Description: In a batch process, as with accumulation in containers, the 90-day period begins the moment the generator first places hazardous wastes in an “empty tank.” The generator then must remove all wastes from the tank within 90 days from the time he first places wastes in the “empty” tank. A tank will be considered empty when its contents have been drained to the fullest extent possible. Since many tank designs do not allow for complete tank drainage due to flanges, screens or siphons, it is not expected that 100% of the wastes will always be removed. As general guidance, a tank should be considered empty when the generator has left the tank’s drainage system open until a steady, continuous flow has ceased (see also 47 FR 1250; January 11, 1982). Under the continuous flow process, in contrast to the batch process, the tank receives hazardous waste on an ongoing, continuous basis. When wastes are flowing through tanks continuously, there is a means of demonstrating when a tank is “emptied” within 90 days under 40 CFR 262.34(a)(1)(ii) that would not require completely emptying the tank, and that may be more suitable for tanks with continuous flow called mass balance approach.
 
02/16/2007TURNOVER OF HAZARDOUS WASTES STORED IN GENERATOR ACCUMULATION TANKSMemo
 Description: In a batch process, as with accumulation in containers, the 90-day period begins the moment the generator first places hazardous wastes in an “empty tank.” The generator then must remove all wastes from the tank within 90 days from the time he first places wastes in the “empty” tank. A tank will be considered empty when its contents have been drained to the fullest extent possible. Since many tank designs do not allow for complete tank drainage due to flanges, screens or siphons, it is not expected that 100% of the wastes will always be removed. As general guidance, a tank should be considered empty when the generator has left the tank’s drainage system open until a steady, continuous flow has ceased (see also 47 FR 1250; January 11, 1982). Under the continuous flow process, in contrast to the batch process, the tank receives hazardous waste on an ongoing, continuous basis. When wastes are flowing through tanks continuously, there is a means of demonstrating when a tank is “emptied” within 90 days under 40 CFR 262.34(a)(1)(ii) that would not require completely emptying the tank, and that may be more suitable for tanks with continuous flow called mass balance approach.
 
08/01/2003SMALL QUANTITY GENERATOR TREATMENT IN TANKSQuestion & Answer
 Description: Hazardous waste generators may treat waste on site in accumulation tanks or containers without a permit or interim status provided that they comply with applicable provisions in 40 CFR 262.34 and the treatment is not thermal treatment (SEE ALSO: 56 FR 10146, 10168; 3/24/86). A small quantity generator (SQG) performing on-site treatment in a tank only follows the special standards in 265.201 and not all of the Part 265, Subpart J requirements. Standards in 265.201 supplant Subpart J requirements for SQGs rather than supplement them. Part 265, Subparts I and J, including SQG tank standards in 265.201, apply whether a unit is used for treatment or accumulation. Authorized states can have more stringent requirements.
 
06/01/2003START DATES ON LARGE QUANTITY GENERATOR TANKSQuestion & Answer
 Description: A large quantity generator (LQG) accumulating hazardous waste in a tank must mark the tank with the date upon which the hazardous waste accumulation period begins. The requirement is not cited in 40 CFR 262.34(a)(2), but EPA intended for both tanks and containers to be marked with the accumulation start date (SEE ALSO: 51 FR 10146, 10160; 3/24/86). The requirement ensures that an LQG accumulates hazardous waste in accordance with the 90-day accumulation time limit.
 
11/18/2002GUIDANCE ON RCRA SUBPART J SECONDARY CONTAINMENT REQUIREMENTS AT AUTOMOBILE SPRAY PAINTING OPERATIONSMemo
 Description: The point of generation is when the paint-solvent mixture exits the spray gun. Piping from the point of generation to a storage tank is ancillary equipment and needs secondary containment. A building may fulfill the secondary containment requirements for indoor tanks and ancillary equipment if it is in accordance with 265.193(b) and (c). Compliance with the secondary containment provisions is site-specific. An owner may apply for a technology-based variance from the secondary containment requirements per 265.193(g). Automobile manufacturing plants that manage purge solvent may receive a variance if certain criteria are met.
 
05/20/2002POINT OF GENERATION FOR SPRAY PAINTING OPERATIONSMemo
 Description: The point of generation of hazardous waste from spray painting operations is at the emergence from the spray paint gun. EPA is working on maximum achievable control technology (MACT) standards for emissions from transporting the waste inside the auto plant building. EPA is also working on Subpart J guidance to reduce or eliminate industry burden, while ensuring that leaks are properly captured and contained.
 
07/18/2000GENERATOR TREATMENT OF SOIL IN A CONTAINERMemo
 Description: Generators may treat wastes in accumulation tanks and containers as long as they comply with the provisions of 262.34. Generator treatment exemption may apply to treatment of hazardous waste cleanups (SEE ALSO: RPC# 10/14/98-01). Authorized state program may have more stringent requirements.
 
06/26/2000REGULATORY STATUS OF A SUMP ASSOCIATED WITH AN ELEMENTARY NEUTRALIZATION UNITMemo
 Description: Sump which meets definition of tank and is used in conveying hazardous wastewater to elementary neutralization unit (ENU) could be considered ancillary equipment to ENU and exempt from the requirements of Parts 264, 265, and 270. Authorized state program or Region must make site-specific determination.
 
05/26/2000KODAK CLAIM FOR MANUFACTURING PROCESS UNIT EXEMPTION TO THE RCRA SUBPART BB AIR EMISSIONS REQUIREMENTSMemo
 Description: Piping system leading from reactor unit that at times carries hazardous waste is not part of exempt manufacturing process unit. Piping system that carries hazardous waste with more than 10 percent organics for more than 300 hours per year is subject to Subpart BB (SEE ALSO: RPC# 12/19/86-01; 45 FR 72025; 10/30/80).
 
04/01/2000APPLICABILITY OF THE SUBPART CC LDR EXEMPTION TO SOILSQuestion & Answer
 Description: Tanks, containers, and surface impoundments storing soils that contain hazardous waste are eligible for land disposal restrictions (LDR) exemption from Subpart CC only when VOCs meet 268.40 numerical concentrations or when soil has been treated by treatment technology in 268.42(a) for organic hazardous constituents. Wastes treated to meet alternative soil treatment standards remain subject to Subpart CC.
 
11/03/1999CLARIFICATION OF REQUIREMENTS FOR SECONDARY CONTAINMENT SYSTEMS ASSOCIATED WITH HAZARDOUS WASTE TANKSMemo
 Description: External liners used as tank secondary containment must be free of cracks and gaps, and be designed to prevent migration of waste. Water stops at all joints and impermeable coatings are appropriate for concrete external liner systems. Although regulations allow for potential alternatives, EPA cannot envision a concrete containment structure meeting the regulatory requirements to prevent migration of waste without the use of impermeable coatings or water stops (SEE ALSO: 53 FR 34079, 34084; 9/2/88).
 
09/23/1999U.S. ARMY - PICATINNY ARSENAL REQUEST FOR WAIVER FROM 40 CFR PART 64, SUBPART CC STANDARDS FOR TANKS AT A PROPOSED HAZARDOUS WASTE INCINERATORMemo
 Description: There is no current provision for waiver from compliance with Subpart CC air emission standards. Miscellaneous units are subject to air emission standards. Waste determination must be made before hazardous waste is placed in tank.
 
10/23/1998PERMITTING OF CATALYZED ELECTROCHEMICAL OXIDATION PROCESSMemo
 Description: Non-thermal treatment process may qualify for generator exclusion from permitting provided the system meets the definition of a tank or container, complies with all applicable tank and container management standards, and treats waste generated on-site within the time periods specified in 262.34.
 
07/01/1998RCRA Organic Air Emission Standards for TSDFs and GeneratorsPublication
 Description: This document provides information about the requirements of RCRA organic air emission standards covered under 40 CFR Parts 264/265, subpart CC. It summarizes information about applicability, effective dates, tanks, surface impoundments, containers, miscellaneous units, inspection and monitoring requirements, and the difference between permitted and interim status facilities, and defines relevant terms.
 
04/09/1998INTERPRETATION OF WASTEWATER TREATMENT UNIT EXEMPTIONMemo
 Description: Tanks satisfying the wastewater treatment unit (WWTU) exemption must be dedicated solely for on-site wastewater treatment at all times and for no other purpose. EPA did not intend for the exemption to apply in either the dual use or alternating use scenario. The generator accumulation provision can be used in such instances.
 
02/06/1998STATE OF UTAH REQUEST REGARDING STATUS OF HAZARDOUS WASTE MANAGEMENT UNITS LOCATED WITHIN A CONTAINMENT BUILDINGMemo
 Description: Whether or not tanks, containers, or miscellaneous units are located within a containment building does not change the regulatory status of those units. Containment building could satisfy secondary containment requirements for tanks or containers.
 
02/01/1998CERTIFICATION OF TANK CLOSURE DURING PARTIAL CLOSUREQuestion & Answer
 Description: Owners and operators are not required to certify partial closure of tanks until all hazardous waste management units are closed and final closure is certified for the entire facility. Owners and operators are still required to remove or decontaminate in accordance with their approved closure plan.
 
12/01/1997DEFINITION OF ""ANNUALLY"" FOR INTERIM STATUS TANK INSPECTIONSQuestion & Answer
 Description: Annual leak assessments for interim status hazardous waste storage tanks must be performed once every twelve (12) months, not once every calendar year. Leak tests must continue to be conducted within 12-month intervals of the most recent test until secondary containment is installed or the tank is closed.
 
09/01/1997CONTAINMENT BUILDINGS AS SECONDARY CONTAINMENTQuestion & Answer
 Description: Containment buildings may serve as secondary containment for LQG accumulation tanks if the building itself acts as a liner and meets the secondary containment provisions of Sections 264/265.193. Containment buildings need not meet the provisions of Parts 264/265, Subpart DD to be used as secondary containment for tanks.
 
09/01/1997GENERATOR STORAGE OF USED OILQuestion & Answer
 Description: Containers and tanks storing used oil do not need to comply with Parts 264/265, Subparts I or J, provided the used oil has not been mixed with a hazardous waste. Units other than tanks or containers (e.g., surface impoundments) storing used oil must be permitted or operating under interim status.
 
08/01/1997PRETREATMENT STANDARDS FOR WASTEWATER TREATMENT UNITSQuestion & Answer
 Description: Facilities that discharge a pollutant covered under CWA Section 307(b) to a publicly owned treatment works (POTW) are considered to be subject to the CWA. Tanks or tank systems that treat hazardous wastewaters before discharging them to a POTW can qualify as exempt wastewater treatment units (WWTUs) because they are subject to the CWA.
 
07/29/1997REGULATION OF EQUIPMENT USED TO CONVEY SOLVENTSMemo
 Description: Solvent used to clean a spray painting unit (gun) is a waste once it leaves the painting unit since it is physically removed from the unit and will no longer be used. Equalization tanks and associate piping used to convey the waste solvent to an accumulation unit are part of the waste storage tank system and subject to generator accumulation requirements and hazardous waste tank standards as applicable. Systems that solely manage waste are not considered part of the manufacturing process.
 
05/01/1997APPLICABILITY OF K052 WASTE CODE TO PIPELINE TERMINALSQuestion & Answer
 Description: The K052 listing is limited to leaded tank bottoms generated at petroleum refineries. Leaded tank bottoms generated at pipeline terminals that are not directly part of a refinery do not meet the K052 listing, and are only hazardous wastes if characteristic.
 
04/04/1997CONCRETE LINERS AS SECONDARY CONTAINMENT STRUCTURES IN HAZARDOUS WASTE TANK SYSTEMSMemo
 Description: Owners and operators of hazardous waste tank systems using concrete structures as secondary containment must address settling, cracking, permeability, and detectability of cracks or leaks. EPA feels that concrete structures that are properly designed, installed, and maintained are acceptable secondary containment structures. Whether a concrete liner made from silica fume lightweight aggregate (SFLWA) is acceptable is up to the implementing agency.
 
