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   vvEPA
                 United StatM
                 Environmental Protection
                 Agmcy
              Office of
              Water Enforcement and Permits
              Washington. DC 20460
                 »•»_...—
                 WknVf
Guidance Manual for the
Identification of Hazardous Wastes
Delivered to Publicly
Owned Treatment Works by
Truck, Rail, or Dedicated Pipe

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      GUIDANCE MANUAL  FOR THE  IDENTIFICATION OF
     HAZARDOUS WASTE DELIVERED TO PUBLICLY OWNED
TREATMENT WORKS BY TRUCK, RAIL,  OR DEDICATED PIPELINE
                       June 1987
                     Prepared for:

         U.S. Environmental Protection Agency
       Office  of  Water  Enforcement and Permits
                  401 M Street, S.W.
                Washington,  DC  20460
                     Prepared by:

    Science Applications International Corporation
                  8400  Westpark Drive
                   McLean,  VA  22102
        EPA Contract No. 68-01-7043, WA  tPl-23
           SAIC Project No. 2-834-03-527-00

           U.S. Environmental Protection Agency
           Region 5, library (PI-12J)
           77 West Jackson Boulevard. 12th Floor
           Chicago, )l 60604-3590

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                               ACKNOWLEDGEMENT

     This document was prepared under the direction of EPA Headquarters,
Office of Water Enforcement and Permits, by Science Applications International
Corporation, EPA Contract No. 68-01-7043, Work Assignment Number Pl-1.  Staff
from the Office of Solid Waste, Office of General Counsel, and the EPA Regions
provided valuable comments on drafts of the document.  Special appreciation
is extended to the following individuals for their participation in the
document's preparation:  James Taft, Environmental Engineer and EPA Work
Assignment Manager; Gary Cohen, Attorney-Advisor; and Robert Linett, Jim
Parker, Frank Sweeney, and Eric Washburn of SAIC.

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                              TABLE OP CONTENTS

                                                                     Page

     EXECUTIVE SUMMARY	  i

1.   INTRODUCTION	  1-1

     1.1  PURPOSE OF THIS MANUAL	  1-1
     1.2  LEGISLATIVE AND REGULATORY OVERVIEW	  1-1
     1.3  ORGANIZATION OF THE MANUAL	  1-2

2.   DESCRIPTION OF RCRA REGULATED WASTES	  2-1

     2.1 ' DEFINITION OF SOLID WASTE	  2-2

          2.1.1  Definition of Solid Waste	  2-2
          2.1.2  Domestic Sevage Exclusion	  2-2

     2.2  DEFINITION OF HAZARDOUS WASTE	  2-3

          2.2.1  Characteristic Wastes	  2-4
          2.2.2  Listed Hazardous Waste	  2-10
          2.2.3  Mixture Rule	  2-13

     2.3  RCRA REGULATORY STATUS OF SELECTED WASTES THAT MAY BE
          RECEIVED BY POTWs	  2-14

          2.3.1  Selected Wastes	  2-14

3.   RESPONSIBILITIES OF POTWs CHOOSING NOT TO ACCEPT HAZARDOUS
     WASTE	  3-1

     3.1  DESCRIPTION OF POTENTIAL LIABILITIES FOR POTWs ACCEPTING
          HAZARDOUS WASTE	  3-2

     3.2  CONTROL MEASURES TO PREVENT DISCHARGES OF HAZARDOUS WASTE
          TO POTWs	  3-3

          3.2.1  Regulatory Control Mechanisms	  3-4
          3.2.2  Administrative Controls	  3-10

     3.3  WASTE MONITORING PLAN	  3-20

          3.3.1  Identification of Potential Hazardous Waste Source
                 and Types	  3-21
          3.3.2  Considerations in Developing a Waste Monitoring
                 Plan	  3-29
          3.3.3  Example Waste Monitoring Plans	  3-32

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                        TABLE OF CONTENTS  (Continued)

                                                                     Page

4.   RESPONSIBILITIES OF POTWs CHOOSING TO ACCEPT HAZARDOUS WASTES   4-1

     4.1  INTRODUCTION	 4-1
     4.2  COMPLIANCE WITH NPDES PERMIT CONDITIONS	 4-2

          4.2.1  Procedures for Determining Compliance	 4-2

     4.3  COMPLIANCE WITH PRETREATMENT PROGRAM REQUIREMENTS	 4-3
     4.4  COMPLIANCE WITH RCRA PROCEDURAL REQUIREMENTS	 4-7

          4.4.1  EPA Identification Number	 4-7
          4.4.2  Manifest System	 4-7
          4.4.3  Operating Record	 4-10
          4.4.4  Biennial Report	 4-11

     4.5  CORRECTIVE ACTION	 4-11


                                  APPENDICES

     APPENDIX A    RCRA LISTS

     APPENDIX A-l  RCRA LISTED HAZARDOUS WASTES
     APPENDIX A-2  40 CFR PART 261, APPENDIX VIII
                   LIST OF HAZARDOUS CONSTITUENTS
     APPENDIX A-3  40 CFR PART 261, APPENDIX VII
                   BASIS FOR LISTING HAZARDOUS WASTES

     APPENDIX B    EXAMPLE POTW SEWER USE  ORDINANCE LANGUAGE

     APPENDIX C    EXAMPLE WASTE HAULER PERMIT

     APPENDIX D    EXAMPLE WASTE TRACKING  FORM

     APPENDIX E    PERMIT BY RULE REQUIREMENTS EXPANDED TO INCLUDE  SECTIONS
                   INCORPORATED BY REFERENCE

     APPENDIX F    FORMS
     APPENDIX F-l  NOTIFICATION OF HAZARDOUS WASTE ACTIVITY
                   (EPA FORM 8700-12)
     APPENDIX F-2  UNIFORM HAZARDOUS WASTE MANIFEST
                   (EPA FORM 8700-22)
     APPENDIX F-3  BIENNIAL HAZARDOUS WASTE REPORT
                   (EPA FORM 8700-13B)

     APPENDIX G    STATE HAZARDOUS WASTE CONTACTS

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                                LIST OF TABLES

Table                                                                Page

2-1  CONSTITUENTS AND CONCENTRATIONS FOR EP TOXICITY                 2-9

2-2  SUMMARY OF SELECTED WASTES                                      2-15

2-3  LISTED METAL FINISHING WASTES                                   2-17

2-4  LISTED SOLVENTS                                                 2-19

2-5  ESTIMATED NUMBER OF SMALL QUANTITY GENERATORS (100 KG
     TO 1,000 KG/MONTH) BY INDUSTRY GROUP                            2-24

3-1  RECOMMENDED REGULATORY MECHANISMS FOR PREVENTING DISCHARGES
     OF HAZARDOUS WASTE BY TRUCK, RAIL, OR DEDICATED PIPELINE        3-8

3-2  RECOMMENDED ADMINISTRATIVE MECHANSIMS FOR PREVENTING DISCHARGES
     OF HAZARDOUS WASTE BY TRUCK, RAIL, OR DEDICATED PIPELINE        3-11

3-3  WASTE EVALUATION PROCEDURES:  APPLICABILITY AND CONSTRAINTS     3-24


                                LIST  OF FIGURES

Figure                   •                                            Page

2-1  HAZARDOUS WASTE IDENTIFICATION PROCESS                          2-5

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                               EXECUTIVE  SUMMARY

     Publicly Owned Treatment Works (POTWs) that accept hazardous wastes by
truck, rail, or dedicated pipeline within the property boundary of the plant
are considered to be hazardous waste treatment, storage, and disposal facil-
ities (TSDFs) and, as such, are subject  to regulation under the Resource
Conservation and Recovery Act  (RCRA).  The purposes of this manual are to:
(1) offer administrative, and  technical  recommendations to POTVs seeking to
preclude the receipt of hazardous wastes by these transportation methods; and
(2) discuss the responsibilities of POTVs choosing to accept hazardous wastes
by these transportation methods.

     In accomplishing these dual purposes, the manual provides the statutory
and regulatory definitions of hazardous  wastes.  It also describes the RCRA
regulatory status of wastes that POTV operators typically may encounter.  As
this section of the manual demonstrates, the RCRA regulatory status of a waste
is not necessarily straightforward.  However, the manual provides some
guideposts which will assist the operator in making these determinations.

     The manual also provides a discussion of legal, administrative, and
technical methods to preclude  the receipt of hazardous wastes, many of which
are already in use.  A description of potential liabilities- that POTVs may
incur as a result of accepting hazardous wastes is also provided.  These
liabilities may present POTVs with an incentive for adopting programs directed
at precluding the receipt of hazardous wastes.

     The manual also describes the responsibilities of POTVs that choose to
accept hazardous wastes by truck, rail,  or dedicated pipeline.  This section
describes the special regulatory provisions, known as permit by rule require-
ments, that the RCRA program imposes upon POTVs accepting hazardous wastes by
the aforementioned transportation methods.

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                               1.  INTRODUCTION

1.1  PURPOSE OF THIS MANUAL
     The manual is directed toward two types of facilities.  First, guidance
is offered to POTWs that wish to preclude the entry of hazardous wastes into
their facilities and avoid regulation and liability under RCRA.  Administra-
tive and technical recommendations for control of such wastes are provided,
many of which are already in use by POTWs.  Second, the responsibilities of
POTVs that choose to accept hazardous wastes from truck, rail, or dedicated
pipeline are discussed, including the relevant regulatory provisions, strict
liability and corrective action requirements for releases, and recommended
procedures for waste acceptance and management.

     Publicly owned treatment works (POTWs) that accept hazardous wastes by
truck, rail, or dedicated pipeline within the property boundary of the plant  '
are considered to be hazardous waste treatment, storage, and disposal facili-
ties (TSDFs) and are subject to regulation under the Resource Conservation and
Recovery Act (RCRA).  This manual provides guidance to POTW operators in
determining whether they are regulated by RCRA, describes the relevant
regulatory requirements they are subject to under RCRA, and explains methods
for avoiding the entry and disposal of hazardous wastes into their sewer
systems.

1.2  LEGISLATIVE AND REGULATORY OVERVIEW
     RCRA establishes a comprehensive program for managing the disposal of
hazardous waste from the time it is generated until its ultimate disposal.
This "cradle to grave" management system regulates the hazardous waste
activities of generators, transporters, and TSDFs.  TSDFs are subject to a
wide range of RCRA requirements, encompassing both administrative and techni-
cal requirements.

     Under RCRA, mixtures of domestic sewage and other wastes that comingle in
the POTW's collection system prior to reaching the property boundary, includ-
ing those wastes that otherwise would be considered hazardous, are excluded
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            from regulation under the domestic sevage exclusion (see Section 2.1.3 of this
            guidance for further information regarding this exclusion).  However, wastes
            that are delivered directly to the POTV by truck, rail, or dedicated pipeline
            do not fall within the exclusion.  Hazardous wastes received by these routes
            may only be accepted by POTVs if the POTWs comply with applicable RCRA
            requirements for TSDFs.

                 In promulgating standards for TSDFs under RCRA, the Environmental
            Protection Agency (EPA) recognized that POTVs already were subjected to
            extensive Clean Water Act (CVA) requirements and therefore adopted a special
            TSDF provision known as the "permit by rule" for POTVs accepting hazardous
            wastes by truck, rail, or dedicated pipeline.  These permit by rule
            requirements are far less comprehensive than those RCRA requirements that
            apply to non-POTV TSDPs.  Under the permit by rule regulation at 40 CFR
            270.60(c), a POTV must 1) have a NPDES permit, 2) comply with that-permit,
            3) obtain a RCRA ID number and comply with certain manifest and reporting
            requirements under RCRA, 4) satisfy corrective action requirements, and
            5) meet all Federal, State, and local pretreatment requirements.   (For more
            information on the procedures for obtaining a permit by rule, please refer  to
            EPA's Guidance for Implementing RCRA Permit By Rule Requirements at POTVs.)

            1.3  ORGANIZATION'OF THE MANUAL
                 POTVs must ascertain if they are accepting hazardous wastes regulated  by
            RCRA to determine if they are subject to RCRA permit by rule conditions.
            Chapter 2 provides the statutory and regulatory definition of "hazardous
            waste" and describes examples of types of waste that, if received  by POTVs,
            will trigger the RCRA regulations.  In addition, the regulatory status of
            selected wastes that may be received by POTVs is discussed by way  of example.
            Chapter 3 provides guidance to POTVs that choose not to accept regulated
            hazardous wastes.  Control measures are presented that may be employed to
            prevent the discharge of hazardous wastes inside the POTV's property boundary
            by truck, rail, or dedicated pipeline.  These measures include ordinance
            provisions, administrative control mechanisms, inspection and sampling
            techniques to regulate known discharges, and surveillance and investigative
            procedures to prevent unknown discharges.  Chapter 3 also addresses the
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development and implementation of a vaste monitoring plan as part of the
hazardous vaste identification process.  In Chapter 4, the responsibilities of
POTVs that choose to accept hazardous wastes by truck, rail, or dedicated
pipeline are discussed, including RCRA permit by rule requirements and  the
potential liabilities associated with the receipt of hazardous wastes.
                                         1-3

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                   2.  DESCRIPTION OF RCRA REGULATED WASTES

     A POTV must ascertain if hazardous wastes are delivered to the property
boundary by truck, rail, dedicated pipeline*, or vessel (the remainder of this
document does not refer to "vessels" although the requirements and recommenda-
tions are also applicable to them) to determine if it is subject to the RCRA
permit by rule requirements.  The receipt of hazardous wastes by these
transportation methods triggers the permit by rule requirements.  Under RCRA,
the classification of a material as a hazardous waste is contingent upon
several factors, including both legal and technical considerations.

