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Document Record Detail

Full Document:
RCRA Online Number:12783
To:Guerci, HQ
From:Weddle and Lehman
Organization of Recipient:EPA
Description: Contaminated groundwater is not a solid waste but must be handled as if it were a hazardous waste if it contains hazardous waste (contained in policy). Units handling such groundwater must be hazardous waste units. Such units may be exempt from permitting under the section 270.72 changes during interim status. Volatile organics released to the air during remediation are not solid wastes, but a release of hazardous constituents is subject to section 3008(h) corrective action authorities. The statute requires both air and groundwater contamination to be addressed. (SEE ALSO: 264/265 Subparts AA, BB, CC). A 1977 spill from a UST is subject to section 9003 corrective action is not subject to section 3008(h). The spraying of treated waste on land is land disposal and is subject to the land disposal restrictions (LDR).
Regulatory Citation(s) : 261.3, 261.4(b)(10), 264.101, 268.2(c), 270.72 EXIT disclaimer
Statutory Citation(s):3008(h); 9003 Read US Code 42, Chapter 82 EXIT disclaimer
Topic(s):Cleanup (RCRA); Compliance; Corrective Action (RCRA); Disposal; Enforcement (RCRA); Exclusions (RCRA); Hazardous Waste; Permits and Permitting; Land Disposal Restrictions; Treatment; TSDFs; Underground Storage Tanks (UST)
Approximate Number of Hardcopy Pages:3
EPA Publication Number:NA
RPPC Number (if applicable): 9441.1986(86)
Official OSW Policy:Yes


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