04/01/1997GENERATOR STORAGE REQUIREMENTS FOR PART 266, SUBPART F, PRECIOUS METALSQuestion & Answer
 Description: Generators accumulating recyclable materials for precious metal recovery are not required to store the materials in RCRA-regulated accumulation units (i.e., tanks, containers, and containment buildings). EPA assumes these materials will be managed carefully due to their economic value. Precious metals being reclaimed must be counted towards generator monthly determination.
 
04/01/1997RCRA Implementation Plan (RIP): Fiscal Years 1998-1999Publication
 Description: This document defines national policy, strategic goals, priority activities, and core measures for OSWER programs. It covers the RCRA program, including the Underground Storage Tank program, and provides information on the Superfund program.
 
04/01/1997TREATMENT STANDARDS FOR D008 RADIOACTIVE LEAD TANKS AND CONTAINERSQuestion & Answer
 Description: D008 radioactive lead solids that are tanks or containers must be treated using macroencapsulation. The placement of waste in a container or tank is not considered macroencapsulation. The owner/operator may use an alternative treatment method if demonstrated to be an equivalent technology.
 
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.
 
11/27/1996APPLICABILITY OF 40 CFR PART 279 TO ON-SPECIFICATION USED OILMemo
 Description: On-specification used oil that will be burned for energy recovery is no longer subject to the used oil requirements once the person making the on-specification claim complies with the applicable marketer provisions. Used oil meeting specification that is refined or disposed is subject to the used oil requirements. The regulatory status of the on-specification oil must be reevaluated if some action is taken that may affect the properties of the oil. Blending used oil to meet specification is processing. Used oil storage may be covered under the Spill Prevention Control and Countermeasures (SPCC) regulations and the underground storage tank (UST) requirements.
 
11/01/1996DETERMINATION OF EQUIVALENT TREATMENT UNDER 268.42(B)Memo
 Description: EPA is approving the determination of equivalent treatment (DET) per 268.42(b) for wastewater sludges from bulk liquid storage tank washings, line cleanings, and shipboard ballast water and other wastes because combustion is not appropriate.
 
09/23/1996APPLICABILITY OF RCRA REGULATIONS TO CHEMICAL FLOCCULATION UNITS WHEN USED TO TREAT WASH WATER FROM AIRCRAFT ENGINESMemo
 Description: A chemical flocculation unit treating cadmium contaminated wash water requires a hazardous waste treatment permit, unless the unit meets an exemption. If the unit is a tank meeting the definition of a wastewater treatment unit (WWTU), or a tank or container regulated as a generator accumulation unit, the unit is exempt from permitting. Treatment sludge generated in the unit must be managed as a hazardous waste if it exhibits a characteristic. Land disposal restrictions (LDR) apply to the treatment sludge and the original wash water.
 
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.
 
06/01/1996TANK STORAGE AT TRANSFER FACILITIESQuestion & Answer
 Description: A transporter may not store hazardous waste in stationary tanks at a transfer facility without a permit or interim status. Hazardous wastes at transfer facilities must be manifested, stored in containers meeting DOT requirements, and be held 10 days or less. Discussed the definition of container.
 
05/01/1996RESOLUTION OF RCRA ISSUES RELATING TO THE WOOD PRESERVING INDUSTRYMemo
 Description: Drip pad sumps can satisfy the wastewater treatment unit (WWTU) exemption if they are part of the facility’s wastewater treatment system, even though the wood preserving regulations require sumps to meet Subpart J tank standards. If a wood preserving facility qualifies as a conditionally exempt small quantity generator (CESQG), it is conditionally exempt from Parts 264/265, Subparts W and J requirements.
 
09/19/1995EPA'S DETERMINATION ON WHETHER MACROENCAPSULATION PROCESS ADDRESSES THE REQUIREMENTS OF 40 CFR SECTION 268.45, TABLE 1Memo
 Description: The definition of “macroencapsulation” is different for radioactive lead solids and debris. Debris macroencapsulation may include a tank or container. Merely placing debris in a container is not “macroencapsulation” unless the container is of non-corroding material (stainless steel).
 
05/25/1995ARE TANK BOTTOMS REMOVED FROM TANKS CONTAINING ONLY NAPHTHA DEEMED TO BE K052 HAZARDOUS WASTE?Memo
 Description: K052 is limited to tank bottoms generated at or as part of a petroleum refinery from tanks used to store leaded gasoline or leaded blending fractions. The listing applies regardless of whether the waste exhibits a characteristic. Because naptha is an unleaded petroleum fraction, tank bottoms from naptha storage at a refinery are not K052.
 
03/08/1995APPLICABILITY OF RCRA TO HAZARDOUS WASTES GENERATED IN PRODUCT STORAGE TANKS AND MANUFACTURING PROCESS UNITSMemo
 Description: Waste generated in a manufacturing process unit or a product storage tank is not regulated until it exits the unit or unless it remains in the unit for more than 90 days after the unit has been shut down. After removal from the unit, the waste may be accumulated without a permit for an additional period, depending on generator status.
 
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.
 
12/01/1994ELEMENTARY NEUTRALIZATION UNITS GENERATING AND STORING NON-CORROSIVE HAZARDOUS WASTESQuestion & Answer
 Description: A tank in which corrosive-only (D002) electroplating wastewaters are treated meets the definition of elementary neutralization unit (ENU), even if the treatment process produces an F006 sludge. F006 is subject to regulation once it is removed from the tank.
 
11/01/1994UST REMEDIATION WASTESQuestion & Answer
 Description: Spent carbon filters used to remediate petroleum-contaminated media and debris from underground storage tank corrective action are newly generated wastes and do not qualify for the Section 261.4(b)(10) exclusion. Spent filters are solid wastes.
 
10/17/1994REGULATION OF FUEL BLENDING AND RELATED TREATMENT AND STORAGE ACTIVITIESMemo
 Description: Fuel blenders are subject to 268.7(b) LDR notification and certification. Fuel blending is not exempt from permitting, unless it is done at a generator site in a 262.34 accumulation unit. Fuel blending at a transfer facility is treatment and requires a permit. Most fuel blending units are permitted as tanks or miscellaneous units. Fuel blenders are subject to the air emissions standards (SEE ALSO: RPC# 12/5/94-01; 59 FR 62896; 12/6/94). Thermal treatment units are not eligible for the 262.34 permit exemption. Recycling units at facilities with other permitted units are subject to the air emissions standards (SEE ALSO: 62 FR 25997; 5/12/97). Generators who send waste off-site to a burner are subject to LDR notification. Cement or light-weight aggregate kiln produced by a Bevill device burning both hazardous waste and Bevill-exempt wastes may be exempt from land disposal restrictions (LDR) treatment standards when used in a manner constituting disposal if the residues pass the significantly affected test in 266.112. If neither the products nor the residues are subject to the LDR treatment standards, the original generator's waste is not prohibited from land disposal, and is subject only to 268.7(a)(6) (SEE ALSO: 62 FR 25997; 5/12/97).
 
09/01/1994CONTAINMENT BUILDINGS AS GENERATOR ACCUMULATION UNITSQuestion & Answer
 Description: Small quantity generators (SQGs) who accumulate waste in a containment building without a permit are subject to the more stringent standards of Section 262.34(a), including the 90 day time limit. SQGs who accumulate under Section 262.34(d) are limited to the use of tanks and containers.
 
05/12/1994CLARIFICATION OF THE REGULATORY STATUS OF A REFINERY DITCH SYSTEMMemo
 Description: An unlined trough, trench, ditch is not ancillary equipment to a tank or sump because they are not constructed of leak proof material or do not have structural support or strength. Discusses the distinction between tank and surface impoundment. Can retrofit ditches to meet the criteria and quality as a wastewater treatment unit (WWTU).
 
05/09/1994REGULATORY REQUIREMENTS FOR ON-SITE TREATMENT OF OXYGEN BREATHING APPARATUS (OBA) CANISTERSMemo
 Description: Oxygen breathing apparatus (OBA) used by firefighters could qualify as exempt scrap metal when recycled. There is no need to determine if recycled scrap metal is a hazardous waste (HW). Emptying a steel OBA canister could be an exempt scrap steel recycling process if the canisters are to be recycled (SEE ALSO: 261.4(a)(13) exclusion for processed scrap metal). Emptying canisters to render them nonhazardous prior to disposal may be regulated treatment. HW canisters may be accumulated on-site without a permit under 262.34. Tanks meeting the wastewater treatment unit definition are exempt from permitting requirements.
 
02/16/1994ACCEPTABILITY UNDER THE RCRA LAND DISPOSAL RESTRICTIONS OF TWO METHODS OF MACROENCAPSULATION FOR MIXED WASTES AT ROCKY FLATSMemo
 Description: The definition of macroencapsulation entails the use of a jacket or inert inorganic material and not merely placement in a tank or container because of the void spaces between the debris and the container. Discusses possible placement with variance from treatment standard, equivalent method variance, or no-migration variance. Discusses the performance standards for immobilization technologies.
 
02/01/1994K052: BOTTOMS FROM TANKS STORING LEADED GASOLINE AT PETROLEUM REFINERIESQuestion & Answer
 Description: The K052 listing applies only to bottoms from tanks storing leaded gasoline at petroleum refineries. The listing does not apply to bottoms from refinery tanks storing other petroleum fractions.
 
02/01/1994REGULATORY STATUS OF SHELL OIL'S NORCO, LOUISIANA FACILITY DITCH SYSTEMMemo
 Description: A trough, trench, or ditch connected to a tank or sump is ancillary equipment. Unlined conveyance systems allowing leakage or a discharge is not ancillary equipment, and may be considered disposal, and may be considered a surface impoundment, miscellaneous, or solid waste management unit (SWMU) subject to corrective action. An unlined trough, trench, ditch that is retrofitted may meet the definition of ancillary equipment to tank and qualify for the wastewater treatment unit (WWTU) exemption.
 
11/01/1993CONTAINMENT BUILDINGS AS INDEPENDENT HAZARDOUS WASTE MANAGEMENT UNITSQuestion & Answer
 Description: A containment building is intended to be an independent hazardous waste management units. Existing tanks, containers, and drip pads do not need to be within a containment buildings. Containment buildings can serve as secondary containment for tanks.
 
11/01/1993GENERATOR MANAGEMENT OF HAZARDOUS WASTE AND THE 90-DAY TREATMENT EXEMPTIONMemo
 Description: The transfer of waste to different tanks or containers does not affect the 262.34 generator accumulation unit treatment exemption. Although treatment may remove the hazardous characteristic, land disposal restrictions (LDR) requirements still apply, including 268.7(a)(4).
 
11/01/1993REGULATORY STATUS OF A DISSOLVED AIR FLOATATION FLOAT STORAGE TANK USED TO FEED MATERIAL INTO A PETROLEUM COKERMemo
 Description: A Dissolved Air Flotation (DAF) float that is inserted into a petroleum coker is a solid and hazardous waste (SEE ALSO: Section 261.4(a)(12)). A DAF float feed tank may be an exempt wastewater treatment unit (WWTU) provided it meets the criteria listed in Section 260.10.
 
10/07/1993CLARIFICATION OF THE USE OF UNDERGROUND STORAGE TANKS TO CONTAIN HAZARDOUS WASTE SPILLSMemo
 Description: An underground tank used to contain a spill of hazardous waste solvent is a hazardous waste tank system. An underground tank used to contain a spill of reclaimed solvent not a hazardous waste tank system, but it may be subject to Part 280.
 
09/20/1993DISCARDED OFF-GAS PIPING, EQUIPMENT, AND OFF-GAS SCRUBBER SOLUTION FROM A TANK SYSTEMMemo
 Description: Discarded off-gas scrubber solution is not listed hazardous waste because the gas contained in the solution is derived-from a product, not a waste. Liquid tank residuals are listed CCP. If container from which residues are removed is RCRA empty, residue not hazardous waste (SUPERSEDED: See the April 12, 2004 letter from Springer to Coles). Contains discussion of the triple rinsing requirement for acute (P-listed) waste.
 