     At a minimum, a POTV needs to determine whether the waste it received was
accompanied by a Hazardous Waste Manifest since, if it was, the waste was
certainly a hazardous waste.  However, POTWs may want to ascertain whether
wastes not accompanied by a Manifest are also hazardous since POTWs may be
subject to RCRA responsibilities even if they unknowingly accept hazardous
wastes.

     This chapter provides a description of key factors used by EPA.in
determining whether a material is a hazardous waste.  It also provides several
examples of common wastes and discusses their regulatory status under RCRA as
of the time this manual was prepared.  The determination of whether or not a
material is a hazardous waste is not a straightforward exercise, and several
procedural and technical steps must be taken by the POTW operator to make a
positive determination.  State and EPA Regional hazardous waste program
officials can help POTWs in making these determinations by providing records
of known hazardous waste handlers.  Recommended steps for determining whether
or not a material is a hazardous waste are provided in Chapter 3.

2.1  DEFINITION OF SOLID WASTE
     The definition of "solid waste" is central to the determination of
whether or not a waste is hazardous.  Under RCRA, hazardous wastes are a

*A dedicated pipeline refers to a separate pipeline that is used to carry
 hazardous wastes directly to a POTW's property boundary without prior mixing
 with domestic sewage.
                                      2-1


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subset of solid wastes.  Therefore, a material must be considered a solid
waste to be defined as a hazardous waste.  The term "solid waste" includes
essentially all physical forms of waste (i.e., solids, liquids, semisolids, or
contained gaseous substances), and is therefore broader than what normally is
considered to be "solid."

2.1.1  Definition of Solid Waste
     Section 1004(27) of RCRA defines "solid waste" to mean

          . . . any garbage, refuse, sludge from a waste treatment
          plant, water supply treatment plant, or air pollution
          control facility and other discarded material, including
          solid, liquid, semisolid, or contained gaseous materials
          resulting from industrial, commercial, mining, and agri-
          cultural operations, and from community activities . . .
          does not include solid or dissolved material in domestic
          sewage, or solid or dissolved materials in irrigation
          return flows or industrial discharges which are point
          sources subject to permits under Section 402 of the
          Federal Water Pollution Control Act, as amended (86 Stat.
          880), or source, special nuclear, or byproduct material as
          defined by the Atomic Energy Act of 1954, as amended (68
          Stat. 923).
     Under RCRA, if a business generates any material that is discarded or
disposed of, it must, determine if that material is a "solid waste" according
to the regulatory definition.  According to the regulatory definition, "solid
waste" is any material that is abandoned or disposed of, burned or
incinerated, or stored, treated, or accumulated before or in lieu of  these
actions.

2.1.2  Domestic Sewage Exclusion
     Some materials, however, are NOT considered to be solid wastes under
RCRA, including domestic sewage or any mixture of domestic sewage and other
wastes that pass through a sewer system to a POTW.  While this exclusion,
known as the domestic sewage exclusion, extends to most wastes that reach
POTWs, IT DOES NOT exempt wastes received within the POTW's property  boundary
by truck, rail, or dedicated pipeline.
                                      2-2

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2.2  DEFINITION OF HAZARDOUS WASTE

     As defined in Section 1004(5) of RCRA, "the term 'hazardous waste' means

a solid waste, or combination of solid wastes, which because of its quantity,

concentration, or physical, chemical or infectious characteristics may —


     (A)  cause, or significantly contribute to an increase in mortality or an
          increase in serious irreversible, or incapacitating reversible,
          illness; or

     (B)  pose a substantial present or potential hazard to human health or
          the environment when improperly treated, stored, transported, or
          disposed of, or otherwise managed."


     Section 3001 of RCRA directs EPA to identify or list those solid wastes

that are considered hazardous for regulatory purposes.  These regulations are

codified in 40 CFR Part 261.  All solid waste generators must determine if any

of their waste is hazardous.  If their waste is hazardous, they must notify

EPA or the State of that fact (see Section 4.4.1 of this guidance for details

on notification).


     There are four steps for determining whether a solid waste is regulated

as a hazardous waste under Federal law:


     •  First, determine if the waste is exempted from regulation as a solid
        or a hazardous waste (see, for example, Section 2.3.1.1).

     •  Second, check to see if it is listed as a hazardous waste in Subpart D
        of 40 CFR 261.  Listed wastes are regulated as hazardous wastes unless
        they have been specifically delisted (see Section 2.2.2).

     •  If the waste has not been listed as a hazardous waste, determine if it
        exhibits, on analysis, any of the characteristics of a hazardous
        waste, cited in Subpart C of 40 CFR 261 (see Section 2.2.1).

     •  Last, determine if the waste is a mixture.  A mixture of a listed
        waste and a nonhazardous solid waste is considered hazardous unless it
        has been specifically excluded under 40 CFR Part 261.3.  A mixture of
        a characteristic waste and a nonhazardous solid waste is only consid-
        ered hazardous if it still exhibits one or more of the hazardous waste
        characteristics.
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     Figure 2-1 presents a flow chart of the hazardous vaste identification
process.  The following discussion provides a general overview of this
process.  More information on this process is provided in 40 CFR Part 261.
Note, however, that the definition of hazardous waste provided here is the
Federal definition.  States may have more stringent or different definitions
of hazardous waste.  See Section 2.3.1.11.

     The generator is responsible for determining whether a solid waste is
hazardous.  A generator must review EFA's hazardous waste listings to deter-
mine if the solid waste is a listed hazardous waste.  If the waste is not
listed, the generator either must test his solid waste using standard methods
(specified in 40 CFR Part 261) or have sufficient knowledge about his waste to
assess whether it exhibits any of the hazardous waste characteristics.  The
tests must be run on representative samples to obtain results that adequately
characterize the nature of the waste.  If the waste exhibits a hazardous waste
characteristic, then it is hazardous and must be handled accordingly.

2.2.1  Characteristic Wastes
     Any solid waste that exhibits one or more of the hazardous waste charac-
teristics is classified as a hazardous waste under RCRA.  For example, if a
sewage sludge exhibited any one of the four characteristics below it would be
considered a hazardous waste:

     •  Ignitability
     •  Corrosivity
     •  Reactivity
     •  EP Toxicity.

     EPA used  two  criteria in selecting  these characteristics as indicators of
hazardous waste.  The  first criterion was  that  the  characteristics be capable
of being defined in  terms of physical, chemical, or other properties  that
cause  the waste  to meet  the definition of hazardous waste in  the Act  (see
pages  2-2 and  2-3).  The second criterion was that  the  properties defining  the
characteristics  be measurable by  standardized,  available  testing protocols.
The  second criterion was adopted  because the primary  responsibility  for
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determining whether a solid waste exhibits any of the characteristics rests
with the generators.  EPA was concerned that unless generators were provided
with widely available and uncomplicated methods for determining whether their
wastes exhibited the characteristics, the identification system would prove
unworkable.

     As testing protocols become generally acceptable and EPA's confidence in
setting minimum thresholds increases, more characteristics will be added.  The
Hazardous and Solid Vaste Amendments (HSVA) of 1984 require that the Adminis-
trator promulgate regulations identifying additional characteristics.  Section
2.2.1.4 of this guidance describes how EPA plans to expand the coverage of one
of the characteristic tests.

     The properties of wastes exhibiting any or all of the existing character-
istics are defined in 40 CFR Parts 261.20-261.24, and are described briefly
below.

2.2.1.1  Ignitability
     A solid waste that exhibits any pf the following properties is considered
hazardous due to its ignitability:

     •  A liquid, except aqueous solutions containing less than 24 percent
        alcohol, that has a flashpoint less than 60°C (140°F)
     •  A nonliquid capable, under normal conditions, of spontaneous and
        sustained combustion
     •  An ignitable, compressed gas per Department of Transportation (DOT)
        regulations
     •  An oxidizer per DOT regulations (40 CFR Part 261.21).

     EPA's objective in selecting ignitability as a hazardous waste character-
istic was to identify wastes capable of causing fires during routine trans-
portation, storage, and disposal and/or exacerbating a fire once started. EPA
recognized that such fires pose a particular danger to transportation and
disposal personnel and also threaten the general public by generating toxic
fumes and transporting toxic particulates to the surrounding area.  Solid
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wastes exhibiting the igndlability characteristic are assigned EPA Hazardous
Vaste Number D001.

2.2.1.2  Corrosivity
     A solid vaste that exhibits any of the following properties is considered
hazardous due to its corrosivity (40 CFR Part 261.22):

     •  An aqueous material with pH less than or equal to 2 or greater  than or
        equal to 12.5
     •  A liquid that corrodes steel at a rate greater than 1/4 inch per year
        at a temperature of 55"C (130°F).

        EPA selected pH as a corrosivity indicator because wastes exhibiting
low or high pH can:  result in harm to human tissue, promote the migration of
toxicants from other wastes, react dangerously with other waste, and cause
harm to aquatic life.  EPA selected the second indicator of corrosivity
because wastes capable of corroding metal can escape from the containers in
which they are segregated, thus freeing other wastes to the environment.
Solid wastes exhibiting the corrosivity characteristics are assigned EPA
Hazardous Vaste Number D002.

2.2.1.3  Reactivity
     A solid waste that exhibits any of the following properties is considered
hazardous due to its reactivity (40 CFR Part 261.23):

     •  Normally unstable and reacts violently without detonating
     •  Reacts violently with water
     •  Forms a potentially explosive mixture with water
     •  Generates toxic gases, vapors, or fumes when mixed with water
     •  Contains cyanide or sulfide and generates toxic gases, vapors,  or
        fumes at a pH between 2 and 12.5
     •  Capable of detonation if heated under confinement or subjected  to
        strong initiating source
     •  Capable of detonation at standard temperature and pressure
     •  Listed by DOT as a Class A or B explosive.
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As these properties imply, reactivity is largely defined on a qualitative
rather than quantitative basis.  Reactivity tests yielding quantitative
results are difficult to administer and interpret.  Nonetheless, reactivity
can pose a hazard at any stage of the waste management cycle.  Thus, despite
the fact that the characteristic of reactivity cannot be easily measured, EPA
promulgated reactivity as a hazardous waste characteristic.  EPA reasoned that
operators, out of concern for their facilities, generally are aware that a
waste is reactive.  Furthermore, reactive wastes rarely are generated from
nonreactive feedstocks.  Examples of reactive wastes include water from
trinitrotoluene (TNT) operations.  Solid wastes exhibiting the reactivity
characteristic are assigned EPA Hazardous Vaste Number D003.

2.2.1.A  EP Toxicity
     The term EP toxicity refers to a characteristic of a waste (40 CFR
Part 261.24), as well as a test for that characteristic.  The extraction
procedure (EP) test is designed to identify wastes likely to leach hazardous
concentrations of particular toxic constituents into the ground water as a
result of improper management.

     The contamination of ground water through the leaching of waste contami-
nants from land disposed wastes is one of the most prevalent pathways by which
toxic waste constituents migrate to the environment.  The legislative history
of RCRA and HSVA indicates that ground water contamination is one of Congress'
primary areas of concern with regard to hazardous waste management.  Under the
EP test procedure, constituents are extracted from the waste in a manner
designed to simulate the leaching action that occurs in sanitary landfills.
This extract then is analyzed to determine whether it possesses any of the
toxic contaminants identified in the National Interim Primary Drinking Water
Standards (NIPDVS).  If the extract contains any of the contaminants in
concentrations 100 times greater than that specified in the NIPDVS, the waste
is considered to be hazardous.  The contaminants of concern, which include
eight metals and six herbicides/pesticides, are listed in Table 2-1.  Solid
wastes exhibiting the EP toxic characteristic are assigned EPA Hazardous Waste
Numbers D004 to D017.
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         TABLE 2-1.  CONSTITUENTS AND CONCENTRATIONS FOR EP TOXICITT


                                                               Maximum
                                                            Concentration
EPA Hazardous                                                (milligrams
Waste Number
D004
D005
D006
D007
D008
D009
D010
D011
D012
D013 .
D014
D015
D016
D017
Contaminant
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Endr in ( 1 , 2 , 3 , 4 , 10 , 10-hexachloro-l , 7-epoxy-
1,4, 4a ,5, 6,7,8, 8a-oc tahydro-1 , 4-endo , endo-
5 , 8-d ime thano-naph thalene )
Lindane (1,2,3,4,5, 6-hexa-chlorocyclohexane ,
gamma isoraer)
Methoxychlor (1,1, l-Trichloro-2 , 2-bis
[ p-me thoxypheny 1 ] e thane )
Toxaphene (C19H19Clg, Technical chlorinated
camphene, 67-69 percent chlorine)
2,4-D, (2,4-Oichlorophenoxyacetic acid)
2,4,5-TP Silvex (2,4,5-Trichlorophenoxy-
per liter)
5.0
100.0
1.0
5.0
5.0
0.2
1.0
5.0
0.02
0.4
10.0
0.5
10.0
1.0
                propionic acid)
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     Like other test procedures employed to identify hazardous character-
istics, the EP test is intended to serve as a quick means of identifying
wastes that are capable of posing a substantial present or potential hazard to
human health and the environment when improperly managed.  Consequently, in
devising the test, EPA necessarily had to make certain assumptions about
improper management processes to which toxic wastes capable of contaminating
ground water are likely to be subjected. For purposes of modeling EP toxicity,
EPA assumed co-disposal of toxic wastes in an actively decomposing municipal
landfill overlying a ground water aquifer.  This is a relatively conservative
assumption, given that municipal landfills are characterized by rapidly
decomposing wastes, which tends to generate more aggressive leaching than can
be found in other landfills.

