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Document Record Detail



Full Document:
Title:SUMMARY OF PERMIT ASSISTANCE TEAM (PAT) COMMENTS
RCRA Online Number:12890
Date:03/30/1987
To:Directors, Regions 1-10
From:Weddle
Organization of Recipient:EPA
Description: A native soil foundation does not constitute a liner for the purposes of the 3005(j)(2) waiver. A 264.282 compatibility demonstration applies to both hazardous and nonhazardous waste. Addresses HSWA waste minimization requirements (3002(b)) and the application of sludge to land treatment units. The identification of principal hazardous constituents for land treated wastes must include all constituents that may enter the waste stream. A land treatment unit performance evaluation must include the unit’s ability to treat and degrade organic constituents, as well as its ability to immobilize heavy metals. Provides guidance on the frequency of soil pore liquid sampling at land treatment units (unsaturated zone monitoring) and guidance on screening groundwater monitoring wells. QA/QC methodology at a land treatment unit should include verification of the organic constituent analysis by gas chromatography/mass spectroscopy (GC/MS). Includes guidance on the content of construction quality assurance plans. A person who conducts quality assurance measures for surface impoundments, waste piles, and landfills should be independent of the construction contractor. Discusses the use of Method 9090 for compatibility testing of liner materials with waste or leachate. All man-made materials that contact waste or leachate should be subjected to the immersion test portion of 9090. A sample of waste or leachate used in compatibility testing must be representative of the actual waste or leachate managed in the surface impoundment, waste pile, or landfill. A concrete pad cannot be equivalent protection. If the design slope of a final landfill cover exceeds 3-5%, the applicant must demonstrate that soil erosion will not be excessive and may need to perform a slope stability analysis. Waste and soil settlement must be included in calculations for the final landfill cover design to be substituted for a waste pile liner as equivalent protection under 3015(a). A flexible membrane liner should not be used in a final cover when the landfill is unusually deep and slopes are steep. Clean, not contaminated, soil should be used for the final cover. A leachate collection system design should be based on realistic infiltration rates. Geogrid and geotextile materials used in place of conventional drainage materials for a landfill must have an equivalent drainage capacity of a one-foot layer of compacted sand. Berms constructed of manufactured slag should not contain hazardous constituents. For landfills, the use of a composite primary liner below the primary synthetic liner is allowable. An owner of a land treatment unit who cannot establish vegetative cover may use an alternate closure procedure. A facility cannot extend closure in order to receive nonhazardous waste (SUPERSEDED: see current 264.113(d)). Addresses the role of the Agency for Toxic Substances and Disease Registry (ATSDR) in exposure information and evaluation. The review of Exposure Information Reports should be coordinated with ongoing RCRA Facility Assessments.
Regulatory Citation(s) : 264.19, 264.97, 264.113(d), 264.221, 264.251, 264.272, 264.278(b)(2), 264.278(a)(2), 264.280, 264.282, 264.301, 264.301(a), 264.310, 270.10(j), 270.20 EXIT disclaimer
Statutory Citation(s):3002(b); 3005(j)(2) Read US Code 42, Chapter 82 EXIT disclaimer
Topic(s):EPA Forms; Hazardous Waste; Land Disposal Units; Land Treatment Units; Nonhazardous Waste; Treatment; TSDFs; Permits and Permitting; Test Methods; Disposal; Landfills; Storage; Surface Impoundments; Test Methods; Waste Piles; Closure (hazardous waste); Nonhazardous Waste
Approximate Number of Hardcopy Pages:13
EPA Publication Number:NA
RPPC Number (if applicable): 9523.00-12
Official OSW Policy:Yes

 

 
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