02/01/1993CLOSED-LOOP RECYCLING EXCLUSIONQuestion & Answer
 Description: Secondary materials stored in open-top tanks may qualify for closed-loop recycling exclusion as long as the system meets requirements in Section 261.4(a)(8). Secondary materials should be managed as valuable materials prior to reclamation to ensure the exclusion will apply.
 
11/27/1992CLARIFICATION OF STATUS OF TREATMENT ASSOCIATED WITH FUEL BLENDING ACTIVITIESMemo
 Description: Treatment associated with hazardous waste fuel blending is subject to regulation. EPA explicitly interpreted the now deleted Section 266.34, to require tank standards to apply to fuel blending tanks. Non-storage activities at fuel blending facilities (e.g., microwave units and distillation columns) may require a treatment permit. All storage of all hazardous waste fuels subject to regulation.
 
10/29/1992RECYCLING OF COKE BY-PRODUCT RESIDUESMemo
 Description: The use of open pits, or flat or low-walled concrete pads to store coke by-product residues is land disposal. Therefore, management of wastes in these units is not exempt under 261.4(a)(10). Wastes managed on the ground or in units constructed so that waste spills or is otherwise disposed are not exempt. Tanks, containers, and containment buildings are units that qualify for the recycling exclusion.
 
10/15/1992REGULATORY STATUS OF SOILS CONTAMINATED FROM RELEASES OF COMMERCIAL CHEMICAL PRODUCTSMemo
 Description: Product carbon tetrachloride released from a tank is U211. Soils containing hazardous waste must be managed as a hazardous wastes until or unless they no longer contain listed waste, exhibit characteristic, or are delisted pursuant to the contained-in policy. The health-based levels used in contained-in determinations are site-specific.
 
08/27/1992RCRA REGULATORY INTERPRETATION ON BENZENE STRIPPERS AT WRC REFINERYMemo
 Description: Refinery benzene stripper is a hazardous waste treatment unit, not tank ancillary equipment. Benzene stripper could be a fully regulated, wastewater treatment unit (WWTU), or generator accumulation unit.
 
07/21/1992TREATING WASTES IN GENERATORS ACCUMULATION TANKS AND CONTAINERSMemo
 Description: Generators may conduct treatment of used oil (e.g., mixing characteristic used oil with another material to render the used oil nonhazardous) in accumulation tanks or containers without a permit or interim status provided that the units conform to the standards in Part 265, Subparts I or J, and 262.34.
 
09/20/1991TREATMENT OF HAZARDOUS WASTE FROM LARGE QUANTITY GENERATORSMemo
 Description: Both LQGs and SQGs can treat in accumulation tanks or containers without a permit if the treatment is in compliance with the 262.34 generator accumulation requirements. Generators who accumulate waste in 262.34 units must comply with the waste analysis plan (WAP) requirements per 268.7(a)(4). Treatment in generator accumulation units cannot violate the dilution prohibition.
 
07/03/1991TCLP AND LEAD PAINT REMOVAL DEBRISMemo
 Description: Provides general guidance for the representative sampling of lead-based paint abatement wastes (debris and abrasives) from drums, roll off boxes, and other containers. Shipments of LBP abatement wastes from a field site (bridge repair) to a central accumulation point must generally be accompanied by a manifest. The central accumulation point must be a transfer facility or a TSDF to accept manifested hazardous waste. Generators conducting lead-based paint (LBP) abatement must test the wastes using TCLP unless they can apply knowledge to determine characteristics (SEE ALSO: 63 FR 70233, 70241; 12/18/98). If an LBP waste first tests nonhazardous in TCLP due to the masking effect of an iron abrasive but exhibits the characteristic prior to disposal, all hazardous waste regulations apply. LBP abatement wastes that are characteristic for lead may be stabilized on site during accumulation in tanks or containers without a permit.
 
05/29/1991ELECTROPLATING WASTESMemo
 Description: Anode bags are spent materials when removed from electroplating bath for reclamation. Spent anode bags are both reactive (D003) and F007. Bags can be washed in an accumulation tank/container without a permit under Section 262.34. Filter media, and residue from the apparatus used to filter cyanide plating bath are D003 (reactive) and F008, but not F007. A cleaning bath that does not contain cyanides is not F009.
 
04/02/1991CLARIFICATION OF THE APPLICABILITY OF THE OIL AND GAS EXCLUSION TO CRUDE OIL RECLAIMER WASTESMemo
 Description: Wastes derived from the treatment of exempt wastes are generally exempt. If tank bottoms are created during primary field operations, wastes from the recovery of oil from the tank bottoms are exempt. Solvent wastes from cleaning tank trucks associated with oil and gas exploration and production activities are not exempt (SEE ALSO: 58 FR 15284; 3/22/93).
 
01/04/1991SOLID WASTE MANAGEMENT UNIT (SWMU) DETERMINATIONMemo
 Description: Tanks used exclusively to store product are not solid waste management units (SWMUs). Agency may use RCRA Section 3005(c)(3) omnibus provision to address leaks from product tank (SEE ALSO: 50 FR 30798; July 27, 1990).
 
12/27/1990TREATMENT STANDARDS FOR CERTAIN MIXED RADIOACTIVE WASTESMemo
 Description: Merely placing waste in a tank or a container is not macroencapsulation (MACRO). A plastic or steel coating that provides reduction in surface exposure to leaching media, and jackets of inorganic materials are MACRO. Macroencapsulation does not comply with existing land disposal restrictions (LDR) standards for metals. Waste could be macroencapsulated and disposed of via a variance from a treatment standard, no-migration petition, or national capacity variance.
 
09/20/1990PETROLEUM REFINING WASTES AND EXEMPTIONS FOR WWTUSMemo
 Description: INCOMPLETE VERSION IN RCRAONLINE - A tank treating or storing wastewater or a wastewater treatment sludge can be a wastewater treatment unit (WWTU). A tank treating off-site hazardous waste (HW) can be a WWTU if the facility is designated to accept manifested HW. Only tanks and ancillary equipment can be WWTUs. Tank bottoms from fuel storage are CCPs and are not solid waste (SW) when used in fuel. Tank bottoms from refining process units are by-products and are SW when used in fuels. A refinery by-product used in a lubricant is a SW if it is listed (SEE ALSO: 261.4(a)(12) and 261.6(a)(3)).
 
09/20/1990SQG COMPLIANCE WITH TC RULEMemo
 Description: A fuel oil leak from a household tank is exempt household hazardous waste (HHW). EPA does not determine if a particular waste is characteristic. The hazardous waste determination is the generator’s responsibility. SQGs that are newly subject due to the toxicity characteristic (TC) rule had until 11/2/90 to notify the region. SQGs were granted an additional three months to comply with the TC Rule. Spilled petroleum products that are reclaimed from contaminated soil and used to produce fuels are not solid wastes.
 
08/15/1990TANK TREATMENT PROCESSESMemo
 Description: Circuit board manufacturing wastes can be F006 if electroplating is involved. Anodizing is electroplating. Chemical conversion coating is a non-electrical process and is not anodizing or electroplating for F006, F007, F008, F009. Wastewater is defined only for the land disposal restrictions (LDR). Containers and tanks storing hazardous waste (HW) before an off-site shipment are not wastewater treatment units (WWTUs). EPA did not intend to include containers in the definition of ancillary equipment. Generator accumulation starts when the waste first enters the container. HW sludge that is removed from a WWTU is subject to full regulation. A unit can be both a WWTU and an elementary neutralization unit (ENU). A wastewater treatment sludge is anything that precipitates or separates during treatment. F006 may be formed in an exempt unit.
 
08/01/1990TANK TREATMENT SYSTEM OF METAL-RICH RINSEWATERSMemo
 Description: Generators using AMUSON recycling should not count waste that is not stored prior to placement in the treatment tank. The treatment tank may not be regulated if it is a CESQG or a generator accumulation unit. Treated wastewater is generally not a reclaimed product. In certain cases, treated wastewater that is legitimately reused is considered reclaimed and is not a solid waste.
 
06/01/1990APPLICABILITY OF WASTEWATER TREATMENT UNIT EXEMPTIONMemo
 Description: Discussion of wastewater treatment unit (WWTU) applicability to connected tanks located at different properties. Tanks at different facilities that ultimately discharge to the same CWA outfall can all qualify as WWTUs if each facility or tank and effluent is identified or controlled by NPDES permit or other CWA effluent limit.
 
05/01/199040 CFR SECTION 261.4(C): HAZARDOUS WASTES WHICH ARE EXEMPTED FROM CERTAIN REGULATIONSQuestion & Answer
 Description: The exclusion for manufacturing process units, associated non-waste treatment units, or product/raw material storage tanks does not apply to units, such as heat exchangers (K050), that are disassembled and shipped off-site for cleaning.
 
03/01/1990BULKING OR CONTAINERIZING COMPATIBLE HAZARDOUS WASTES FOR TRANSPORTATIONMemo
 Description: Bulking or consolidating hazardous waste (HW) shipments for transport may not be treatment. Mixing different HW for fuel is blending subject to permit. The state or Region decides if it is treatment. Fuel blending is not defined. Discussion of blending versus bulking. Non-generator blending tanks need a permit. Blenders must ensure significant heating value (SUPERSEDED: See RPC# 11/8/94-01).
 
11/30/1989OPERATED TO CONTAIN, DEFINITIONMemo
 Description: Secondary containment should consist of a barrier operated to contain the volume of the largest tank plus precipitation from a 25-year 24-hour storm. The acceptability of secondary containment consisting of operational control such as pumps is site specific.
 
11/17/1989RECYCLING OF LEAD-ACID BATTERIESMemo
 Description: Restricted wastes, like lead-acid batteries, may be stored on the land in tanks or containers (i.e., land disposed) without meeting treatment standards if done solely to accumulate as necessary to facilitate proper recovery, treatment, or disposal. Storage must comply with all storage standards, such as secondary containment. the Battery shell (casing/housing) is the container (SEE ALSO: Part 273).
 
11/01/1989SECONDARY CONTAINMENT SYSTEMS FOR HAZARDOUS WASTE TANKSQuestion & Answer
 Description: Petroleum tanks may be installed within the same secondary containment as hazardous waste tanks. The secondary containment must be large enough to contain 100% of capacity of largest hazardous waste tank.
 
10/01/1989INTEGRITY ASSESSMENT FOR HAZARDOUS WASTE TANKS AND POST-CLOSURE REQUIREMENTSQuestion & Answer
 Description: Tanks without secondary containment must comply with the closure/post closure requirements, even if the tank’s owner and/or operator completes a successful integrity assessment. An owner and/or operator must submit a closure plan for the decontamination of a tank system and a contingency plan for post-closure care. Post-closure care is required only if decontamination cannot be performed.
 
09/26/1989WASTEWATER TREATMENT UNIT EXEMPTIONMemo
 Description: Wastewater treatment units (WWTUs) receiving off-site wastewater meets the WWTU exemption provided prior shipment or treatment does not violate NPDES or pretreatment requirements. Tank storage or treatment prior to shipment is not exempt.
 
07/28/1989TEL GASOLINE SLUDGE DISPOSALMemo
 Description: Leaded tank bottoms from the petroleum refining industry are listed hazardous waste (K052) subject to land disposal restrictions (LDR). Solvent extraction and incineration is best demonstrated available technology (BDAT) for gasoline sludge waste. A temporary variance may be granted.
 