     As part of BSVA, EPA is required to reconsider the EP toxicity test with
respect to two perceived shortcomings.  The first shortcoming is the limited
number of contaminants addressed by the EP toxicity test (see Table 2-1).  The
second shortcoming concerns the fact that the existing EP test was optimized
to evaluate the leaching of elemental rather than organic constituents.  On
June 13, 1986, EPA published a notice in the Federal Register (51 FR 21648)
which proposed the following amendments to the EP toxicity characteristic:
expanding the characteristic to include 38 additional compounds;, applying
compound specific dilution/attenuating factors (as opposed to a constant
dilution factor of 100 to establish acceptable threshold levels for each
contaminant); and introducing a second leaching procedure, known as the
Toxicity Characteristic Leaching Procedure (TCLP) to address the mobility of
both organic and inorganic compounds.  EPA intends to replace the EP toxicity
test with the TCLP test.

2.2.2  Listed Hazardous Waste
     A waste is regulated and must be managed as a hazardous waste if  it is
listed in 40 CFR Parts 261.31-261.33 (see Appendix A-l).  If a waste appears
on any of these lists, it is a regulated hazardous waste, regardless of
whether or not it displays the hazardous waste characteristics described
above.  Hazardous wastes may be listed as "toxic," "acutely hazardous," or
because they exhibit one or more of the hazardous waste characteristics.  A
brief explanation of each of these terms is provided below.
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     Solid wastes are  listed as  toxic hazardous wastes  (hazard  code  'T')  if
they contain a  toxic constituent  from Appendix VIII and pose a  substantial or
potential threat to human health  and the environment upon  consideration of
multiple factors that  appear in  §261.11(a)(3).  Appendix VIII constituents,
known as "hazardous constituents," are pollutants which have toxic,  carcino-
genic, mutagenic, or teratogenic  effects on humans or other life  forms.
(Appendix VIII  appears as Appendix A-2 of  this document).  The  presence of any
of these constituents  in the waste is presumed to be sufficient to list the
waste unless EPA concludes  that  the waste  is not hazardous, after considera-
tion of the following  factors:   the type of toxic threat posed; the  concentra-
tions of the constituents in the  waste; the migration, persistence,  and
degradation potential  of the constituents; the degree to which  the constitu-
ents bioaccumulate in  ecosystems; the plausible types of improper management
to which the waste could be subjected; the quantities of waste generated; and
other factors,  including damage  incidents  involving wastes containing  the
constituents and actions taken by other governmental agencies with respect to
the waste or its toxic constituents.

     Acutely hazardous wastes ('R')» in contrast, are listed because they may
"cause or significantly contribute to an increase in serious, irreversible, or
incapacitating  reversible,  illness" even vhen managed properly  (emphasis
added).

     Solid wastes may  also be listed as hazardous wastes if they exhibit one
or more of the  hazardous waste characeristics.  Any waste may be listed as EP
toxic ('E') if  it contains certain concentrations of heavy metals or pesti-
cides after performing the Extraction Procedure (EP) test prescribed in
§261-24.  Wastes may also be listed for exhibiting the hazardous character-
istics of ignitability ('!')» corrosivity  ('C') or reactivity ('R').

     Constituent(s) which caused  EPA to list a waste as EP toxic ('E') or
toxic ('T'). appear in  Appendix VII of Part 261 of the the RCRA regulations.
Appendix VII appears as Appendix  A-3 of this document.  There is a significant
overlap between the CVA priority  pollutant list and the Appendix VIII list of
hazardous constituents.  Many of  the priority pollutants have been used as a
basis for listing wastes and thus appear in Appendix VII as well.
                                     2-11

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     The listed wastes are subcategorized into four separate categories:


     •  Hazardous vastes from nonspecific sources — These wastes are gen-
        erated by activities that are not specific to a particular industry or
        process.  For example, spent degreasing solvents are listed as
        hazardous wastes.  Vastes listed in this manner appear on the "F" list
        in Appendix A-l.

     •  Hazardous wastes from specific sources — These include wastes
        generated by a specific product process by a particular industry, such
        as emission control dust/sludge from secondary lead smelting (K069).
        They appear on the "K" list in Appendix A-l.

     •  Acutely hazardous commercial chemical products, off-specification
        species, container residues, and spill residues — These wastes are
        acutely hazardous and include discarded chemical products manufactured
        or formulated for commercial or manufacturing use, and which consist
        of the commercially pure grade of the chemical, any technical grades
        of the chemical that are produced or marketed, and all formulations in
        which the chemical is the sole active ingredient.  These wastes were
        listed to account for all acutely toxic chemical products that are
        sometimes thrown away in pure or diluted form.  Reasons for discarding
        these materials might be that the materials do not meet required
        specifications, inventories have been changed, or the product line has
        been altered.  Vastes listed in this manner appear on the "P" list in
        Appendix A-l.

     •  Toxic commercial chemical products, of^specification species,
        container residues, and spill residues — Substances may be listed as
        hazardous because they are chronically toxic or they exhibit one or
        more of the characteristics of hazardous waste (ignitability, cor-
        rosivity, reactivity, or EP toxicity).  These wastes include chemical
        products manufactured or formulated for commercial or manufacturing
        use, and which consist of the commercially pure grade of the chemical,
        any technical grades of the chemical that are produced or marketed,
        and all formulations in which the chemical is the sole active ingred-
        ient.  Vastes listed in this manner appear on the "U" list in Appendix
        A-l.


     A generator who handles listed wastes may petition the Administrator to

have his waste "delisted."  The petitioner must demonstrate to EPA that his

waste is not hazardous.  To demonstrate this, the generator must provide

sampling and analytical data and detailed information on his waste management

procedures.  Further information on delisting can be found in Guidance

Petitions to Delist Hazardous Vastes (EPA/530-SV-85-003, April, 1985).
                                     2-12

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     If a waste does not appear on any of these lists, then the generator must

determine whether his solid waste exhibits any of the hazardous waste charac-
teristics, as described in Section 2.2.1.


2.2.3  Mixture Rule

     One of the questions that EPA faced when setting conditions for identify-
ing hazardous wastes was how to classify a waste mixture that was composed of

both a listed hazardous waste and a nonhazardous solid waste.  EPA decided

that any waste mixture containing a listed waste would be considered hazard-

ous, regardless of the proportion of the listed waste contained in the

mixture.  Consequently, if a POTV accepts a listed hazardous waste by truck,

rail, or dedicated pipeline, the resulting mixture of sludge and listed

hazardous waste is considered hazardous under RCRA.


      Vithout the mixture rule, generators could evade Subtitle C requirements
simply by comingling listed wastes with nonhazardous solid wastes.  Most of

these waste mixtures would not be captured by the four Subtitle C character-

istics because they would contain wastes that were listed for reasons other

than exhibiting the characteristics (e.g., they are acutely toxic).  There

are, however, two exceptions to the mixture rule:


     •  If an industrial wastewater discharge subject to regulation by the CVA
        is mixed with low concentrations of a listed waste, as specified in 40
        CFR Section 261.3(a)(2)(iv), the resultant mixture of specified
        pollutants is not considered a listed hazardous waste at certain
        concentrations.  For example, if carbon tetrachloride, tetrachloro-
        ethylene and/or trichloroethylene are mixed with an industrial waste
        subject to the pretreatment regulations (e.g., an electroplating
        wastewater), the mixture is not subject to the RCRA regulations
        provided that the maximum total usage of these solvents divided by the
        average weekly flow of wastewater into the headworks of the facility's
        pretreatment system does not exceed 1 part per million (40 CFR Part
        261.3(a)(2)(iv)(A)).  However, if such a mixture exhibits one of the
        characteristics, it is deemed hazardous.

    *•  Mixtures of nonhazardous wastes and listed wastes that are listed
        solely for exhibiting a hazardous waste characteristic are not
        considered hazardous if the mixture no longer exhibits any character-
        istics.  Only four wastes on the 'F' and 'K' lists are listed purely
        due to the fact that they exhibit a hazardous waste characteristic.
        They are:  spent nonhalogenated solvents exhibiting the ignilability
                                     2-13

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 . ;!                  characteristic (F003); and three separate vastestreams from the
 •>;                  explosives industry that exhibit reactivity (K044, K045, and K047).
 ;'                  Such exceptions may be subject to change.

            2.3  RCRA REGULATORY STATUS OF SELECTED WASTES THAT MAY BE RECEIVED BY POTWS
                 As can be seen from the above definitions of solid and hazardous wastes,
            determining whether or not a waste is subject to RCRA requirements is not
            always a straightforward exercise.  This section provides examples of wastes
            that POTV operators typically may encounter and discusses their regulatory
  .          status under RCRA.  In most cases, determination that a waste is hazardous
•;:          requires the operator to know:  (1) the source of the waste, and/or (2) the
 •;          waste's composition and characteristics.  As illustrated in Table 2-2, the
            wastes described below may or may not be hazardous.  The following discussion
            provides additional details on how an operator may determine the status of
            wastes received for treatment by truck, rail, or dedicated pipeline.  However,
            in most cases, the recommended controls discussed in Section 3 must be
            implemented to make an informed decision.
 i
            2.3.1  Selected Wastes

            2.3.1.1  Septage Wastes
                 Septage wastes delivered to FOTVs by truck, rail, or dedicated pipeline
            are regulated as solid wastes under RCRA.  However, septage wastes derived
            from household sources are specifically excluded from regulation as hazardous
.'.           wastes.  Household wastes include materials  (i.e., garbage, trash, and
 '_.           sanitary wastes in septic tanks) derived from households including single and
 .;:           multiple residences, hotels and motels, bunk houses, ranger stations, crew
 \           quarters, camp grounds, picnic grounds, and  day-use recreation areas.  On the
'-           other hand, septage wastes derived from nonhousehold sources, such as indus-
 :           trial septic  tanks, are regulated like any other solid waste under RCRA
            provisions and may meet the definition of hazardous waste.  In addition,
            household wastes mixed with hazardous waste  may meet the definition of
            hazardous waste via the mixture rule, as described in Section 2.2.3.

                 In managing septage wastes, a POTW should identify the possible  sources
            of  septage wastes  (see discussion on legal and administrative procedures in
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                    TABLE 2-2.  SUMMARY OF SELECTED WASTES
    Waste

Septage Wastes
Metal Finishing
Wastes
Spent Solvents

Pickle Liquor
Leachate,
Contaminated Ground
Water, and
Impoundment Wastes
Superfund Wastes
Small Quantity
Generator Wastes
Is it RCRA Hazardous?

Potentially




Potentially



Potentially

Potentially



Potentially
Potentially


Potentially
Used Oil
Potentially
Spill Residues
(including
transportation
spills)
Potentially
PCB Wastes

State Hazardous
Wastes
No

Potentially
          Determining Variables

•  Is it wholly or in part hauled from an
   industrial site?  If hauled, does it
   contain or has it been mixed vith listed
   or characteristic wastes?

•  Is it a listed metal finishing waste-
   stream?  If not, does it exhibit a
   hazardous waste characteristic?

•  Is it a listed spent solvent?

•  Is it accepted as waste or is it used as a
   wastewater conditioner?  Is it generated
   from the iron and steel industry?

•  Is it wastewater from a RCRA TSDF that has
   handled listed wastes?

•  If it is wastewater from a RCRA TSDF that
   has handled characteristic wastes only,
   does it exhibit a hazardous waste
   characteristic?

•  Was it determined to be a hazardous waste
   during Agency/State investigations?

•  Does the source facility generate more
   than 1 kilogram per month of acutely
   hazardous waste?

•  Does the source facility generate between
   100 and 1,000 kilograms per month of
   nonacutely hazardous waste?

•  Used oils intended for disposal which
   exhibit hazardous waste characteristics
   are hazardous.  Used oil intended for
   recycling is not considered a listed
   hazardous waste (51 FR 4190).
   Is the spilled material a
   waste?
listed hazardous
                          Does the spill residue exhibit a hazardous
                          waste characteristic?