07/21/1989ACETONE AND METHANOL CONTAMINATED WASHWATERSMemo
 Description: When toluene is used as solvent in a production process and then recovered, trace quantities of toluene found in facility's washwaters are not normally F-listed spent solvents and do not render all facility wastewaters and sludges hazardous via the mixture rule. Using pure methanol and acetone as a drying agent to extract water from a product is solvent use, and resulting wastes are F003. If a product contains only F003 solvents before use, wastes from solvent use are F003. F003 that is nonignitable when generated is still F003 until mixed with solid waste and qualifies for 261.3(a)(2)(iii) mixture rule exemption (SEE ALSO: 66 FR 27266; 5/16/01). If a tanker truck holding P- and U-listed hazardous waste is rendered empty according to 261.7 (contents removed using "reasonable" means and less than one inch or 0.3% of tanker volume remains), water from subsequent rinsing is not regulated, even if it contains traces of P- or U-listed chemicals.
 
06/26/1989MIXED WASTE REGULATION - RCRA REQUIREMENTS VS. NRC REQUIREMENTSMemo
 Description: Activities that do not require a permit include: recycling, resource recovery, totally enclosed treatment, and treatment in a generator’s accumulation tank. EPA is not planning to modify storage rules to allow generators to hold radioactive mixed waste on-site for radionuclide decay beyond 90 days without a permit (SEE ALSO: 64 FR 63464; November 12, 1999). EPA and the Nuclear Regulatory Commission (NRC) are developing guidance to integrate regulations on radioactive mixed waste storage. EPA and the NRC agree on dual manifesting of mixed waste. Hazardous waste can be shipped to a designated facility in a state that does not regulate that waste as hazardous. EPA does not require a transporters to obtain permits, but States may do so. States may list used oil as hazardous waste.
 
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.
 
03/27/1989STORAGE PERMIT FOR FACILITIES INVOLVED IN HAZARDOUS WASTE RECYCLINGMemo
 Description: Hazardous waste fuel blending tanks are subject to storage regulations (not exempt recycling units). Federal regulations do not specify an allowable holding time before off-loading a shipment of hazardous waste into the recycling process. Some States may allow up to 24 hours before a storage permit is required.
 
03/20/1989PERMIT REQUIREMENTS FOR ZERO WASTEWATER TREATMENT SYSTEMMemo
 Description: A "zero discharge" wastewater system must have NPDES permit, applicable effluent guideline, or pretreatment standard specifying zero discharge to qualify as wastewater treatment unit (WWTU). A zero discharge system returning all treated water to production avoids CWA rules but does not automatically qualify for the totally enclosed treatment unit (TETU) exemption. A wastewater treatment system using open tanks and not restricting escape of contaminant to air is not a TETU. Illegal discharge of hazardous waste to river may be "subject to" CWA and eligible for industrial discharge exclusion, although discharge is a CWA violation subject to EPA enforcement action.
 
03/14/1989SECONDARY CONTAINMENT FOR EXISTING HAZARDOUS WASTE TANK SYSTEMSMemo
 Description: Secondary containment is a component of a tank system. A new secondary containment system for an existing tank system must be certified. A certified written assessment should provide information to the permit writer and enforcement official to evaluate the basis for the certifier’s assessment.
 
03/13/1989APPLICABILITY OF PERMITTING REQUIREMENTS TO SOLVENT RECYCLERSMemo
 Description: The direct transfer of solvents from transportation tanks into distillation equipment does not require a storage permit.
 
02/01/1989COKE AND COAL TAR RECYCLABLE MATERIAL REQUIREMENTSQuestion & Answer
 Description: Decanter tank tar sludge from coking operations (K087) that is blended with product creosote for use as a fuel in steel production does not meet the 261.6(a)(3)(vii) exclusion. The exclusion applies only to coke and coal tar fuels derived from K087. Includes a detailed explanation of the exclusion (SUPERSEDED: See 56 FR 7203; 2/21/91, and 261.4(a)(10)).
 
01/09/1989STANDARDS FOR SECONDARY CONTAINMENT OF HAZARDOUS WASTE TANK SYSTEMSMemo
 Description: A secondary containment system to which coating or lining is applied must be certified. The coating or liner installed with a new tank system or as secondary containment requires certification. Where certification is not required, a statement from the manufacturer or the installer should be in a file.
 
01/03/1989REGULATION OF HAZARDOUS WASTE TRANSFER OPERATIONSMemo
 Description: Blending and feed storage tanks may be useful in establishing a uniform feed rate. However, the trial burn should determine if a facility can comply with the emissions performance standards without a feed storage tank.
 
12/12/1988SECONDARY CONTAINMENT SYSTEMS CERTIFICATIONMemo
 Description: An independent, qualified, registered, professional engineer must certify a new tank system and secondary containment. A secondary containment system is not required to account for rare catastrophic failures. There is no defined quantity of released waste specified for automatic shut-off devices. The acceptance of a shut-off device is determined by site. A pressurized pipe means aboveground piping through which waste is transferred via pump, but not by suction pump.
 
10/27/1988PESTICIDE RINSEATE TREATMENT/RECYCLING SYSTEMMemo
 Description: Tanks with no discharge because effluent is recycled or otherwise handled cannot be wastewater treatment units (WWTU). Tanks that have eliminated discharge of effluent as direct result of CWA rules and limits (zero dischargers) can qualify as WWTUs. Reclaimed wastewaters are generally not products. In certain cases, treated wastewater that is legitimately reused is considered "reclaimed" and loses its solid waste status. Listed rinsewater destined for filtering and reuse is a spent material and a solid waste prior to reclamation. Rinsing nonempty containers that held P-listed or U-listed pesticide CCPs renders rinsate listed hazardous waste.
 
10/11/1988CONTRACTORS AND GENERATOR RESPONSIBILTIESMemo
 Description: Waste produced at sea is subject to regulation as soon as it is produced unless it is in an exempt unit such as product or raw material storage tank, product or raw material tank vehicle or vessel, or manufacturing process unit (SEE ALSO: Federal Facility Compliance Act (FFCA) section 3022)). Under EPA's cogenerator policy, either Navy personnel or contractors meeting generator definition may perform Part 262 duties. A contractor may sign a manifest certification on behalf of a generator, such as the U.S. Navy, if properly authorized.
 
10/01/1988CHANGES DURING INTERIM STATUS (REVISES SEPTEMBER 1988 MRQ)Question & Answer
 Description: The cost of adding secondary containment to a tank system to comply with 265.193 is not included when calculating the 50% change to interim status reconstruction limit under changes during interim status (SEE ALSO: this guidance supersedes RPC# 9/1/88-01).
 
10/01/1988DEFINITION OF WASTEWATER TREATMENT UNITQuestion & Answer
 Description: The removal of wastewater treatment sludges or tank bottoms for off-site disposal does not disqualify tanks from being wastewater treatment units (WWTUs).
 
09/02/1988SUMMARY OF ASSISTANCE BRANCH PERMITTING COMMENTSMemo
 Description: Aboveground bolted flange joints that are inspected daily do not need secondary containment. Joints where waste may contact the thread must meet the secondary containment requirement for tank ancillary equipment. A trench below tank waste lines may qualify as secondary containment if it is sized to contain a release and if the trench is dry so that leaks can be detected. Discusses the status of new tank systems at facilities permitted between 7/14/86 and 1/12/87. To meet the definition of a boiler, the combustion chamber and energy recovery section must be of integral design. A unit with a “post-combustion” chamber between the combustion and energy recovery sections is not a boiler. A unit with a combustion section connected to an energy recovery unit by a duct and a control system is not a boiler. A unit with innovative insulation installation does not qualify as boiler under a variance petition if the insulation does not provide significantly better performance. The determination of boiler efficiency should be conducted under controlled conditions following a method specified by the American Society of Mechanical Engineers. Thermal relief vents can be used in the design of a new incinerator, but a permit should require backup systems to minimize their use. Addresses the application of the minimum technology requirements (3004(o)) to the vertical and lateral expansions of surface impoundments and landfills. The minimum technology waiver petition was granted due to alternate design and operational factors. The 3004(o)(2) waiver petition that would prevent the migration of contaminated groundwater beyond the waste management area (e.g. surface impoundment) is inadequate because it does not prevent all groundwater contamination. Incinerators may be eligible for research, development, and demonstration (RDD) permits. Provides guidance on the duration of Research, Development, and Demonstration (RDD) permits beyond a calendar year and criteria for renewing RDD permits. Discusses the applicability of the new tank system regulations in authorized v. unauthorized states. Includes guidance on the selection of principal organic hazardous constituent (POHCs) and the use of surrogate v. actual wastes during the incinerator trial burn. The actual waste can be spiked during the trial burn to raise principal organic hazardous constituent levels. Addresses the sampling frequency during a trial burn. The mass feed rate of a principal organic hazardous constituent (POHC) input used for destruction and removal efficiency (DRE) calculations must equal mass feed rate in the wastestream only. When sampling for particulates and semi-volatile POHCs during an incinerator trial burn, two separate Modified Method 5 (MM5) trains should be used. Only one confirmatory sampling event is necessary to trigger compliance monitoring. Discusses the disposal of purged water generated during groundwater sampling and analysis. An owner of a landfill or surface impoundment submitting a no migration waiver petition must use a worst-case soil permeability factor in groundwater modeling. The constituent concentration, retardation factors, and constituent half-life must be evaluated when developing a model for a no migration waiver petition for a surface impoundment or a landfill (3004(o)(2)). The owner of a site with a complex hydrogeology should use a 2 or 3-dimensional model to support a no migration demonstration. Provides criteria for evaluating landfill composite bottom liner equivalency. Addresses the evaluation of a final cover slope using a soil loss equation. EPA recommends the use of glass vessels when performing compatibility testing on a high-density polyethylene (HDPE) liner. Scarifying and remolding do not meet the minimum technological requirements for a landfill secondary soil liner. A contingency plan must designate a sufficient number of emergency coordinators to provide 24-hour and vacation coverage. The federal regulations require a compressive strength test for stabilized wastes (going to a landfill) that pass the paint filter test only if true chemical stabilization has not occurred.
 
07/29/1988CEMENT KILN DUST WASTEMemo
 Description: Cement kiln dust (CKD) is not a hazardous waste (SEE ALSO: 60 FR 7366; 2/7/95). A mixture of exempt cement kiln dust with corrosive liquid (D002) will result in a nonhazardous waste if the mixture no longer exhibits any characteristic (SEE ALSO 261.3(d)(1)). Mixing is considered treatment. No permit is required for treatment performed in generator accumulation tanks subject to 262.34.
 
07/01/1988TANK REPLACEMENTQuestion & Answer
 Description: The replacement of a hazardous waste storage tank would not constitute final closure. There is no notification for the partial closure of a tank, container, or incinerator. While not specifically required, the tank and equipment should be decontaminated and the region or state implementing agency should be notified.
 
07/01/1988WASTEWATER TREATMENT UNIT/GENERATOR ACCUMULATION TANKQuestion & Answer
 Description: Wastewater treatment units (WWTUs) must be dedicated for use with an on-site wastewater treatment facility. Tanks occasionally or routinely used to store or treat wastewaters before off-site transfers are not WWTUs.
 
06/24/1988DRUM SHREDDER REGULATIONMemo
 Description: A drum shredder that processes containers filled with hazardous waste is a miscellaneous unit requiring a permit. Certain tank requirements may be appropriate for inclusion in the Subpart X permit.
 
06/09/1988PUMP EXEMPTION FROM SECONDARY CONTAINMENTMemo
 Description: A Barrier Fluid Pump Sealing System may be similar to sealless pumps and may qualify for an exemption from the secondary containment requirement for tank ancillary equipment, but a site-specific determination is needed.
 
06/03/1988CONTAINMENT AND DETECTION OF RELEASE FROM HAZARDOUS STORAGE TANK SYSTEMSMemo
 Description: Daily visual monitoring is acceptable for a hazardous waste tank that is elevated above the ground. A grooved concrete pedestal is acceptable leak detection. A secondary containment system must be able to contain 100 percent of the largest hazardous waste tank plus rain from a 25-year 24-hour storm.
 
06/01/1988HAZARDOUS WASTE TANKSQuestion & Answer
 Description: The age of a tank for the purposes of release detection requirements is based on when the tank was first installed, not when the tank was first used for hazardous waste storage.
 
06/01/1988HAZARDOUS WASTE TANKS - INSTALLATION/CERTIFICATION OF SECONDARY CONTAINMENTQuestion & Answer
 Description: Minor or routine replacements of tank system components do not need recertification by a professional engineer or an independent qualified installation inspector. The Agency intends this requirement to apply only to replacement components affecting the tanks structural integrity (i.e. new tanks, secondary containment, or extensive piping). Which new tank components need certification is a site-specific determination.
 
06/01/1988HAZARDOUS WASTE TANKS/CONTAINERS - CAPACITY OF SECONDARY CONTAINMENTQuestion & Answer
 Description: A vault containing both tanks and containers must be able to contain 100% of the largest tank. If that volume is greater than 10% of the containers’ volume, then no additional capacity is needed. 110% capacity is not required.
 
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.
 
05/01/1988HAZARDOUS WASTE TANK - LEAK DETECTIONQuestion & Answer
 Description: Tanks elevated above a concrete pad may use visual inspection for leak detection. Tanks resting on a concrete pad may use visual inspection if the pad is impermeable and sloped. A double bottomed tank may have a leak detection system installed in the interstitial space. A vaulted tank with leak detection within the vault walls is sufficient.
 
05/01/1988HAZARDOUS WASTE TANKS - EXISTING VS. NEW TANKQuestion & Answer
 Description: A tank installed in an existing hazardous waste sump in order to comply with the secondary containment requirements for tanks is a new tank and must be installed in compliance with the new tank requirements. A sump serving as secondary containment must have leak detection and meet all the applicable technical requirements.
 
04/29/1988ELEMENTARY NEUTRALIZATION EXEMPTIONMemo
 Description: Sumps, as defined in 260.10, are tanks. A neutralization sump and ancillary equipment handling corrosive-only wastewater qualify for the elementary neutralization unit (ENU) exemption.
 
04/19/1988CALL-IN OF STORAGE AND TREATMENT APPLICATIONSMemo
 Description: Pursuant to 3005(c)(2)(C), interim status treatment and storage facilities that were in existence on 11/8/84 must submit their Part B permit applications by 11/8/88, or their interim status will terminate on 11/8/92. A facility with only tanks, containers, or incinerators must submit a closure plan 45 days prior to the date that closure will begin.
 
04/19/1988CALL-IN OF STORAGE AND TREATMENT APPLICATIONS PRIOR TO 11/08/88 DEADLINEMemo
 Description: Pursuant to 3005(c)(2)(C), interim status treatment and storage facilities that were in existence on 11/8/84 must submit their Part B permit applications by 11/8/88, or their interim status will terminate on 11/8/92. A facility with only tanks, containers, or incinerators must submit a closure plan 45 days prior to the date that closure will begin.
 
04/01/1988POST CLOSURE PLANS FOR HAZARDOUS WASTE TANKSQuestion & Answer
 Description: A permit can shield a tank owner/operator from the requirement to prepare a contingent post-closure plan. Contingent post-closure plans are only required for tanks without secondary containment. The region or state implementing agency may reopen and modify a permit issued before the tank regulations were revised (7/14/86) to require a plan if cause exists.
 
04/01/1988SECONDARY CONTAINMENT FOR HAZARDOUS WASTE TANKSQuestion & Answer
 Description: Double walled tanks do not need to be able to contain 100% of the waste in the system’s interstitial void.
 
03/16/1988CONCRETE LINERS FOR HAZARDOUS WASTE TANK SYSTEMSMemo
 Description: A concrete structure may be used as secondary containment for tanks when provided with an impermeable coating or a lining that is compatible with the hazardous waste. There is no permeability standard available for a concrete structure. Determine this requirement by site.
 
03/08/1988PROCESS WASTEWATER FROM METAL DEGREASING OPERATIONSMemo
 Description: Solvent-contaminated water in a rinse tank is a process waste, not a spent solvent, and is hazardous only if it exhibits a hazardous characteristic. Includes a comparison of the mixture rule exemption for solvent-water and the land disposal national capacity variance for wastes with less than 1% F001-F005 solvents.
 
03/07/1988SLUDGE DEHYDRATION EQUIPMENT THAT IS PART OF A WASTEWATER TREATMENT FACILITYMemo
 Description: The wastewater treatment unit (WWTU) exclusion does not apply to conventional incinerators even when they are part of a wastewater treatment system. Sludge dehydration equipment (i.e., sludge dryers) qualifies for the WWTU exclusion, provided the equipment meets the definition of a WWTU and is used to evaporate water from sludge. Most sludge dryers meet the definition of a tank. Sludge dryers that are not eligible for the WWTU exclusion are subject to either 265 Subpart P or 264 Subpart X.
 
02/08/1988TANK SYSTEMS SINCE CHANGES IN DEFINITION OF HAZARDOUS WASTE, CLASSIFICATION OFMemo
 Description: A tank system in existence prior to its contained material becoming hazardous waste is an existing tank system. A tank system not used to store the material prior to its becoming a hazardous waste is new tank system.
 
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.
 
02/01/1988BLENDING OF HAZARDOUS WASTE FUEL BURNED IN CEMENT KILNSQuestion & Answer
 Description: Tanks in which hazardous waste fuels are blended are regulated by 264 Subpart J/265 Subpart J regardless of the type of unit in which the waste will be burned. Blending tanks are subject to the same regulations as storage tanks (266.31(c) cement kiln exclusion SUPERSEDED: See 266 Subpart H).
 
01/28/1988PERMIT REQUIREMENTS FOR REMOTE SECONDARY CONTAINMENT AREA FOR DIRECT OFFLOADING OF HAZARDOUS WASTE-DERIVED FUEL INTO A CEMENT KILNMemo
 Description: Primary containment sumps designed to collect and transport routine and systematic discharges of hazardous waste are subject to the tank standards. Secondary containment sumps are exempt from the secondary containment requirement. Temporary tanks used for immediate response are exempt.
 
01/27/1988HAZARDOUS WASTE TANK SYSTEM STANDARDS TO ANCILLARY EQUIPMENT AND EXEMPTED ELEMENTARY NEUTRALIZATION SYSTEMSMemo
 Description: The hazardous waste tank standards do not apply to ancillary equipment associated with non-regulated units, such as elementary neutralization units (ENUs). An authorized state program must be as stringent as the federal program.
 
01/01/1988“LAB PACKS” AT GENERATOR SITESQuestion & Answer
 Description: A service company may act on behalf of a generator and re-package waste into larger containers (lab packs) with absorbents without a permit. Generators may treat in accumulation tanks or containers provided the treatment is not thermal treatment or incineration. The addition of absorbents to waste is exempt from permitting.
 
12/21/1987WASTEWATER TREATMENT AND ELEMENTARY NEUTRALIZATION UNITS EXEMPTIONMemo
 Description: Provides a clarification of wastewater treatment facility. A facility must be on site and have an NPDES permit or discharge to a POTW. The means of conveyance between units does not matter. Wastewater treatment units (WWTUs) can receive wastewater from off site and remain exempt. A tank system used to manage wastewater prior to an off-site transfer is not covered by the exemption. Discusses zero-discharge NPDES permits and wastewater treatment units (WWTUs).
 
12/15/1987QUALIFICATION OF AN ENGINEER FROM THE CORPS OF ENGINEERS AS INDEPENDENT WITH RESPECT TO AN ARMY FACILITYMemo
 Description: An engineer in the Army Corps of Engineers meets the criteria for an independent, qualified, professional engineer for assessments, installation, and tests of tank systems at Department of Army facilities.
 
10/16/1987OPERATING DAY DEFINED FOR TANKS AND SURFACE IMPOUNDMENTSMemo
 Description: Once each operating day for tanks means once each day that manufacturing operations are conducted. Operating day for surface impoundments means each day waste is placed in surface impoundments. Leak detection and visual inspection are required whether or not manufacturing operations occur.
 
10/02/1987Questions and Answers Regarding the July 14, 1986, Hazardous Waste Tank System Regulatory AmendmentsPublication
 Description: This document answers questions concerning compliance or implementation of Part 264/265, Subpart J requirements for hazardous waste tanks. Topics include the applicability of requirements, integrity assessments, design and operation requirements, secondary containment, and closure and postclosure care.
 
10/01/1987SEALLESS VALVE DEFINITIONMemo
 Description: There is no definition of a sealless valve. A sealless valve refers to a valve whose design prevents the leakage of liquids from the valve stem or to valves designed to provide containment of media within the valve body.
 
09/23/1987SECONDARY CONTAINMENT REQUIREMENTS FOR ABOVE GROUND WELDED FLANGES AND SEALLESS VALVESMemo
 Description: Aboveground threaded connections associated with a tank require secondary containment. Aboveground welded connections and sealless valves do not require secondary containment but need daily inspection. Welded flanges include slip-on, socket, lap joint, and welded neck flanges. There is no definition of a sealless valve.
 
09/11/1987SECONDARY CONTAINMENT FOR HAZARDOUS WASTE TANKSMemo
 Description: Integrity assessments for existing hazardous waste tanks are not required in unauthorized states provided secondary containment is installed by 1/12/88.
 
08/19/1987MIXTURES OF LISTED AND CHARACTERISTIC WASTESMemo
 Description: Combining different hazardous waste in the same tank truck for transport is not regulated as hazardous waste treatment. The optional boxes on the manifest that are left blank are for use by states. EPA does not require waste codes on the manifest. Each waste in a waste mixture must be described on the manifest (currently under EPA review).
 
08/03/1987PRESSURIZED PIPING SYSTEMS WITH AUTOMATIC SHUT-OFF DEVICESMemo
 Description: A pressurized piping system with an automatic shut-off device is exempt from the secondary containment requirement for tank ancillary equipment. The exemption applies in the absence of welded flanges, welded joints, welded connections, sealless valves, and sealless or magnetic coupling pumps.
 
08/01/1987CHANGES AT INTERIM STATUS TANK FACILITIESQuestion & Answer
 Description: Upgrading an interim status tank to meet the secondary containment requirements constitutes a change during interim status and requires the submission of a revised Part A prior to the change. The cost of retrofitting the tank may exceed the 50% reconstruction limit.
 
08/01/1987TANK INTEGRITY ASSESSMENTSQuestion & Answer
 Description: Integrity assessments are not required for hazardous waste tanks that have secondary containment. Aboveground piping does not need secondary containment if it is visually inspected daily.
 
07/29/1987TRD INDICATING THAT ETHANOL AND STAINLESS STEEL ARE COMPATIBLEMemo
 Description: Ethanol is compatible with stainless steel equipment used for tanks and containers.
 
07/20/1987INDEPENDENT ENGINEER QUALIFICATIONS AND SCOPE OF THE TERMMemo
 Description: An independent qualified registered professional engineer is required to avoid the obligation or pressure to certify tank condition. There is no requirement for the engineer to have an in-state license, but it is desirable. A welded flange means a flange where a welded connection is between a pipe and a flange.
 
07/09/1987SECONDARY CONTAINMENT FOR PIPING SYSTEMSMemo
 Description: Secondary containment with leak detection is required for a tank’s underground piping. Aboveground piping must be inspected daily. Secondary containment is required for all threaded connections and packing-type pump seals. A welded flange means a flange joined to a pipe by a welded connection.
 
07/01/1987ON-SITE TREATMENT BY GENERATORS UNDER 262.34Memo
 Description: Generators can treat in accumulation tanks or containers without a permit provided the treatment occurs in units complying with Subparts I or J of 265. Open burning in drums or tanks is not allowed under 262.34. Subparts I and J limit the type of treatment that can occur. Burning in open drums is not allowed because open burning (defined in 260.10) is a method of disposal. Open burning (thermal treatment) of waste, except for explosives, is prohibited under 265.382.
 