                          Is it a cleanup residue of a spill of any
                          of the 400 commercial chemical products or
                          manufacturing chemical intermediaries
                          identified in RCRA?
•  Unless the waste is also considered
   hazardous under Federal RCRA regulations,
   receipt will not trigger Federal permit by
   rule requirements.
                                     2-15

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Chapter 3).  Septage wastes derived exclusively from household sources will
not trigger the POTV permit by rule requirements even if the septic wastes
include a listed hazardous waste or exhibit a RCRA hazardous characteristic.
When septage wastes are derived wholly or in part from nonhousehold sources,
such as industrial septic tanks, the wastes are regulated as any other solid
wastes, and may be deemed hazardous if the septage has been contaminated with
listed or characteristic wastes.  Accordingly, a POTW should exercise great
care in the management of septage wastes received by truck, rail, or dedicated
pipeline that it knows or suspects may originate from industrial sources.

2.3.1.2  Metal Finishing Wastes
     Many metal finishing wastes, especially those wastes containing cyanide,
are regulated as listed hazardous wastes under RCRA.  Examples of these wastes
include spent cyanide plating bath solutions, bottom sludges containing
cyanide, and wastewater treatment sludges from electroplating operations.
Table 2-3  is a partial listing of hazardous wastes that may be found in
electroplating operations.  Other listed wastes may appear in integrated
facilities.  In addition, some nonlisted metal finishing wastestreams.(e.g.,
rinse waters) may qualify as characteristic hazardous wastes due  to  the
presence of. metal constituent concentrations at levels exceeding  the criteria
for  the EP toxicity  characteristic.  Chapter 3 describes procedures  for making
determinations as to whether wastes received from metal finishers may  be
hazardous.

     Under the Clean Water  Act's general pretreatment program regulations  (40
CFR  Part 403), metal finishing  wastes  sent directly  to a POTW by  truck,  rail,
or dedicated  pipeline  also  must meet categorical pretreatment standards  (and
any  local  limits)  for  the metal finishing  industrial  category and prohibited
discharge  standards.   In view of  the  typical metal  concentrations found  in
metal  finishing  wastes,  this  requirement would  imply  pretreatment of the  waste
prior  to  its  delivery to  the  POTW.  Where  a  metal  finishing waste is diluted
or mixed  with other  wastes  at  the  manufacturing  facility,  a POTW would apply
 the  combined  wastestream  formula  (as  described  in  40  CFR Part 403.6) to
determine appropriate limits  for  discharge of  the  wastewater.   Pretreating
listed hazardous wastes  (e.g.,  spent  cyanide plating  bath  solutions) will not
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                   TABLE 2-3.   LISTED METAL FINISHING WASTES
Hazardous Vaste
    Number
 (Hazard Code)

    F006
    (T)
    F019
    (T)
    F007
    
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affect their status as hazardous wastes.  However, pretreating characteristic
wastes, such as highly concentrated metal laden rinse waters, may work to
improve the quality of the wastewater to a degree where it no longer displays
the relevant characteristic.  In this case, the wastewater is no longer
hazardous.

2.3.1.3  Spent Solvents
     Spent solvents are regulated as listed hazardous wastes under RCRA.
Accordingly, hauled wastes containing spent solvents must be handled as
hazardous wastes.  Spent solvent listings presently encompass 30 organic
compounds (see Table 2-4).  Several of these solvents are used widely by
manufacturing facilities for degreasing metal parts.  Discharge of spent
solvents from certain industrial sources, such as electroplating operations,
also may be regulated under categorical pretreatment standards for parameters
such as total toxic organics.  See Table 2-4 for the spent solvents listed as
hazardous wastes.

2.3.1.4  Pickle Liquor
     Most recycled materials are considered solid wastes by EPA, although some
of these materials are exempted from the definition of hazardous waste.  This
distinction depends on both the recycling activity and the nature of the
recycled material.  An example of a waste that may be sent to a POTV for
recycling is spent pickle liquor.

     Spent pickle liquor (a metal laden acid bath) from iron and steel
industry finishing operations is regulated as a listed hazardous waste.  Spent
pickle liquor from industrial operations other than the iron and steel
industry is not a listed hazardous waste.  However, these pickle liquors may
be hazardous if they exhibit one or more of the hazardous waste characteris-
tics.

     Where utilized as a wastewater conditioner (i.e., phosphorus removal,
sludge conditioner) in a POTtf, spent pickle liquor can be considered a
recycled material exempt from RCRA regulation.  Under RCRA provisions,
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                          TABLE 2-4.   LISTED SOLVENTS


Hazardous Waste                             Listed
   Number                              Hazardous Waste
 (Hazard Code)

    F001        The following spent halogenated solvents used in degreasing:
    (T)         tetrachloroethylene,  trichloroethylene, methylene chloride,
                1,1,1-trichloroethane, carbon tetrachloride, and chlorinated
                fluorocarbons; all spent solvent.mixtures/blends used in
                degreasing containing, before use, a total of ten percent or
                more (by volume) of one or more of the above halogenated
                solvents or those solvents listed in F002, F004 and F005;
                and still bottoms from the recovery of these spent solvents
                and spent solvent mixtures.


    F002        The following spent halogenated solvents:  tetrachloro-
    (T)         ethylene, methylene chloride, trichloroethylene, 1,1,1-
                trichloroe thane, chlorobenzene, 1,1,2-trichloro-
                1,2,2-trifluoroethane, ortho-dichlorobenzene, and tri-
                chlorofluoromethane;  and 1,1,2-trichloroethane; all spent
                solvent mixtures/blends containing, before use, a total of
                ten percent or more (by volume) of one or more of the above
                halogenated solvents  or those listed in F001, F004, or F005;
                and still bottoms from the recovery of these spent solvents
                and spent solvent mixtures.


    F003        The following spent non-halogenated solvents:  xylene,
    (I)         acetone, ethyl acetate, ethyl benzene, ethyl ether, methyl
                isobutyl ketone, n-butyl alcohol, cyclohexanone, and
                methanol; all spent solvent mixtures/blends containing,
                before use, only the  above spent non-halogenated solvents;
                and all spent solvent mixtures/blends containing, before
                use, one or more of the above non-halogenated solvents, and,
                a total of ten percent or more (by volume) of one or more of
                those solvents listed in F001, F002, F004, and F005; and
                still bottoms from the recovery of these solvents and spent
                solvent mixtures.

    F004        The following spent non-halogenated solvents:  cresols and
    (T)         cresylic acid, and nitrobenzene; all spent solvent
                mixtures/blends containing, before use, a total of ten
                percent or more (by volume) of one or more of the above non-
                halogenated solvents  or those solvents listed in F001, F002,
                and F005; and the still bottoms from the recovery of these
                spent solvents and spent solvent mixtures.


    F005        The following spent non-halogenated solvents:  toluene,
    (I,T)       methyl ethyl ketone,  carbon disulfide, isobutanol, pyridine,
                benzene, 2-ethoxyethanol, and 2-nitropropane; all spent
                solvent mixtures/blends containing, before use, a total of
                ten percent or more (by volume) of one or more of the above
                non-halogenated solvents or those solvents listed in F001,
                F002, or F004; and still bottoms from the recovery of these
                spent solvents and spent solvent mixtures.


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materials are not solid wastes vhen they can be shown to be recycled by being
employed in a particular function or applied as an effective substitute for a
commercial product.  Accordingly, permit by rule requirements will not apply
to truck, rail, and dedicated pipeline discharges consisting solely of spent
pickle liquor from iron and steel facilities used for wastewater treatment at
a POTV.  However, spent pickle liquor from iron and steel facilities received
at POTVs would be considered hazardous if the material was not being applied
as a part of the wastewater treatment operation.

2.3.1.5  Leachate, Contaminated Ground Water, and Impoundment Vastes
     Facilities that treat, store, or dispose of RCRA regulated hazardous
wastes may generate hazardous waste residuals as a result of normal operations
or due to unusual situations (e.g., facility closure requirements).  Examples
of such residuals are leachates, contaminated ground water, and surface
impoundment wastes.  The regulatory status of these aqueous waste residuals is
determined by the types of waste handled at the TSDF generating the residual
wastewater.  Vhen the wastewater is derived from the treatment, storage, or
disposal of a listed waste at a RCRA TSDF, the residual waste also is regu-
lated as a listed hazardous waste.  However, where a mixture of ground water
and listed leachate waste can be rendered non-hazardous by treating the
mixture to remove the leachate,  the ground water is not considered a listed
hazardous waste.  Where the waste originates from the treatment, storage, or
disposal of a characteristic waste at a RCRA TSDF, the residual is hazardous
only it it exhibits one of the hazardous waste characteristics.  In accordance
with RCRA requirements, the generator is responsible for determining whether a
solid waste is hazardous.  Thus, if a POTW receives, and plans to accept, an
unmanifested aqueous waste from a RCRA TSDF, a prudent approach would be to
verify that it is not hazardous by obtaining accurate information concerning
the types of solid and hazardous wastes managed at the TSDF generating the
wastes.  The POTW operator also may want to conduct independent verification
by sampling and inspections (see Section 3.3).

     The regulatory status of residual waste from solid waste management
facilities, such as sanitary landfills, also is determined by the types of
waste managed at the facility.  Under the RCRA exclusion for household wastes,
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household vastes and  residuals  resulting  from  the  treatment, storage,  and
disposal of household waste are exempt  from regulation as hazardous waste.
Accordingly) where a  leachate or other  residual wastewater originates  from  a
solid waste management  facility managing  only  household wastes,  the wastewater
is exempt from regulation as hazardous  waste.  Where  the facility also accepts
nonhousehold wastes such as industrial  or commercial  wastes, the residual
wastewater may be deemed hazardous  if it  exhibits  any characteristic of a.
hazardous waste.  Consequently, POTVs may want to  evaluate whether leachate
and other wastewaters from solid waste  management  facilities (known or
believed to be managing industrial  or commercial wastes) test  for possible
hazardous characteristics, especially EP  toxicity.  See Section  3.3 for
recommended methods for determining testing requirements.

2.3.1.6  Superfund Vaste
     Cleanup of Superfund sites by  Federal, State, and private parties
frequently results in the generation of aqueous wastes such as leachate,
contaminated ground water, impoundment  wastes, and other wastewaters.   Where
delivered to a POTW by  truck, rail,  or  dedicated pipeline, some  Superfund
wastes may be hazardous as defined  by RCRA, and therefore may  trigger  permit
by rule requirements  for the POTW managing the waste.  Substances found most
often at Superfund sites include:   trichloroethylene, lead, toluene, benzene,
PCBs, and chloroform.   Wastes from  Superfund sites can contain many other
substances as well, depending on site-specific characteristics.  Before
accepting wastes from Superfund sites,  POTW operators should ascertain from
the EPA/State whether the waste is  hazardous and should ensure that any
'necessary local pretreatment requirements are  established and  will be  met in
accordance with 40 CFR  Part 403.

2.3.1.7  Small Quantity Generator Waste
     It is estimated  that 630,000 facilities in the Nation generate less than
1,000 kilograms of hazardous waste  per  month.  Historically, these small
quantity generators (SQGs) have been subject to less  stringent RCRA disposal
requirements than other generators.  However,  regulations recently promulgated
by EPA have significantly tightened  these SQG  requirements.  Nevertheless,
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POTVs should be aware that receiving some wastes that might otherwise trigger
the RCRA permit by rule requirements for the POTW will not trigger those
requirements if the waste originated exclusively with certain SQGs.

     Uhen EPA originally promulgated the SQG regulations in May 1980, the
exclusion level was set at 1,000 kilograms per month of hazardous waste with
the understanding that EPA later would expand the SQG requirements to include
facilities generating between 100 and 1,000 kilograms of hazardous waste per
month.  Pursuant to a mandate in the 1984 HSVA amendments to review and
establish regulations for SQGs that generate 100-1,000 kilograms per month,
EPA promulgated a second set of regulations, effective September 22, 1986,  to
strengthen controls on the management of SQG wastes.

     For regulatory purposes, three classes of SQGs have been distinguished:

     •  Generators of less than 1 kilogram per month of acutely hazardous
        waste ('H' hazard code wastes)
     •  Generators of less than 100 kilograms per month of nonacutely hazard-
        ous wastes ('T' hazard code wastes)
     •  Generators of between 100 and 1,000 kilograms per month of nonacutely
        hazardous wastes  ('T' hazard code wastes).

The first two categories  of  SQGs are conditionally exempt SQG's, subject  to
the following minimal hazardous waste disposal requirements:  hazardous waste
determination,  storage restrictions, and disposal at a state-approved solid
waste management or recycling facility.  Under RCRA permitting regulations,
any facility  that  treats, stores, or disposes of these conditionally exempt
SQG wastes  (i.e.,  less than  1 kilogram  per month acutely hazardous wastes  or
100 kilograms per  month nonacutely hazardous waste) is not required  to  obtain
a  RCRA  permit.  Accordingly,  those conditionally exempt SQG wastes will not
trigger POTW  permit by rule  requirements.