07/01/1987SECONDARY CONTAINMENT FOR TANKSQuestion & Answer
 Description: A vault used as secondary containment must be designed to contain 100 percent of the largest HAZARDOUS WASTE tank.
 
06/25/1987TANKS AND ANCILLARY EQUIPMENT DESIGNMemo
 Description: Dikes must be compatible with the waste in the tank and must prevent the migration of moisture. Large sudden failures must be accounted for in the contingency plan. Tightness testing is needed for welded pipes to flange systems. Flanges must be inspected for leaks daily. Threaded joint systems require secondary containment.
 
06/19/1987REGULATORY STATUS OF VARIOUS TYPES OF PENTACHLOROPHENOL WASTESMemo
 Description: F021 is for pentachlorophenol (PCP) manufacturing wastes, not for wood-preserving wastes like dip tank bottom sludge or discarded pentachlorophenol (PCP)-treated wood (SEE ALSO: F032). F027 is for unused PCP wood preservatives, not for used formulations which come in contact with wood that remains in process vessel or dip tank after treatment or contained-in treated wood (posts, poles, railroad ties); K001 for treatment sludges from wastewater from PCP or creosote wood preserving, not dip tank bottom sludge from PCP wood preserving facilities (SEE ALSO: 261.24 and 261.31)
 
06/08/1987SURFACE IMPOUNDMENT RETROFITTING WAIVER REQUEST (UNION CARBIDE)Memo
 Description: The most recent, best available data should be used to determine compliance with CWA for purposes of a waiver from the minimum technological requirements for a surface impoundment under 3005(j)(3). A full Part 261 Appendix VIII analysis of groundwater is not needed for a waiver under 3005(j)(3)(C)(ii).
 
06/01/1987MOBILE WASTEWATER TREATMENT UNITSQuestion & Answer
 Description: A mobile treatment unit can be a tank. A mobile tank can be used as a part of an exempt wastewater treatment unit (WWTU). provided it is stationary when in operation.
 
05/29/1987TANK SYSTEM DESIGN-SECONDARY CONTAINMENTMemo
 Description: A new tank system and its components must have secondary containment, be compatible with the waste, protect against corrosion, and withstand vehicular overhead stress. A tank system must be installed properly and tested for tightness before it is put into service.
 
05/01/1987APPLICABILITY OF CONTINGENT CLOSURE AND POST-CLOSURE PLANSQuestion & Answer
 Description: Contingent closure and post-closure plans are required for all tanks that do no have secondary containment until secondary containment meeting 264.193 or 265.193 is installed.
 
05/01/1987DEFINITION OF SOLID WASTEQuestion & Answer
 Description: Waste sodium hydroxide (NaOH) that is used as a substitute for a commercial product in a tank clean-out is not a solid waste if it would function as a product in normal commercial use, unless it is speculatively accumulated. A generator may increase the effectiveness of a “product” by adding additional NaOH.
 
05/01/1987DISPOSAL PRIOR TO NOVEMBER 19, 1980Question & Answer
 Description: A tank closed in accordance with existing industry practices in 1977 is an inactive disposal facility and is not subject to RCRA Subtitle C, unless the waste is subsequently managed in a manner that constitutes treatment, storage, or disposal. EPA could enforce under 7003 or CERCLA.
 
05/01/1987EVAPORATOR USED TO REMOVE WATER FROM HAZARDOUS WASTEMemo
 Description: Evaporation meets the definition of treatment. Since an evaporator could release solid or hazardous constituents or water vapor into the air, the unit is not a totally enclosed treatment unit (TETU). An evaporator meets the definition of a thermal treatment unit, and if it meets the definition of a tank, generator treatment in the accumulation unit is exempt from permitting (SUPERSEDED, no thermal treatment in generator units: see RPC# 10/17/94-01).
 
05/01/1987HAZARDOUS WASTE TANKSQuestion & Answer
 Description: An existing tank that is moved and reinstalled is subject to new tank requirements, including secondary containment.
 
05/01/1987INSPECTION REQUIREMENTS FOR HAZARDOUS WASTE TANKSQuestion & Answer
 Description: Only the accessible and visible aboveground portions of a tank must be inspected each operating day. Data gathered from leak detection equipment must also be inspected each operating day.
 
04/20/1987TEMPORARY TANK SYSTEMS USED IN RESPONSE TO EMERGENCIES, REQUIREMENTS FORMemo
 Description: Temporary tanks are used for responses to unexpected occurrences are covered under emergency permit provisions. A secondary containment system does not need secondary containment. A stand-by tank is not a temporary tank.
 
04/15/1987SPENT AND RECLAIMED SOLVENTS, BLENDING OF RECLAIMED XYLENEMemo
 Description: Blending recycled solvents to produce marketable solvent is not regulated. A solvent and chemical mixture from a blending error that is sold as a fuel becomes a solid and hazardous waste when it is determined that it is not suitable for solvent use. Hazardous waste fuel blending tanks are regulated.
 
04/09/1987F027 LISTING - USED AND UNUSED FORMULATIONS IN WOOD PRESERVINGMemo
 Description: In regards to the F027 listing, the word 'used' includes formulations that have contacted wood or which remain in a dip or process tank after preservation. The formulations do not have to be spent to be classified as used; even after one treatment, a formulation is considered to be used. Dipping a piece of wood in a container of unused preservative in order to claim it as used is sham use.
 
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.
 
04/02/1987THREE AND FOUR-SIDED, FLOORED STRUCTURES, REGULATORY CLASSIFICATION OFMemo
 Description: Describes a tank as a unit that contains materials and a waste pile as a noncontainerized accumulation of solid, non-flowing hazardous waste. Discusses approaches to address the overlap of the definitions of tank and waste pile and the applicability to 3 and 4-sided floored structures.
 
04/01/1987STORAGE PRIOR TO RECYCLINGQuestion & Answer
 Description: A recycling facility that holds waste in a receiving bin (tank) when a distillation unit is not operating is subject to storage standards. A recycler who uses a receiving bin to convey solvent to a distillation unit is not subject to storage standards provided the tank never holds waste when the unit is not in operation.
 
03/25/1987TREATMENT OF HAZARDOUS WASTE IN GENERATOR'S ACCUMULATION TANKSMemo
 Description: A generator meeting the requirements of 262.34 does not need to obtain a RCRA Subtitle C permit in order to conduct treatment in tank systems.
 
03/04/1987FOUNDRY SANDS RECYCLED AND RETURNED TO THE FOUNDRYMemo
 Description: Foundry sands that are accumulated for 90 days or less in tanks or containers prior to recycling are subject to 262.34. A storage permit is required if the foundry sands are stored on site for greater than 90 days.
 
03/01/1987TANKS HOLDING HAZARDOUS WASTEQuestion & Answer
 Description: Video monitoring could be used to meet the daily inspection and leak detection requirements for tank systems. A system must provide a comparable level of performance to visual inspection and must provide 24-hour leak detection.
 
02/01/1987LAND DISPOSAL RESTRICTIONSQuestion & Answer
 Description: The one-year storage prohibition period for a generator with interim status for storage begins on the date when waste is first placed in the tank or container. An owner/operator bears the burden of proof for storing waste longer than one year. Wastes initially accumulated prior to the land disposal restrictions (LDR) are not subject to storage prohibitions.
 
12/30/1986DRAINS AND TRENCHES ASSOCIATED WITH TANK SYSTEMSMemo
 Description: In-building floor drains and outside-building trenches that are used to transfer hazardous waste to inground storage tanks comprise a tank system that requires secondary containment. Drains and trenches are ancillary equipment. Trenches may also be sumps that require secondary containment.
 
12/22/1986GENERATOR TREATMENT IN ACCUMULATION TANKS AND CONTAINERSMemo
 Description: Generators can treat hazardous waste in accumulation tanks or containers without a permit, provided treatment performed strictly in accordance with 262.34.
 
12/22/1986TREATMENT OF HAZARDOUS WASTE IN A GENERATOR'S ACCUMULATION TANKS AND CONTAINERSMemo
 Description: Generators can treat hazardous waste in accumulation tanks or containers without a permit, provided treatment is performed strictly in accordance with 262.34.
 
12/19/1986TANK SYSTEMS APPLICABLE TO PRODUCTION TANKS DURING CLEANOUT, PROCESS TRANSFER EQUIPMENT, AND HOSE LINESMemo
 Description: A manufacturing process tank cleaned within 90 days after production ceases is not an accumulation tank. Discusses the status of a product hose line used for waste. Reused material from incomplete production is not a solid waste. Process equipment transferring hazardous waste (HW) is part of a HW tank system. Engineer certification for tanks must account for all factors in the regulations.
 
12/05/1986TREATMENT IN ACCUMULATION TANKS AND CONTAINERS ALLOWED FOR ALL GENERATORS SUBJECT TO 262.34Memo
 Description: All generators accumulating waste in compliance with 262.34 may treat waste in on-site tanks and containers.
 
12/01/1986LEAK TESTING FOR EXISTING HAZARDOUS WASTE TANKSQuestion & Answer
 Description: An overview of the leak testing requirements for existing tank systems that do not yet have secondary containment. An existing tank system that has secondary containment is exempt from the sections 264.191 and 265.191 assessment.
 
11/28/1986TANK RULES APPLIED TO WWT UNITS AND DISTRIBUTION SYSTEMSMemo
 Description: A wastewater treatment unit (WWTU) is not subject to permitting. The closed-loop exclusion applies to a reclaimed material returned to the production process, production process is the manufacturing or primary activity. A manhole or sump serving as secondary containment must comply with Subpart J except for section 264.193.
 
11/03/1986FLOATING PLASTIC BALLS USED TO CONTROL VAPORS FROM TANKS CONTAINING LISTED PRODUCTMemo
 Description: Floating hollow plastic balls used to control vapors from industrial process tanks containing product carbon disulfide are hazardous wastes, since carbon disulfide is listed as P022. Cleaning may render the balls nonhazardous.
 
11/01/1986GENERATOR ACCUMULATION AND SECONDARY CONTAINMENTQuestion & Answer
 Description: LQGs are subject to the Part 265 Subpart J tank standards. Existing LQGs are not subject to the tank secondary containment provisions for underground tanks that cannot be entered for inspection until the State adopts the regulations.
 
10/31/1986USED OIL TANK CLASSIFICATIONMemo
 Description: Tanks storing used oil are not subject to the hazardous waste tank standards. An underground tank storing used oil must comply with the Part 280 UST standards.
 
10/01/1986HAZARDOUS WASTE TANKSQuestion & Answer
 Description: Permits only incorporate regulations effective prior to the final administrative disposition of a permit. Regulations that are not yet effective may be added under the omnibus authority. A tank installed between 7/14/86 and the effective date is a new tank. All tanks that meet the definition of a new tank, must follow the new standards.
 
10/01/1986SECONDARY CONTAINMENT VARIANCES FOR TANKSQuestion & Answer
 Description: A technology-based or risk-based variance from the secondary containment standards is available. The technology-based variance is for the alternative design or practice. A risk-based variance is for no present or potential hazard. A risk-based variance is not granted to new underground tank systems.
 
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.
 
08/27/1986SEALED BELLOW VALVES USED IN LIEU OF SECONDARY CONTAINMENT FOR GLOBE VALVESMemo
 Description: Sealed bellow valves on tanks may be used without external secondary containment and without a separate leak detection device. All connections and flanges used in conjunction with valves must be welded.
 