      The  third  category of  SQGs generate between 100 and  1,000 kilograms  per
month of  nonacutely hazardous waste.  They must comply with more comprehensive
generator requirements, including hazardous waste determination, notification,
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onsite storage restrictions, disposal at a Subtitle C facility, compliance
with DOT requirements, and manifesting.  Under RCRA permitting regulations,
facilities managing these SQG wastes (i.e., betveen 100 and 1,000 kilograms
per month of nonacutely hazardous waste) must obtain a RCRA TSDF permit.
Consequently, such SQG wastes delivered to a POTV by truck, rail, or dedicated
pipeline will trigger POTV permit by rule requirements.  POTWs that receive
these SQG wastes by truck, rail, or dedicated pipeline should obtain accurate
information on the types and quantities of hazardous wastes generated by these
facilities.  See Table 2-5 for a list of common SQGs generating hazardous
wastes in this volume category.

     A transporter may conduct "milk runs'1 of conditionally exempt SQG wastes
from several generators, none of whom contribute enough waste to trigger
comprehensive RCRA requirements, including the requirement that the waste be
treated, stored, or disposed of at a RCRA TSDF.  If a POTV receives such
waste, even if the total amounts to greater than 1,000 kilograms, permit by
rule requirements would not be triggered.  (Nevertheless, the POTV should take
precautions to ensure that acceptance of such wastes by the POTV will not
cause pass through or interference under the Clean Water Act's pretreatment
program.)

2.3.1.8  Used Oil
     As defined by RCRA statutory provisions, used oil is any oil that has
been refined from crude oil, used and, as a result of such use, contaminated
by physical or chemical impurities.  Used oils include:  (1) spent automotive
lubricating oils (including car and truck engine oil), transmission fluid,
brake fluid, and off-road engine oil; (2) spent industrial oils, including
compressor, turbine, and cleaning oils, hydraulic oils, metal working oils,
gear oils, electrical oils, refrigerator oils, and railroad drainage; and
(3) spent industrial process oils.  Under current RCRA provisions, used oils
intended for recycling, including those exhibiting any hazardous waste
characteristic, are exempt from RCRA hazardous waste generator, transporter,
treatment, storage, and disposal regulations.  EPA has decided not to list
                                     2-23

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          TABLE  2-5.  ESTIMATED NUMBER OF SMALL QUANTITY GENERATORS
                       (100 KG TO 1,000 KG/MONTH) BT INDUSTRY GROUP*1'
                                                           Number of
    Industry Group                                         Generators
Pesticide End Users                                              231
Pesticide-Application Services                                 1,660
Chemical Manufacturing                                           391
Wood Preserving                                                  107
Formulators                                                      395
Laundries                                                      2,515
Photography                                                    2,817
Textile Manufacturing                                            124
Vehicle Maintenance                                           82,528
Equipment Repair                                                 269
Metal Manufacturing                                .           11,076
Construction                                                   1,117
Motor Freight Terminals                                           45
Furniture/Vood Manufacture and Refinishing                       579
Printing/Ceramics                                              3,420
Cleaning Agents and Cosmetic Manufacturing                       265
Other Manufacturing                                              946
Paper Industry                                                    83
Analytical and Clinical Laboratories                           1,286
Educational and Vocational Establishments              .          241
Wholesale and Retail Establishments                          .    575
TOTAL                                                        110,677
UlSource:  National Small Quantity Hazardous Waste Generator Survey,
   ABT Associates, Inc., February 1985.
                                     2-24

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used oil that is intended to be recycled.  Unless EPA decides to list used oil
as a hazardous waste, only used oils that exhibit a hazardous waste character-
istic and are intended for disposal are considered hazardous wastes.

     Used oils are frequently contaminated with metals (e.g., lead, arsenic,
cadmium, chromium), solvents (e.g., trichloroethylene 1,1,1-trichloroethane,
tetrachloroethylene), and other hazardous constituents (e.g., naphthalene,
toluene, phenol) that are naturally occurring in petroleum-derived and
synthetic oils.

     Some generators have been known to mix hazardous wastes with used.oils to
disguise the status of the waste.  As described in Section 2,2.3, mixtures of
hazardous and nonhazardous wastes may qualify as hazardous wastes.  Thus,
operators should be sure to determine the source of used oils before receiving
them for storage, treatment, or disposal.  See Chapter 3 for further informa-
                                                  x
tion on source identification and control.

2.3.1.9  Spill Residues (Including Transportation Spills)
     Cleanup residues resulting from spills of hazardous wastes handled by
generators, transporters, or TSDFs may be deemed hazardous wastes under RCRA.
In the case of a listed hazardous waste that is spilled, spill residues will
be considered listed hazardous wastes unless specifically delisted by EPA.
In the case of a characteristic hazardous waste, a spill residue will only be
hazardous if it continues to exhibit a characteristic of a hazardous waste.
RCRA hazardous waste regulations also may apply to cleanup residues resulting
from the spill on land or water of any of approximately 400 commercial
chemical products or manufacturing chemical intermediates identified in RCRA
regulations.  Accordingly, spill residues from truck, rail, pipeline, barge,
or onsite industrial accidents involving raw materials may be regulated as
listed hazardous wastes depending on the chemical involved in the accident
(40 CFR Part 261.33). Where delivered to a POTV by truck, rail, or dedicated
pipeline, these spill residues, including contaminated wastewaters, may
trigger POTV permit by rule requirements.
                                     2-25

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            2.3.1.10  PCB Wastes
                 PCB wastes are not regulated under existing RCRA hazardous waste re-
            gulations.  Instead,  these wastes are regulated under the Toxic Substances
            Control Act (TSCA) and 40 CFR  Part 761, which establishes storage and disposal
            restrictions on materials containing PCBs at concentrations greater  than or
            equal  to 50 parts per million  (ppm).  Consequently, unless a PCB-laden waste
            can  be considered hazardous  due  to some attribute other  than the presence of
            PCBs (e.g., presence  of solvents), the waste will not trigger RCRA permitting
            provisions.

            2.3.1.11  State Hazardous Wastes
                 Some States regulate wastes as hazardous under State hazardous  waste laws
            that are not regarded as hazardous wastes under Federal  RCRA regulations.
            For  example, 16 States consider  PCBs as hazardous wastes, 12 States  list used
            oil  as hazardous, and others list specific  contaminants  or have additional
            characteristic  tests. Even  where delivered to a POTV by truck, rail, or
            dedicated pipeline,  these wastes do not  trigger Federal  POTV permit  by  rule
            provisions  since  they are not  considered  to be hazardous under Federal  law.
            Nonetheless, POTV acceptance of  these wastes may trigger individual  State
            hazardous waste permit  requirements or  analogous permit  by rule provisions
            under  State law.
;                                                  2-26
i

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     3.  RESPONSIBILITIES OF POTWs CHOOSING NOT TO ACCEPT HAZARDOUS WASTE

     If a POTV accepts hazardous wastes via truck, rail, or dedicated pipe-
line, it will be required to comply with RCRA permit by rule provisions.
Chapter 4 discusses the responsibilities of POTVs that receive hazardous
wastes by these transportation methods.  This chapter describes steps POTVs
may undertake to preclude acceptance of RCRA regulated wastes.

     The most direct method of precluding the receipt of hazardous waste by
truck, rail, or dedicated pipeline is  to prohibit the delivery of any wastes
via these methods and to enforce such  a prohibition.  This may not be a
desirable or feasible approach, however, especially if a POTV services a
community where septage wastes are generated.

     A second way POTVs may preclude the delivery of hazardous wastes is by
specifically prohibiting the discharge of hauled industrial wastes, thus
limiting the receipt of hauled waste to only household wastes.  As discussed
in Chapter 2, household wastes are specifically exempted from the definition
of hazardous waste.  However, even under these circumstances, POTVs run the
risk of receiving hazardous wastes as  unscrupulous septage haulers may mix
hazardous and household wastes.

     POTVs that agree to accept hauled wastes from industrial users face
additional challenges in precluding the receipt of hazardous wastes, given
that some industrial wastes may be considered hazardous.  Should POTVs accept
hauled industrial wastes, they must ensure that the wastes meet all applicable
pretreatment standards (e.g., local limits, prohibited standards, categorical
standards) before discharge is allowed.  Section 4.3 of this guidance dis-
cusses the responsibilities of POTVs for ensuring that hauled wastes comply
with pretreatment program requirements and standards.

     This chapter discusses how a POTV can develop and implement both regula-
tory and administrative mechanisms to  preclude the discharge of hazardous
wastes to its treatment plant via truck, rail, or dedicated pipeline.
                                     3-1

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Further, this chapter discusses hov to develop and implement a vaste moni-
toring plan that a POTV can use to characterize vastes received by truck,
rail, or dedicated pipeline.

3.1  DESCRIPTION OF POTENTIAL LIABILITIES FOR POTVS ACCEPTING HAZARDOUS WASTE
     The receipt of hazardous vastes imposes certain responsibilities on a
facility.  Even if a POTV chooses not to accept hazardous vastes discharged
via truck, rail, or dedicated pipeline, the POTV is not necessarily absolved
from potential RCRA and Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA), otherwise knovn as "Superfund," liabilities.
POTVs may be subject to these liabilities vhether or not they are avare of the
receipt of hazardous vastes.  POTVs also may be liable under RCRA and CERCLA
for any past releases of hazardous vastes, hazardous constituents, or hazard-
ous substances to the environment.  The definition of "release" under CERCLA
is extremely broad and may encompass any "spilling, leaking, pouring, emit-
ting, emptying, discharging, injecting, escaping, leaching, dumping, or
disposing into the environment ..."  The RCRA definition of release for the
RCRA corrective action program (see Section 4.5) is at least as broad as the
CERCLA definition.

     Receiving hazardous vastes by truck, rail, or dedicated pipeline without
a RCRA permit or, in a POTV's case, vithout regard to permit by rule condi-
tions, can lead to enforcement action under RCRA.  If a POTV receives hazard-
ous vaste vithout complying vith the permit by rule conditions, it may be
subject to both criminal and civil penalties.  For example, violations of RCRA
requirements can result in fines of up to $25,000 per day per violation.
POTVs must realize that enforcement actions against noncompliant POTVs can be
taken vhether or not the POTV operator vas avare that the vaste received by
truck, rail, or dedicated pipeline vas a hazardous vaste.  Consequently, to
minimize its liability, it is important that a POTV take steps to discover
vhether it is receiving hazardous vaste by these transport methods.  In
addition, a POTV conducting a responsible, veil designed program to preclude
the receipt of hazardous vastes by truck, rail, or dedicated pipeline,
although strictly liable under RCRA, vould be demonstrating good faith.  This
could shift the equities and help reduce POTV liabilities resulting from the
receipt of such vastes.
                                      3-2

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     Both RCRA and CERCLA impose potential liabilities on facilities that
handle, or have handled, hazardous vastes.  These responsibilities include
corrective measures designed to address releases of hazardous vastes, hazard-
ous constituents, or hazardous substances to the environment that result in a
threat to human health and the environment.  A more detailed discussion of
RCRA corrective action requirements, which encompasses the cleanup of releases
of hazardous vastes and constituents, appears in Section 4.5.

     Finally, a hazardous vaste generated by an industrial user and received
by a POTV by truck, rail, or dedicated pipeline, is subject to applicable pre-
treatment standards (i.e., Federal, State, and/or local standards).  Although
the industrial user is responsible for ensuring that all pretreatment stan-
dards are met, enforcement actions can be taken against a POTV vith an
approved pretreatment program under the CVA if it fails to 'implement its
pretreatment program by not enforcing applicable standards against the
industrial user.  In addition, because a permit by rule requires compliance
vith the pretreatment regulations, if the POTV accepts a hazardous vaste from
an industry that is not in compliance vith pretreatment standards the POTV may
also be in violation of its RCRA permit by rule requirements (see Section
4.3).

     As explained in the above discussion, although there are no express legal
requirements under RCRA/CERCLA for POTVs to adopt programs to preclude the
receipt of hazardous vastes, the liabilities associated vith unknowing
acceptance act as an incentive to develop such a program.

3.2  CONTROL MEASURES TO PREVENT DISCHARGES OF HAZARDOUS VASTE TO POTVS
     POTVs can use regulatory and administrative control mechanisms such as
ordinances, permits, contracts, physical barriers, and vaste tracking systems
to prohibit the discharge of hazardous vastes to their treatment plants via
truck, rail, or dedicated pipeline.  These regulatory and administrative
control mechanisms also can be used by POTVs to restrict or oversee the
discharge of any nonhazardous vastes by truck, rail, or dedicated pipeline
that may be of concern to the POTV.  This section discusses these control
mechanisms and the benefits and dravbacks associated with their use, and
                                      3-3

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provides examples of how some POTVs have integrated these different mechanisms
into a successful control strategy.