08/19/1986TREATMENT OF HAZARDOUS WASTE IN PIPELINES LEADING TO A WASTEWATER TREATMENT PLANTTREATMENT OF HAZARDOUS WASTE IN PIPELINES LEADING TO A WASTEWATER TREATMENT PLANTMemo
 Description: An elementary neutralization unit (ENU) or wastewater treatment unit (WWTU) can be a series of connected units. A flume, gutter, pipe, or open channel may be defined as a tank. WWTU wastewater is water with few percent contaminants (SUPERSEDED: See RPC# 2/11/91-01, RPC# 6/2/93-04). Pouring characteristic hazardous waste (HW) into an industrial sewer drain pipe where HW mixes with wastewaters is not treatment as the dilution is incidental to the pipe's primary purpose of conveyance (SEE ALSO: 268.3). An open channel in an enclosed building is not a totally enclosed treatment unit (TETU). HW subject to substantive regulation is counted for generator category determination. HW piped directly into an ENU and CWA sewer discharge is not counted. The 261.3(a)(2)(iv) de minimis mixture rule exemption is only for listed HW mixtures, not characteristic mixtures.
 
08/13/1986TANK CONVERSION FROM WASTE STORAGE TO FEEDSTOCK STORAGE - REGULATIONMemo
 Description: A waste storage tank that is closed and converted to product storage is no longer subject to Parts 264 Subpart J/265 Subpart J. A containment structure used to contain a release during an immediate response to a spill is exempt from permitting and the technical standards if the hazardous residue is removed. A release may be subject to section 3004(u) corrective action. Inactive disposal units that are clean closed before 11/19/80 may be subject to sections 3004(u) or 3008(h) corrective action if other hazardous waste management units are currently in operation.
 
08/01/1986HAZARDOUS WASTE TANK REGULATIONSQuestion & Answer
 Description: Existing tanks and components must have secondary containment when they reach 15 years old. The age of piping is independent of the age of a tank for purposes of the secondary containment requirements.
 
08/01/1986HAZARDOUS WASTE TANKS AND GROUND-WATER MONITORINGQuestion & Answer
 Description: The final tank rules do not allow tank owners or operators to use a combination of groundwater monitoring and partial secondary containment. Tanks must have full secondary containment and an interstitial leak detection system.
 
08/01/1986LEAK DETECTION REQUIREMENTS FOR HAZARDOUS WASTE TANKSQuestion & Answer
 Description: Built-in continuous leak detection is required only for double-walled tanks, continuous leak detection may not be feasible or needed for other secondary containment systems. A daily visual inspection is acceptable for aboveground tanks to meet the leak detection requirements.
 
08/01/1986RELEASES FROM 90 DAY ACCUMULATION TANKSQuestion & Answer
 Description: Releases from 90 day accumulation tanks are not normally covered by RCRA sections 3004(u), 3004(v) or 3008(h) corrective action authorities, however, a leak from a generator tank which is not cleaned up may be considered open dumping under RCRA and could be covered by the imminent hazard provision of section 7003.
 
07/25/1986PERMITTING OF TREATMENT ACTIVITIES IN A GENERATOR'S ACCUMULATION TANKS OR CONTAINERSMemo
 Description: All generators accumulating waste in compliance with section 262.34 may treat in on-site tanks and containers. Treatment in other units requires permit. EPA does not distinguish between accumulation for handling other than treatment and accumulation for the sole purpose of treatment.
 
06/17/1986PERMITTING OF TREATMENT ACTIVITIES OCCURRING IN A GENERATOR'S ACCUMULATION TANKS OR CONTAINERSMemo
 Description: Detailed discussion of the EPA policy allowing generators to treat hazardous waste in accumulation tanks or containers without obtaining a permit or interim status (SEE ALSO: 51 FR 10168; 3/24/86). If a facility has interim status, and should withdraw permit application, Region or State will determine residual interim status obligations (e.g., closure requirements).
 
05/01/1986BY-PRODUCT CRUDE OIL TANK BOTTOMSMemo
 Description: Fuels produced at a refinery from crude oil tank bottoms are not solid wastes. Recyclable materials are hazardous waste that are recycled (SEE ALSO: 261.6(a)(3)(iii)). Crude oil tank bottoms are by-products (SEE ALSO: new K169 listing, added 63 FR 42110; 8/6/98). Tank bottoms being refined into fuel are solid wastes, subject to regulation before recycling (SEE ALSO: 261.4(a)(12)).
 
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).
 
04/16/1986ACCUMULATION AND TREATMENT OF WASTES ON-SITE/PERMIT REQUIREMENTSMemo
 Description: A generator who solidifies or fixes hazardous waste in an accumulation tank or container does not need a permit or interim status.
 
04/07/1986ENVIRONMENTAL RELEASES FROM WOOD PRESERVING PLANTSMemo
 Description: A summary of EPA regulations applicable to releases from wood preserving facilities. The wood preserving process wastewater effluent is subject to the CWA (SEE ALSO: 261.4(a)(9)). The storage or mixing tanks, kraft bags can be empty containers under section 261.7. Discusses the applicability of the F020, F021, F026, F027 listings. Dioxin wastes are acutely hazardous and are subject to the 1 kg threshold. Wastewater treatment sludges from creosote and pentachlorophenol (PCP) are K001. An explanation of the closure of units used to treat these process wastewaters. The applicability of the EP (extraction procedure) toxicity characteristic (SUPERSEDED: see 261.24) to wood preserving wastes. A discussion of section 3004(u) and (v) corrective action at wood preserving facilities.
 
04/07/1986WOOD PRESERVING AND SURFACE PROTECTION FACILITIES, CONTROLLING ENVIRONMENTAL RELEASES FROMMemo
 Description: A summary of EPA regulations applicable to releases from wood preserving facilities. The wood preserving process wastewater effluent is subject to the CWA (SEE ALSO: 261.4(a)(9)). The storage or mixing tanks, kraft bags can be empty containers under section 261.7. Discusses the applicability of the F020, F021, F026, F027 listings. Dioxin wastes are acutely hazardous and are subject to the 1 kg threshold. Wastewater treatment sludges from creosote and pentachlorophenol (PCP) are K001. An explanation of the closure of units used to treat these process wastewaters. The applicability of the EP (extraction procedure) toxicity characteristic (SUPERSEDED: see 261.24) to wood preserving wastes. A discussion of section 3004(u) and (v) corrective action at wood preserving facilities.
 
03/26/1986SMALL QUANTITY GENERATOR WASTE STREAMS - TANK RISK ANALYSISMemo
 Description: A discussion of dominant risk constituents from various small quantity generator (SQG) tank wastestreams. The risk associated with waste is summarized by using the dominant risk constituent.
 
02/25/1986TORPEDO PROPULSION UNITS SHIPPED FOR RECYCLING, REGULATION OFMemo
 Description: Metal torpedo components which must be decontaminated before reuse are not exempt under 261.2(e). Components are scrap metal and are exempt when reclaimed. A sump defined as a tank can be a wastewater treatment unit (WWTU). Hazardous waste (HW) surface impoundments are not WWTUs. If it is storing HW prior to neutralization and is not part of WWTU or other exempt unit, a sump is subject to 262.34 or Parts 264/Part 265.
 
02/11/1986TOTALLY ENCLOSED TREATMENT EXEMPTION FOR SCRAP METAL RECYCLERMemo
 Description: A tank treating emission control dust at a scrap metal recycler is not a totally enclosed treatment unit (TETU) since the treatment occurs downstream of the baghouse, and the baghouse is not part of the production process. Characteristic emission control dust is a sludge, and is not a solid waste if recycled. If the dust is returned to cupola for metal recovery, the process is exempt reuse.
 
01/07/1986EMPTY CONTAINER RULE APPLIED TO TANKER OR VACUUM TRUCKSMemo
 Description: The section 261.7 definition of “empty” applies to tanker vehicles/trucks as well as containers. Trucks emptied by normal means and with less than one inch or equivalent volume remaining are empty.
 
01/02/1986PERMIT-EXEMPT STATUS OF SLUDGE DRYERS ADDED TO WASTEWATER TREATMENT UNITSMemo
 Description: A sludge dryer that meets the wastewater treatment unit (WWTU) definition is exempt from permitting. Sludge drying is a treatment. Presses, filters, and sumps may be tanks under the definition of a WWTU. Tanks not discharging under sections 402 or 307(b) of CWA that are part of the wastewater treatment system meet the exemption. WWTU tanks may volatilize their contents and retain the exemption. Sludge dryers can be used to meet the section 3002(b) waste minimization requirements. While the WWTU is exempt from permitting, hazardous waste sludge removed from the unit is subject to regulation.
 
01/02/1986SLUDGE DRYER ADDED TO WASTEWATER TREATMENT UNIT-EFFECT ON WWTU EXEMPTIONMemo
 Description: The addition of sludge dryer to a wastewater treatment unit (WWTU) does not jeopardize the unit exemption as long as the sludge dryer meets the unit definition. Tanks include presses, filters, sumps and processing equipment. WWTU include covers, sludge digesters, thickeners and dryers. A unit meets the WWTU definition even if the discharge is not subject to the CWA. Other tanks in the system must have discharge subject to the CWA. Tanks that volatilize contents can be exempt as a WWTU. Sludge removed from the unit is subject to RCRA.
 
12/24/1985RD&D PERMIT FOR A SLUDGE DRYING PROCESS IN A WASTEWATER SYSTEMMemo
 Description: For wastewater treatment unit (WWTU) exemption, tanks can include sumps, presses, filters, sludge dryers, or other equipment. A sludge dryer can be an exempt WWTU, although the hazardous waste sludges removed from dryer are subject to full regulation.
 
12/13/1985PESTICIDE APPLICATOR WASHING RINSE WATERMemo
 Description: Airplane washwater is not listed hazardous waste via the mixture rule because the pesticide residue on the aircraft is used and not a discarded CCP. The washwater may be characteristic. Pesticide residue remaining in spray tanks has not been used and is a CCP.
 
12/12/1985EMPTY TANK CARS THAT CONTAINED COMMERCIAL CHEMICAL PRODUCTMemo
 Description: Tank cars are containers. Residues rinsed from empty tank cars are not hazardous waste. Rinsewaters are exempt unless characteristic. (SEE ALSO: RPC# 4/12/04-02)
 
12/03/1985REQUIREMENTS FOR CHANGING STATUS OF A TANK FROM TSD TO GENERATOR ACCUMULATIONMemo
 Description: A generator who is also an operator of a TSDF can convert an interim status tank or container to a generator accumulation unit under 262.34. The enforcement agency will determine applicable closure requirements. If a Part B was submitted, the applicant should notify the Region of the change.
 
12/01/1985BURNING AND BLENDING AND INTERIM STATUSQuestion & Answer
 Description: A facility that has existing tanks but is not storing hazardous waste on the effective date of the 266 Subpart D regulations may qualify for interim status if it has objective evidence that indicates the intent to begin storage within a reasonable time. The facility needs interim status or a permit to store hazardous waste fuel on-site prior to burning in a cement kiln. To qualify for interim status, a facility must be in existence, the owner or operator must obtain an EPA ID number, and they must submit a Part A application. Fuel is regulated when it is blended.
 
09/26/1985CHLORINATED DIOXIN WASTES (F023)Memo
 Description: Mixing and formulating tank wastes generated in tanks that were used in the past to manufacture chemicals derived from 2, 4, 5-trichlorophenol meet the F023 listing. If the company replaces mixing tanks, any subsequent waste generated would not be F023, or, the company could submit a delisting petition showing dioxins and furans are below levels of concern.
 
08/13/1985REGULATORY STATUS OF SOLDER DROSS WHEN SMELTED FOR LEAD RECOVERYMemo
 Description: Solder dross is a by-product. An unlisted (characteristic) by-product is not a solid waste when it is reclaimed. Discussion of spent material versus by-product. Spent materials include spent solvents, acids, pickle liquor, catalysts, and lead-acid batteries (battery). By-products include distillation residues, slags, dross, and tank bottoms (SEE ALSO: RPC# 8/28/92-01).
 
08/01/1985CORRECTIVE ACTION FOR CONTINUING RELEASES (3004(U))Question & Answer
 Description: Sumps made of nonearthen materials are tanks. Sumps can be used to accumulate hazardous waste for 90 days or less without permit. The TSDF owner or operator must include information on all solid waste management units (SWMUs), including sumps, in a Part B permit application under 3004(u) corrective action.
 