     This section refers predominantly to the control of wastes delivered by
truck, which is the most likely means by which a POTV would receive a hazard-
ous waste.  Many of these same control measures can also be used to control
wastes received by rail.  However, they may not be applicable to wastes
received by dedicated pipeline.  A dedicated pipeline refers to a separate
pipeline that is used to carry hazardous wastes directly to a POTV's property
boundary without prior mixing with domestic sewage.  To ensure that a POTV
does not receive hazardous wastes from a dedicated pipeline, a POTV would need
to apply strictly the control measures used in its pretreatment program (i.e.,
issuance of local user permits, sampling and inspections, etc.) to those
industrial users that discharge to a pipeline that does not receive domestic
sewage.  Therefore, the POTV will need to determine if hazardous wastes are,
or are likely to be, discharged via a dedicated pipeline to the POTV.  Section
3.3 provides further guidance on generator audits, which could be used to
assist in this determination.
                                  •
3.2.1  Regulatory Control Mechanisms

3.2.1.1  Applicable Pretreatment Controls
     The National Pretreatment Program is designed to protect municipal
wastewater treatment plants from the potential adverse effects of industrial
discharges.  Specific goals of this program are to:

     •  Prevent interference with POTV operations that could result from the
        introduction of pollutants that are toxic'or inhibitory to the
        treatment process.
     •  Prevent the pass through of pollutants to the receiving water.
        Pollutants that are incompatible or otherwise unaffected by the
        treatment processes could have an adverse environmental impact on the
        receiving water body.
     •  Preserve and improve sludge quality so that the chosen method of
        sludge disposal can be continued and the possibility of more attract-
        ive sludge reuse and recycle' options can be enhanced.
                                      3-4

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All industrial users discharging to POTVs are subject to National Pretreatment
Program requirements and standards, as set forth in the General Pretreatment

Regulations (40 CFR Part 403).  About 1,500 municipalities (POTVs) have been

required by EPA or authorized States to develop local pretreatment programs,

in pursuit of these goals, to manage and effectively control all nondomestic

wastes discharged to, and subsequently treated by, their treatment system.

Where POTVs were not required to develop local pretreatment programs, they

must still meet certain minimum pretreatment requirements and EPA or States

with approved pretreatment programs must apply and enforce certain other

applicable pretreatment standards and requirements (e.g., national

pretreatment standards for regulated industry categories).


     Every component of a local industrial pretreatment program that applies

to piped industrial vastes vould also apply to hauled wastes.  This section

discusses many of these components.  (If a POTV is not required to develop and

obtain approval of a local pretreatment program, but is concerned about

receiving hazardous waste by truck, rail, or dedicated pipeline, within the

POTV property boundary, it may wish to establish such a program voluntarily.)

There are several aspects of local pretreatment programs that may need to be

modified to ensure adequate control over hauled wastes, including:


     •  Sewer use ordinance — Many sewer use ordinances will address the
        discharge of waste from septage trucks.  In many cases, these
        regulations and references may be vague and provide only minimal
        controls.  A general ordinance should state that the discharge of
        hazardous waste by septage haulers is prohibited.  Specific ordinance
        changes should include clear definitions of hazardous, industrial, and
        domestic wastes geared toward the type of industrial users making use
        of the POTV so that no ambiguity exists with respect to the intent or
        applicability of the ordinance.  Section 3.2.2 provides further
        guidance regarding sewer use ordinance provisions for waste received
        by truck, rail, or dedicated pipeline.

     •  Multijurisdictional arrangements — As per 40 CFR Part 403.8(b)(l), a
        POTV must be able to enforce against all individual users making use
        of the treatment system.  Vhile it is recognized that developing such
        an arrangement with a user outside the jurisdictional boundaries of
        the POTV may be difficult, the requirements of 40 CFR Part 403.8(b)(l)
        must be satisfied.  The POTV must enter into an arrangement with the
        industry to allow for the extension of the POTV's legal authority to
        inspect and sample at the generating facility, take enforcement
        action, and require remedies consistent with the receiving POTV's
        sewer use ordinance and pretreatment program.
                                      3-5

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     •  Control mechanisms — The POTV should require discharge permits for
        generating industries and operating permits for waste haulers.  Local
        sever use ordinances (and in some cases State lav) may need to be
        amended to extend POTV authority to issue these permits.  Section
        3.2.3 discusses in detail the provisions necessary for development of
        a control mechanism for waste haulers.

     •  Compliance sampling and inspections — The POTV's compliance program
        must ensure industry compliance vith local and applicable Federal
        standards and requirements.  Generators of industrial vastes could be
        inspected vith the same frequency as other significant or categorical
        industrial users.  These inspections should verify information
        submitted by the industry on permit application forms, baseline
        monitoring reports, compliance schedules, and self-monitoring reports.
        Each inspection should cover vaste hauling records and manifests,
        providing sufficient information to account for all vastes generated
        since the previous inspection.  If the industry is subject to categor-
        ical standards and the combined vastestream formula is used, or if
        solvent management plans are employed, actual industry practices must
        be verified.

      Sampling and analysis should be undertaken consistent vith EPA proce-

dures (40 CFR Part 136) and analysis must be performed for at least all

regulated pollutants.  All inspection and sampling events must be documented

properly to ensure admissibility in possible legal actions.  POTVs should take

special care vhen sampling hauled vastes.  Primary concerns are unrepresenta-
tive samples due to partitioning in the tank truck (solids vill settle, and

organics may float), and possible safety concerns due to toxic fumes that

could build up in the tank head space.  Changes in the sampling and analysis

procedures may be necessary to ensure adequate coverage of hazardous vaste.

Section 3.3 provides further guidance on the monitoring of hauled vastes.


3.2.1.2  Other Regulatory Control Mechanisms

     POTVs may use regulations or ordinances to prevent discharges or deliver-

ies of hazardous vaste to their treatment facilities by truck, rail, or
dedicated pipeline.  Most communities already have sever use ordinances to

regulate the use of publicly ovned severs.  Prohibitions on discharges by

truck, rail, or dedicated pipeline vithin the POTV boundary can be

incorporated easily into most sever use ordinances.
                                      3-6
     • 'ir '

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     To prevent truck, rail, or dedicated pipeline discharges of hazardous
waste to its facility, a POTW could incorporate a prohibition on such dis-
charges into its ordinance.  There are at least three major degrees of regu-
latory control alternatives that can be implemented by the POTW to improve the
implementation of this prohibition.  These are:  prohibiting the discharge of
all hauled wastes (including septage); prohibiting the discharge of wastes
from industrial sites; and prohibiting the discharge of wastes containing
industrial wastes.  In considering these alternatives, the POTW may want to
reserve the option of accepting hazardous wastes under well defined circum-
stances, e.g. receipt of contaminated leachate from a local CERCLA site.  A
summary description of these three supplementary control alternatives appears
in Table 3-1, along with a short description of advantages and disadvantages.
The discussion below expands upon the tabular explanation.

     •  Prohibiting All Wastes Discharged to a POTW by Truck, Rail, or
        Dedicated Pipeline
     Sewer use ordinances (or equivalent POTW use and treatment rules) for
POTWs that want to ensure that they will not receive discharges of hazardous
waste by truck, rail, or dedicated pipeline could set forth explicit pro-
hibitions for discharges to the POTW through any means other than normal sewer
connections.  This type of local ordinance prohibition would be the most
effective way for a POTW to ensure that hazardous wastes are not knowingly
discharged to their collection or treatment system because all hauled wastes,
including septage, industrial hazardous wastes, and mixed wastes would be
prohibited from being discharged.  Appendix B provides example language that
a POTW may wish to include in its local sewer use ordinance to prohibit the
discharge of all hauled wastes.  In addition to being the most effective way
to preclude hazardous waste discharges, strict prohibitions on all hauled
wastes do not require implementation of administrative controls (as described
in Section 3*2.3).  However, such a prohibition is not always practical or
desirable.
                                      3-7

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                TABLE 3-1.  RECOMMENDED REGULATORY MECHANISMS FOR PREVENTING
                            DISCHARGES OF HAZARDOUS WASTE BT TRUCK, RAIL, OR
                            DEDICATED PIPELINE TO THE FACILITY BOUNDARY
Regulatory Control Mechanisms

 Prohibit all truck, rail, and
 dedicated pipeline discharges to
 the POTW
    Advantages

Most protective method
of avoiding reception
of hazardous wastes

No administrative
controls are required
for implementation
  Disadvantages

May conflict vith nee<
to serve nonsewered .
communi ty
                    i!t

May create incentives
for illegal midnight
dumping
 Prohibit discharge of all hauled
 industrial wastes
 Prohibit discharge of  industrial
 process wastes only
Provides service to
residential community

Protects against
discharge of hazardous
industrial wastes
Allows service of
domestic type sewage '
from industrial  .
facilities
Industrial wastes may
be surreptitiously
mixed with residentia
wastes

Suggests need for
stringent
administrative and
waste monitoring
control
                                                                   Industrial process
                                                                   wastes may be
                                                                   illegally mixed with
                                                                   domestic type sewage

                                                                   Suggests need for
                                                                   administrative and
                                                                   waste monitoring
                                                                   controls
                                    3-8

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     •  Prohibiting Wastes from Industrial Sites Discharged to a POTV by
        Truck, Rail, or Dedicated Pipeline
     For many POTVs, prohibiting all hauled wastes from being discharged to
either its treatment system may be infeasible.  Certain sections of a POTW's
service area may not be connected to the POTW treatment system, and many
domestic and/or industrial customers may still need to use septic tank
systems.  These POTVs should consider only accepting hauled wastes from
domestic sources and prohibiting hauled wastes from industrial sites.
Provisions to this effect could be included in local sewer use ordinances.
Appendix B provides example language that a POTV may wish to include in its
local sewer use ordinance to prohibit the discharge of hauled wastes from
industrial sites.

     The benefit of this approach is that POTVs can be relatively confident
that a hazardous waste will not be received, since, as explained in- Section
2.3, household wastes, such as domestic septage, are specifically exempted
from the definition of hazardous waste.  However, since the POTV still would
be accepting hauled wastes, it also should implement an administrative control
mechanism (see Section 3.2.3), in addition to ordinance prohibitions and
restrictions, to ensure that only wastes from domestic sources are delivered
and discharged to the POTV.  This is especially important in light of the fact
that mixtures of domestic and hazardous wastes could be considered hazardous
(see discussion of mixture of listed and characteristic wastes in Section
2.2).

     •  Prohibiting Industrial Process Vastes Discharged to a POTV by Truck,
        Rail, or Dedicated Pipeline
     It may not be feasible or desirable for a POTV to prohibit the discharge
of hauled domestic type wastes generated at industrial facilities.  However,
to ensure that hazardous wastes are not contained in wastes hauled from
industrial facilities, a POTV can specifically prohibit the delivery and
discharge of industrial process wastes, spill residues, etc.  This type of
control can be contained in local sewer use ordinances, which can be amended
to prohibit specifically the discharge of hauled industrial wastes.  Appendix
B contains example language that a POTV may wish to include in its local sewer
                                     3-9

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use ordinance to prohibit the discharge of hauled industrial waste.  As
industrial hazardous wastes may be mixed with domestic type wastes that are
hauled from an industrial facility, it is strongly recommended that a POTV
also implement administrative controls to enforce applicable sewer user
ordinance provisions.

3.2.2  Administrative Controls
     Administrative controls can allow POTVs to place specific restrictions
on businesses involved in generating or transporting nondomestic wastes.
Specifically, these controls can assist a POTV in ensuring that hazardous
wastes are not being discharged to its treatment system, thus avoiding
liabilities under RCRA.  In addition, implementation of these administrative
controls by a POTV can assist in protecting treatment plant operations.  For
example, a POTV may wish to restrict metals concentrations in hauled waste to
protect the sludge quality.  Similarly, accepting volatile solvents may create
interference with biological treatment systems or cause explosive hazards at
the plant.  The following sections describe five types of administrative
controls that can be used by POTVs to oversee the discharge of hauled wastes.
These controls include the use of permits, a waste tracking system, physical
restrictions, surveillance, and inspections and sampling.  A listing of these
administrative control mechanisms appears in Table 3-2.  A discussion of
inspection and sampling methods appears in Section 3.3.  Although each
administrative control mechanism is discussed in Table 3-2 separately, a POTV
could use all, or any combination, of these administrative controls.  This
guidance recommends that POTVs adopt all aspects of these five types of
administrative controls, adjusting the intensity of use of each aspect to suit
its own needs. The following sections provide an indepth discussion of these
mechanisms.

3.2.2.1  Permits
     The most direct way to restrict the discharge of wastes received from
haulers is for the POTV to issue permits that would outline the conditions
that would have to be met before a waste could be discharged to the POTV.
These conditions may be similar to those conditions or requirements for indus-
                                     3-10

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trial users subject to a local pretreatment program.  POTVs can issue permits
to either the waste transporter and/or the vaste source or generator.
Requiring permits is an effective means of limiting the community of users.

This method of control improves the POTW's knowledge of transporters/

generators and improves its overall ability to ensure that the receipt of

hazardous waste is prohibited.


     For a permit to be effective in controlling wastes discharged to POTWs,

the establishment of discharge conditions is recommended.  The following are
several conditions that are highly recommended to be included as part of a

permitting system.  These conditions could be placed directly into the permit,

or the permit simply could require compliance with the local sewer use

ordinance, which could contain these conditions:


     •  Right of refusal to accept waste — The POTW should reserve the right
        to refuse any waste suspected or proven to be hazardous to avoid RCRA
        responsibilities.  Reason for refusal of certain wastes, such as
        solvents or those wastes with high metals concentrations, may protect
        the plant, worker safety, or the environment.

     •  Prohibited or restricted substances — The permit could contain
        explicit restrictions on pollutant concentrations, waste character-
        istics, or waste types.  If the POTW chooses to prohibit all RCRA
        wastes from being hauled and directly discharged, the criteria or
        wastes listed in 40 CFR Part 261 could be adopted as specific prohibi-
        tions in the permit (e.g., corrosive or EP toxic wastes, or specific
        listed wastestreams).  In the alternative, the control mechanism could
        clearly identify the wastes that will be acceptable, taking care that
        the Part 261 wastes and criteria are not included in the permit.

     •  Notification of change of waste type — The POTW may want to require
        that any new industrial or commercial waste be approved by the POTW
        prior to being hauled.  The hauler and/or generator could be required
        to notify the POTW of requests to haul new.or significantly different
        waste from recognized, permitted sources or waste from previously
        unrecognized sources.  (To implement this requirement, the POTW would
        have to clearly define what constitutes a "significantly different"
        waste).  This ensures that the POTW knows of its introduction into the
        system and can adequately characterize this new waste.  After this
        characterization of wastes is performed, the POTW could accept the
        wastes, or deny the discharge because the wastes are hazardous or
        otherwise incompatible with the treatment works.

     •  Waste tracking — Each permit could require the waste generator and/or
        waste hauler to use a waste tracking system that enables the POTW to
        track the sources, types, and quantities of wastes delivered to the
                                     3-13

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   POTV.  (Section 4.4.2 provides a discussion of RCRA waste manifest
   system.)  The use of a waste tracking system is useful in determining
   if a waste is a RCRA hazardous waste, in recognizing possible illegal
   hauling, or in identifying wastes that have a potential to cause
   upsets or other treatment plant problems.   The POTV could develop and
   require the use of a form that provides relevant information on the
   hauled waste, including the source,  address, telephone number, time
   and date of pickup, waste type, known or suspected pollutants, and
   certification that the waste is not  hazardous.  (Section 3.2.3.2
   provides more information on the implementation of a waste tracking
   system.)

•  Monitoring and sampling — The permit could explicitly allow the POTV
   operator or a designated representative the opportunity to sample
   prior to discharge by the septage hauler.   The permit also can require
   the hauler to sample any waste where it is generated, before it is
   initially pumped into the truck or rail car.  If haulers are required
   to sample, sampling and preservation procedures can be specified in
   the permit by the POTV.  The permit  could also make the industrial
   user aware of its responsibilities to determine that its solid waste
   is a hazardous waste.  (Section 3.3  provides further information on
   monitoring strategies.)

•  Designated disposal points — Each permit could designate specific
   discharge times and points at the treatment plant.  Ideally, disposal
   should occur where direct supervision by plant personnel is available
   (e.g., at the headworks or into a holding tank at the plant).  This
   allows plant personnel to inspect easily the waste tracking manifest,
   verify its information, sample the waste,  and ensure that incompatible
   vastes are not dumped into the system.  Receipt of hazardous waste to
   a point in the collection system constitutes a violation of RCRA
   manifest requirements.  Therefore, before receiving solid wastes into
   the collection system, the POTV should ensure that such wastes are not
   hazardous wastes.

•  Fee system — A fee schedule for treatment of hauled wastes can be
   described within the permit, setting forth baseline charges for a
   specific volume of waste as well as high strength surcharges.  Extra
   charges to cover the cost of sampling and analysis also may be
   included.  These costs may vary dependent on  techniques used  (see
   discussion of waste monitoring plan in Section 3.3).

•  Penalties and other remedies for noncompliance — Each permit could
   describe the penalties and other remedies available to the POTV should
   a waste hauler violate any conditions of discharge.  For example,
   hauling waste in violation of Federal or local limits may carry a
   different fine or legal action than violating waste tracking pro-
   cedures or discharging waste that damages the treatment plant.  In
   addition, the permit could specify the legal  procedures (e.g., show
   cause hearings or  issuing injunctions) that would be available under
                                3-14

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        appropriate circumstances of nonrompliance.  Permits also could
        describe federally imposed penalties that generators/transporters may
        face.  For example, Section 3008(e) of RCRA provides for penalties of
        up to $250,000 and 15 years imprisonment for placing a person in
        imminent danger of death or bodily injury.

     •  Damage liability — The permit should contain language that describes
        the liability of a hauler who discharges waste that damages the
        treatment plant or collection system, causes injury to plant per-
        sonnel, contaminates sludge, or otherwise results in problems for the
        POTV.  This liability should include the legal costs the POTV incurs
        in assessing damages, as well as the cost to repair plant damages,
        etc.  Upon proof of willful or intentional damage, and as allowed by
        State and local law, the POTV may assess additional liability (e.g.,
        several times the amount of the actual damage) as a punitive measure.
        Dependent on State and local law, a POTV might also hold the waste
        hauler liable for the civil penalties and fines a POTV may incur for
        noncompliance with RCRA permit by rule requirements or for releases of
        hazardous waste or hazardous constituents to the environment, should
        the hauler knowingly discharge a hazardous waste to the POTV without
        notifying and receiving permission from the POTV.

     •  Permit revocation — The permit could be revocable in the case of a
        significant violation or a pattern of violations by the waste hauler,
        or by the waste generator or storage facility from which waste is
        hauled to the POTV.  By specifying that the permit is revocable, the
        POTV can deter haulers from transporting potentially hazardous wastes.
        As a result, haulers may be more selective in receiving wastes from
        industrial facilities,


     Some POTVs have adopted the following conditions, in addition to those
listed above, as part of their control programs.  The following conditions,

while not directly related to preventing the receipt of hazardous wastes, may

be used to improve waste management procedures:


     •  Liability insurance — To ensure that the hauler can reimburse the
        POTV for damages caused by discharging an incompatible waste, the POTV
        could require the hauler to obtain liability insurance as a condition
        in the permit.  The amount of liability insurance coverage can vary
        tremendously, depending on the potential for damage to the system.
        One large urban POTV requires haulers to obtain coverage for at least
        $1 million for each occurrence.  Potential plant damage will depend on
        the size and complexity of the POTV.

     •  Equipment performance standards — The permit may contain minimum
        performance requirements for the permittee's vehicle, as well as
        procedures for pumping, discharging, and measuring waste.  These
        requirements can prevent inadvertent leakage and can facilitate
        trouble-free discharging of waste.  For example, the POTV could
                                     3-15

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        require the hauler to maintain the waste hauling tank without leaks or
        corrosion, to install a positive check valve or use a level gauge to
        prevent over-fill, or to maintain a suitable discharge valve, hose,
        and connector, etc.
     •  Spill prevention/notification — The POTV could require that waste
        haulers take precautions to avoid spills and notify the POTV when
        spills occur.  Spilled wastes should not enter the sewer system
        without being sampled and determined compatible with the treatment
        system.  If the waste is potentially toxic (e.g., industrial), the
        POTW can also contact appropriate environmental authorities or
        document its introduction into the system and sample the appropriate
        sewer lines for contamination.

     In summary, the permit provides three distinct and useful functions:  an
informational function, a regulatory function, and an enforcement function.
As an informational tool, the septage hauler or waste generator can improve
treatment or hauling system procedures to avoid mixing solid and hazardous
wastes.  The permit also provides a means for the POTW to develop an inventory
of haulers and generators, thereby improving control over use of the treatment
system.

     Permits may be used by a POTV to require the hauler or generator to meet
specific requirements necessary to ensure that hazardous wastes are not
received at the treatment plant.  Permits may also be used to protect plant
operations and the environment, and include limitations on waste type or
pollutant concentrations and self-monitoring requirements to ensure such
protection.  Using a permit also allows the POTV to place specific restric-
tions on waste haulers and generators who use the POTV, creating a foundation
for possible enforcement actions.  An example waste hauler permit is presented
in Appendix C.

     As an enforcement tool, a permit can define the criteria for determining
when a violation has occurred and set appropriate penalties.  It also may
specify hauler or generator liability, and define procedures and responsi-
bilities in legal hearings.  A permit also can be revoked by the POTV under
appropriate circumstances, constituting a ban on accepting waste from a hauler
or generator.  Consequently, use of an administrative and/or regulatory
structure  to control  the practice of hauling waste to the plant allows the
                                     3-16

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POTV to protect itself from receiving hazardous wastes, potentially hazardous
wastes, or dangerous, incompatible wastes.

3.2.2.2  Vaste Tracking System
     A waste tracking system is another mechanism a POTV can use to ensure
that a waste being hauled and subsequently discharged is not hazardous.  A
waste tracking system will enable the POTV to track the sources, types, and
quantities of waste that are being hauled to the treatment plant.  As pre-
viously discussed in Section 3.2.2.1, compliance with a waste tracking system,
including the submission of a waste tracking form, can be required as a
condition in a permit.  Alternatively, a waste tracking system can be used
independently of other control mechanisms.

     In developing a waste tracking system, POTVs will need to rely on one of
two strategies:

     •  Require the waste generator to obtain a waste tracking form from the
        POTV, list the type and volume of waste, SIC code, source, address,
        telephone number, time and date of pickup, waste type, known or
        suspected pollutants, and certification that the waste is not hazard-
        ous on the form and transmit the form to the POTV via the waste
        hauler.  Restrict waste haulers to hauling only wastes accompanied by
        completed waste tracking forms.
     •  Require the waste hauler to list the SIC code, source, address,
        telephone number, time and date of pickup, waste type, known or
        suspected pollutants and certification that the waste is not hazardous
        for each generator serviced on a waste tracking form and transmit the
        form to the plant operator before discharge of the waste would be
        allowed.

     Use of waste tracking, in concert with a source control program (i.e.,
permitting, sampling, and inspecting the generator), and a hauler sampling
program will provide a high degree of control by the POTV over incoming
wastes.  By requiring the use of waste tracking forms, the POTV can determine
the source of the waste, its probable content, and its volume before allowing
it to be discharged.  This information can be checked by sampling and compar-
ing the volume noted on the tracking form to the hauled volume, and by
contacting the waste generator to verify that waste was pumped and hauled from
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the source listed on the waste tracking form.  An example waste tracking form
that can be used by POTVs to track hauled wastes is presented in Appendix D.

3.2.2.3  Physical Restrictions
     To minimize illegal discharges and to ensure that the POTV has the
opportunity to exercise control over incoming hauled waste, discharge points
for hauled wastes should be restricted and supervised.  Restrictions of
discharge points for hauled wastes can be implemented through a permit or
contract (as discussed in Section 3.2.3.1) or as an independent control
mechanism.  Following are some alternatives for physically restricting the
discharge of hauled wastes should a POTV choose to use this type of admin-
istrative control.

     The advantage of using a discharge point in the collection system is that
hauled wastes may have the opportunity to mix adequately with other wastes in
the collection system before reaching the treatment plant headworks. Again,
this may be desirable for smaller POTVs or those POTVs susceptible to shock or
slug loads.  The disadvantage of a collection system discharge point is that
the POTV may not be able to oversee discharge activities as easily as if
discharge occurred at the treatment plant.  Thus, a collection- system dis-
charge point, with restricted access controls, should be identified that can
be surveyed easily by the POTV to ensure proper oversight of waste hauler
activity.

     Accepting hazardous waste in the collection system may pose additional
legal concerns to the POTV.  Hazardous waste generators are required to send
their hazardous waste to permitted TSDFs, accompanied by a RCRA manifest.  The
dumping of hazardous waste down a manhole outside of the POTV facility is a
violation of RCRA hazardous waste generation and transportation requirements.
Thus, the generator and transportator could both be liable for manifest
violations.  It is unlikely that a POTV which unknowingly receives hazardous
waste which had been illegally dumped down a manhole would independently be in
violation of RCRA requirements.  However, POTVs which knowingly allow or
participate in such activities may be subject to criminal liability under a
variety of statutes as an accessory to generator and transporter violations.  •
                                     3-18

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     In many cases,'treatment plant access may result in discharges directly
to the headworks.  This is normally allowed at larger POTVs, which can handle
the slug load from the hauler without any detrimental effects on the POTW
operations.  However, in some cases where storage or equalization capacity is
available, hauled waste can be required to be discharged to equalization or
holding tanks, where it can be characterized prior to introduction to (or
restriction from) the treatment system.  However, receipt of hazardous wastes
to equalization and holding tanks would trigger RCRA permit by rule
requirements.  Equalization and holding tanks also will allow smaller POTVs,
or those POTVs susceptible to shock or slug loads, to regulate the intro-
duction of the hauled wastes into the treatment system.  EPA is currently
developing a guidance manual on the prevention of interference with POTV
operations.  Sections of this guidance manual will discuss waste management
techniques which may lessen impacts from discharged wastes.