04/01/1985WASTEWATER TREATMENT UNIT EXEMPTIONMemo
 Description: A tank holding but not treating hazardous waste (HW) prior to an off-site transfer is not a wastewater treatment unit (WWTU) but could be a generator accumulation unit. An off-site WWTU can only receive HW if it is a designated facility (permitted or interim status facility) (SUPERSEDED: See RPC# 3/26/98-01). The WWTU exemption does not attach to waste removed from the unit.
 
12/26/1984REQUEST FOR GUIDANCE/CLARIFICATION OF WASTEWATER TREATMENT UNIT DEFINITIONMemo
 Description: The wastewater treatment unit (WWTU) definition does not require tanks at a facility to be connected. Wastewater can be piped, trucked, otherwise conveyed between components of WWTU’s.
 
12/24/1984WASTEWATER TREATMENT UNIT EXEMPTION/DEFINITIONMemo
 Description: A wastewater treatment unit (WWTU) must be a tank receiving influent hazardous wastewater and be part of a facility subject to CWA standards. Components of units at a facility do not have to be connected. Wastewater can be piped, trucked, or otherwise conveyed between WWTUs.
 
11/28/1984TANK CARS AND DRUMS, DEFINITION OF EMPTYMemo
 Description: A container is not "empty" unless any and all industry practices normally used to achieve maximum possible removal are used. Tank cars qualify as containers.
 
11/01/1984RECIRCULATING TANK FEEDS CAUSTIC TO INCINERATOR SCRUBBERQuestion & Answer
 Description: A recirculating tank that receives caustic from an incinerator does not qualify for the 261.4(c) product storage tank exclusion. The tank may qualify as a generator accumulation tank.
 
09/10/1984WASTEWATER TREATMENT UNIT EXEMPTIONMemo
 Description: The states or Regions determine the applicability of the wastewater treatment unit (WWTU) exemption to a leachate treatment tank. There is no EPA definition of wastewater for purposes of WWTU exemption (SEE ALSO: RPC# 2/11/91-01; RPC# 6/2/93-04).
 
09/07/1984WASTEWATER TREATMENT UNIT EXEMPTIONMemo
 Description: The states or Regions determine the applicability of the wastewater treatment unit (WWTU) exemption to a leachate treatment tank. There is no EPA definition of wastewater for purposes of WWTU exemption (SEE ALSO: RPC# 2/11/91-01; RPC# 6/2/93-04).
 
09/01/1984TANKS USED FOR COLLECTING SPILLSQuestion & Answer
 Description: A tank used on a predictable basis for collecting hazardous waste spills must be addressed in the closure plan. A tank used to collect hazardous waste spilled from a manufacturing process unit is subject to the generator or TSDF standards.
 
07/30/1984DRAGOUT FROM F007 - SPENT CYANIDE PLATING BATH SOLUTIONSMemo
 Description: Chlorination tank bath solutions and sludges contaminated with plating bath dragout (carryover) are F007. The sludge may be F006 if wastewaters from an electroplating operation enter the chlorination tank (SEE ALSO: RPC# 7/12/94-01; RPC# 4/7/88-01; RPC# 11/24/86-02).
 
07/19/1984WASTEWATER TREATMENT UNIT EXEMPTIONMemo
 Description: If a tank treats wastewater to comply with the POTW pretreatment requirements, the tank is "subject" to 307(b) of the CWA and is eligible for the wastewater treatment unit (WWTU) exemption, even if treated wastewater is actually delivered to the POTW by truck (SUPERSEDED: see RPC# 12/21/87-03; 53 FR 34079, 34080; 9/2/88).
 
06/27/1984APPLICABILITY OF THE WASTEWATER TREATMENT UNIT EXEMPTION TO A GROUNDWATER TREATMENT SYSTEMMemo
 Description: The state or Region must determine the applicability of the wastewater treatment unit (WWTU) definition to a groundwater treatment tank. There is no EPA definition of wastewater for the purposes of the WWTU exemption (SEE ALSO: RPC# 2/11/91-01; RPC# 6/2/93-04).
 
05/22/1984DEFINITION OF “WASTEWATER TREATMENT UNIT”Memo
 Description: Tanks that produce no effluent as direct result of CWA requirements (i.e., zero dischargers) can qualify as an exempt wastewater treatment unit (WWTU).
 
05/01/1984FILTER PRESS IN WASTEWATER TREATMENT UNIT, EXCLUSION FORQuestion & Answer
 Description: A tank-like portable filter press used in a wastewater treatment facility is excluded from regulation if the filter press meets the 260.10 criteria for a wastewater treatment unit (WWTU).
 
05/01/1984LEAKING TANK DISQUALIFIES WASTEWATER TREATMENT FACILITY AS DE MINIMISQuestion & Answer
 Description: Groundwater contaminated with a listed commercial chemical product (CCP) from a leaking tank is not eligible for the de minimis losses exclusion from the mixture rule (261.3(a)(2)(iv)(D)).
 
05/01/1984TANK V. SURFACE IMPOUNDMENTQuestion & Answer
 Description: An explanation of the difference between tanks and surface impoundments is provided. Tanks are self-supporting, while surface impoundments require supporting earthen materials (SEE ALSO: RPC# 4/8/83-01).
 
04/26/1984WASTEWATER TREATMENT SLUDGES FROM WOOD PRESERVING PROCESSES USING CREOSOTE AND/OR PENTACHLOROPHENOLMemo
 Description: Wood preserving oil/water separator sludges and thermal dehydrator sludges may be K001 if creosote and/or pentachlorophenol (PCP) was used. Storage/work tank sludges mixed with the above sludges are listed. Historic estimation rates of waste generation are provided.
 
03/01/1984STORAGE TANKS THAT ARE PART OF WASTEWATER TREATMENT SYSTEM ARE EXCLUDEDQuestion & Answer
 Description: A tank storing sludge piped from a wastewater treatment unit (WWTU) qualifies for the WWTU exemption, even if the storage tank does not discharge under CWA standards.
 
03/01/1984TANKS AND SURFACE IMPOUNDMENTS HOLDING DE MINIMIS SPILLSQuestion & Answer
 Description: A tank or surface impoundment used to contain de minimis spills of commercial chemical products (CCPs) prior to the promulgation of the 261.3(a)(2)(iv)(D) mixture rule exemption is subject to interim status standards until 11/17/81, including closure requirements.
 
02/23/1984HAZARDOUS WASTE TREATMENT/STORAGE TANKS, PERMITTINGMemo
 Description: Permits must specify a minimum shell thickness for all treatment and storage tanks. Methods exist for determining the thickness for various tanks and are provided. Tanks must be inspected internally before the issuance of a draft permit and during their active life (SUPERSEDED: see 51 FR 25422; 7/14/86).
 
02/01/1984TREATMENT TANKS FOR LEACHATE OR LIQUID WASTESQuestion & Answer
 Description: There is no regulatory definition of wastewater. A reasonable interpretation would be industrial process waste containing 1 percent or less contaminants. Treatment tanks for leachate, liquid wastes should not be exempt wastewater treatment units (WWTUs) (SEE ALSO: RPC# 8/15/90-01; RPC# 2/11/91-01).
 
12/14/1983MINIMUM SHELL THICKNESS REQUIREMENT, WAIVERMemo
 Description: There are no provisions for the Regional Administrator (RA) to grant a waiver for the minimum shell thickness that is required for hazardous waste storage or treatment tanks (SUPERSEDED: see 51 FR 25422; 7/14/86).
 
11/01/1983PERMIT REQUIREMENTS FOR NON-REGULATED UNITSQuestion & Answer
 Description: EPA cannot call for a Part B permit application for an interim status unit for which there are no regulations in Part 264 (e.g., an underground tank that cannot be entered for inspection).
 
10/01/1983MANIFEST FOR SPLIT SHIPMENTQuestion & Answer
 Description: Provides guidance on completing the manifest when one rail shipment of waste is divided among five tank trucks for transport to the designated facility identified on the manifest (SEE ALSO: RPC#8/7/98-02).
 
09/21/1983TANK INSPECTION PROCEDURESMemo
 Description: The inspection of tanks should include visual inspection of the tank interior. Applicants may use alternatives to physical entry of the tank. The inspection frequency is based on the nature of the tank and the material being stored (SUPERSEDED: see 51 FR 25422; 7/14/86) (SEE ALSO: 264.195(b) for the proper citation).
 
09/01/1983WASTE STORAGE TANK ATTACHED TO FILTRATION UNITQuestion & Answer
 Description: An activated carbon filtration unit attached to a hazardous waste storage tank vent pipe treats waste, but it is not permitted separately from the tank. A permit would be issued for the tank for storage only. The carbon is a solid waste and may exhibit characteristics or may contain listed waste.
 
04/20/1983TANK SHELL THICKNESS REQUIREMENTMemo
 Description: Owners and operators must submit information about the tank shell thickness when submitting a permit application. Federal regulations do not require secondary containment for tanks (SUPERSEDED: see 264.193 and 265.193).
 
04/08/1983TANK AND SURFACE IMPOUNDMENT, DEFINITIONSMemo
 Description: A facility must evaluate units as free standing and filled to design capacity. Tanks have walls or shells that provide sufficient structural support to maintain structural integrity of the unit. Surface impoundments will not retain structural integrity without supporting earthen materials.
 
02/18/1983TOTALLY ENCLOSED TREATMENT FACILITY, REGULATORY CLARIFICATION OFMemo
 Description: A totally enclosed treatment unit (TETU) must be enclosed on all sides, pose little threat of waste escape, and be integrally connected to an industrial production process. TETUs are limited to pipelines, tanks, and tank-like equipment. The exemption applies to the unit, not effluent from the unit. Effluents discharged to surface water, sewer, or publicly owned treatment works are not RCRA regulated.
 
02/01/1983CONTAINER STORAGE IN PART BQuestion & Answer
 Description: The part B permit application for a container storage area does not need certification of technical data. The certification of other units, such as tanks, is not limited to state-certified professional engineers.
 
08/31/1982ACCUMULATION OF HAZARDOUS WASTE IN TANKS (90-DAY)Memo
 Description: Generators may accumulate hazardous waste in tanks or containers for 90 days or less without a permit or interim status. EPA considers generator accumulation to be incidental to their operations. Provides guidance on defining an empty tank.
 
06/06/1981K052 LISTING FOR WASTES GENERATED BY PETROLEUM INDUSTRYMemo
 Description: The K052 listing is limited to only those leaded tank bottoms that are generated at or as part of a petroleum refinery. Provides definition of petroleum refinery. Only those tanks that are directly part of a refinery and generate leaded bottoms are listed.
 
05/20/1981APPLICABILITY OF GENERATOR REGULATIONS TO ON-SITE CONTRACTORSMemo
 Description: An on-site contractor removing hazardous waste from tanks, vehicles, and vessels qualifies as a generator. The contractor may be jointly and severally liable with other cogenerator for compliance with applicable regulations.
 
05/07/1981APPICABILITY OF 261.33(F) LISTING TO SEWER AND CESSPOOL ADDITIVES CONTAINING ORTHODICHLOROBENZENEMemo
 Description: Use of orthodichlorobenzene (U070) to unclog sewer pipes and septic tanks is not disposal of unused CCP and is not listed. CCPs are not hazardous waste until they are discarded. Normal use is not disposal. Organic solvents in cesspool/ sewer lines may contaminate groundwater and soil.
 
03/03/1981REGULATORY CLARIFICATION OF TOTALLY ENCLOSED TREATMENT FACILITYMemo
 Description: The totally enclosed treatment unit (TETU) exemption is limited to tanks, pipes, and tank-like equipment. The exemption applies to the unit, not effluent from the TETU. The TETU must be completely contained, present no potential for escape of constituents, and be directly connected to industrial process. It must prevent leaks, spills and gaseous emissions.
 
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