     The benefits of restricting discharges to a single area within the POTV
boundaries are that the plant operator can easily inspect and sample any or
all hauled waste, verify waste tracking records, supervise the discharge of
waste, and prohibit wastes that are incompatible with the treatment system.
By restricting access and supervising the discharge of hauled waste, POTVs can
discourage haulers from attempting to discharge illegally incompatible toxic
or hazardous industrial wastes.

     Some POTVs have chosen to issue magnetic cards to haulers to gain access
to discharge areas.  These cards signal the operator that a hauler is dis-
charging, identify the hauler, and calculate the volume of waste being
discharged.  Vhile this measure offers some level of control, it is not as
effective as the POTV manning the discharge area and conducting sampling.  As
an additional measure of control, some POTVs simply use a gate with a padlock
to restrict discharges.  Typically, discharging is only allowed during a
specified period in the day (e.g., 8:00 a.m. to 3:30 p.m.), enabling the plant
operator to supervise the discharge of hauled wastes.
                                     3-19

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3.2.2.4  Surveillance and Investigative Techniques
     All POTWs, by nature of their collection systems, are subject to unknown
discharges of incompatible wastes (e.g., illegal "midnight dumping").  POTWs
may want to pursue a course of surveillance and/or sampling as a control
mechanism to detect the sources of these unknown discharges.  Monitoring to
detect illegal dumping may entail periodic sampling of suspected sewer lines,
and/or surveillance of manholes or storm drains.  POTVs can contact State or
Federal RCRA authorities to determine likely sources of hazardous waste and
obtain records of their disposal practices, compliance history, waste types,
etc.  Many States also have illegal discharge enforcement programs, which can
assist POTVs in their surveillance programs.  Local law enforcement officials
can be requested to assist in surveillance activities and enforcement of
municipal statutes and regulations dealing with illegal discharges.  Some
POTVs have chosen to use video cameras to monitor septage discharge stations.
In cases where illegal dumping is suspected, video surveillance can be used at
manholes or storm drains where surveillance by POTV personnel is infeasible.
Where POTVs suspect that a septage hauler is mixing hazardous and domestic
wastes, the POTV may want to follow the hauler schedule on a random basis.

3.3  VASTE MONITORING PLAN
     A POTV also may want to design a waste monitoring plan as part of its
administrative control system.  While a hazardous waste may not be transported
legally without a hazardous waste manifest, POTVs should be aware that some
haulers may carry unmanifested hazardous wastes illegally.  Therefore, even if
a POTV does not receive manifested wastes, it may be receiving hazardous
wastes and thus may still be responsible for obtaining and satisfying the
requirements of a RCRA permit by rule.  The purpose of the waste monitoring
plan is to complement the aforementioned administrative techniques, thereby
helping to identify unmanifested hazardous wastes and preclude their «ntry
into the POTV system.

     Since the definition of hazardous waste is a legal definition, and not
strictly based on the presence of pollutants or the concentration of those
pollutants in a waste, a waste monitoring plan may not, by itself, work to
                                     3-20

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preclude the entry of hazardous wastes.  This is especially true given that a
listed hazardous waste, when mixed with a solid waste, remains a hazardous
waste without regard to the resultant concentrations.  Nonetheless, a well-
executed waste monitoring plan can work as an effective mechanism to deter
unscrupulous waste generators and haulers.

     As described in Sections 3.1 and 3.2, it is recommended that if a POTW
accepts hauled wastes, it should limit its receipt of these hauled wastes to a
well-defined set of generators and haulers.  By monitoring the set of waste
generators, the POTV can exercise a high degree of control over incoming
waste.  While this approach should limit any potential for receipt of hazard-
ous wastes, some opportunity remains as a result of either unscrupulous or
careless behavior by generators and haulers.  The design of a waste monitoring
program can be more complex where the POTV is seeking to identify a hazardous
constituent or hazardous waste characteristic from an unknown source.  Given
the fact that hazardous wastes can be extremely varied and at times difficult
to detect, the implementation of a waste monitoring plan can be a time
consuming, costly exercise.  Full consideration was given to time and cost
constraints in the recommendations provided in Sections 3.3.1 and 3.3.2 so
that a POTV can structure a workable program.

3.3.1  Identification of Potential Hazardous Vaste Source and Types
     As described in Section 3.2, a POTV could maintain a legal/administrative
system that limits the number and types of hauled wastes that could be
accepted at the treatment plant.  By using such a system, the POTV can tailor
a waste analysis plan to the characteristics of each generator.  However, even
with such a system, permitted generators and/or haulers may mix solid or
domestic wastes with "nonmanifested" hazardous wastes as a result of either
unscrupulous or careless practices.  Consequently, in these cases, the POTV
will need to make a reasoned effort in determining probable hazardous waste
contamination sources and design a program to detect mixing of hazardous waste
with domestic waste from these.sources.  This section presents methodologies
for designing a waste monitoring plan in two separate cases:  (1) where the
generator is unknown and the POTV must screen the waste at the treatment plant
before allowing it to be discharged, and (2) where the generator is known and
is subject to waste monitoring prior to hauling waste.
                                     3-21

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3.3.1.1  Identification of Hazardous Wastes from Unknown Generators
      Designing a waste monitoring plan to detect hazardous wastes from an
unknown hazardous waste generator can be challenging.  This will be the case
if the POTV is seeking to detect hazardous wastes mixed with septage sewage.
While the steps described in this section can be expected to reduce the number
of potential parameters of concern, this list still may be large and varied
(e.g., metals, volatile organics).  Section 2.3 provided discussions on those
wastes that may be commonly discharged to POTWs.  These discussions should
provide the POTV with an idea of some of the hazardous wastes and constituents
that may.be generated in its service area.  POTWs can refine this list by
focusing on industries located in its service area and researching their waste
types and quantities reported through CWA and RCRA mechanisms (e.g. RCRA 3010
notification).

     Further, rather than design a monitoring program to monitor for the
numerous types of hazardous waste (there are over 300 RCRA Appendix VIII
hazardous constituents and four hazardous waste characteristics to consider)
it is recommended that the POTW consider evaluating wastes hauled from an
unknown generator by performing a three tiered analysis.

     In the first tier, the POTW should perform a data gathering exercise and
desktop analysis to identify potential hazardous waste generators in its
service community including types and quantities of waste, as well as current
and/or proposed management practices.  Section 3.3.1.2 of this document
describes aspects of this data gathering exercise by way of example.  This
exercise involves reviewing data previously submitted by the facilities as a
result of CWA or RCRA authorities.

     In the second tier, the POTW should use information gathered in the first
tier to design a monitoring plan intended to screen hauled waste.  This can be
accomplished by performing tests on indicator parameters.  For example, if
industries in the community typically generate caustic or acidic wastes, a
simple pH test may be appropriate.  Similarly, the presence of spent solvents
may be indicated using an OVA/HNU meter.  The example waste monitoring plans
in Section 3.3.3 of this document provide examples of simple screening tests
                                     3-22

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that a POTV may choose to employ.  The second tier of tests will not

definitively identify whether a. waste is hazardous or not.  However, they may
be helpful in identifying wastes of concern.  Among the test methods that are

described in Table 3-3 are those that fit this "screening" purpose, including

biluminescence tests and vapor analysis tests.  Potential screening techniques

appear in boldfaced print in Table 3.3.


     Affirmative results to these screening tests could trigger a third tier

of testing.  This would involve more extensive analysis, such as EP Toxicity

testing or GC/MS analysis, to identify and quantify specific hazardous

constituents.


     Undertaking the following will assist the POTV operator in developing a

waste monitoring strategy:


     •  Contact State and Federal hazardous waste program officials to
        determine who the hazardous waste handlers (e.g. generators, trans-
        porters, and TSDF's) are in your service area.  Ascertain the hazard-
        ous waste types and constituents handled by these facilities from
        State/Federal officials.  Appendices A-l, A-2, and A-3 to this
        document list hazardous wastes and constituents that may be found in •
        selected industries.

     •  Certain hazardous wastes are widely generated and the constituents
        associated with these wastes probably should be considered in pre-
        paring a waste monitoring plan.  Examples of widely generated hazard-
        ous wastes include electroplating wastes, spent solvents, and small
        quantity generator wastes such as dry cleaner wastes.  Section 2.3 of
        this document describes these widely generated hazardous wastes, as
        well as others, that POTVs may encounter.

     •  Some wastes will be generated by industries that are particular to the
        region in which a POTV is located.  For example, a POTV operating in a
        geographical region where numerous wood preserving industries are
        located should be aware of the potential for receipt of listed bottom
        sediment sludges from wood preserving wastewater treatment systems.


3.3.1.2  Identification of Hazardous Vaste from Known Generators

     By imposing specific waste monitoring requirements on known generators,

the POTV can increase its knowledge of the nature of waste accepted for

treatment.  To develop industry-specific monitoring requirments, the POTV can

use the following mechanisms:
                                     3-23

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     •  As described above, a first step is to contact State and Federal
        hazardous waste program officials to determine vho the hazardous waste
        handlers (e.g. generators, transporters, and TSDF's) are in your
        service area.  Ascertain the hazardous waste types and constituents
        handled by these facilities from State/Federal officials.

     •  Onsite audits or inspections by the POTV of known or suspected
        hazardous waste generators would assist in determining what types of
        hazardous wastes are handled at a facility and where wastes are sent
        for treatment and disposal.  These audits or inspections could be
        performed in conjunction with inspections performed as part of the
        POTV's pretreatment program.  These audits or inspections also could
        be performed prior to permit issuance, should a POTV choose to permit
        hazardous waste generators.

     •  Review Appendix A to this document to determine whether this facility
        belongs to an industry which is known for generating a listed waste,
        e.g., listed solvents.  Also review the Appendix VII list to target
        particular hazardous constituents associated with these wastes.

     •  Industrial waste surveys performed by POTWs during pretreatment
        program development may provide information that would be useful in
        determining hazardous waste practices of industrial/commercial
        facilities in the POTV service area.  In some instances, POTVs
        required specific information regarding hazardous waste types gener-
        ated at a given facility and then associated waste disposal practices.


     Perhaps the most reliable information source that a POTV can use to

design a generator-specific waste monitoring plan is the onsite audit de-

scribed above.  However, to be effective, the audit should encompass a review
of all wastestreams at the subject facility, not only those wastestreams for

which the discharge permit is being sought.  Generally, the audit should

involve:


     •  Identification and sampling of all wastestreams to determine concen-
        trations of suspected Appendix VII and VIII hazardous constituents,
        characteristic tests, and physical characteristics such as specific
        gravity, pH, and solids content.  This can be required of the industry
        prior to acceptance of wastes by the POTV.

     •  An explanation of the production processes leading to the generation
        of these wastestreams, including such information as:  types and
        quantities of raw materials, catalysts, reagants used in the produc-
        tion process; routine variations in process operation; previous
        history of waste handling methods; practices used to avoid waste
        mixing, etc.
                                     3-27

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     •  A review of the generator's records of hazardous vaste identification,
        including manifest records of wastes routinely sent off-site.  If the
        generator manages wastes onsite, the facility's operating records
        should be reviewed.

     As a result of an audit (and/or a pretreatment review of permit applica-
tion or industrial waste survey data if an onsite audit is not feasible), the
POTV will be in a better position to determine if the potential exists for
receiving mixtures of hazardous and nonhazardous wastes.  If the facility
generates listed hazardous wastes, and the POTV still chooses to receive the
nonhazardous facility wastes, the data gathered will provide the POTV with a
list of hazardous constituents that may be monitored for during a spot check,
or if time and cost allow, more routine basis.  In addition, if the hazardous
waste is a characteristic waste, the hazardous characteristics that should be
considered in the waste monitoring plan will be identified.

     In a broader sense, the audit and/or industrial data review will give the
POTV the opportunity to consider what is the most appropriate waste monitoring
approach in dealing with the subject generator.  If the POTV is accepting
wastes by truck, rail, or dedicated pipeline from industries subject to
categorical standards, the POTV will need to monitor for compliance with
categorical standards and local limits.  The POTV also will want to monitor
these wastes for any parameters that may cause POTV operational problems or
worker health and safety hazards (i.e., corrosion, fire/explosion, and
toxicity to the biological treatment system).  POTVs receiving industrial
process wastes, particularly when that industrial facility is a known hazard-
ous waste generator, should monitor for hazardous constituent parameters and
characteristics at a more frequent basis than would be conducted for the
receipt of septage wastes.

3.3.2  Considerations in Developing a Vaste Monitoring Plan
     Vhen developing a waste monitoring plan to ensure that hazardous wastes
are not being hauled and discharged to their wastewater treatment system, a
POTV will have to consider the resources available to implement this plan.
Table 3-3 presents information regarding analytical protocols and the approxi-
mate resources necessary to monitor various hazardous waste parameters.
                                     3-28

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     The time, cost, and expertise constraints listed in Table 3-3 may limit
both the monitoring approach and monitoring frequency selected by a FOTV.  As
Table 3-3 illustrates, there are a variety of options for analyzing for both
organics and metals.  While only the first four techniques, the characteristic
tests, are designed specifically for making hazardous waste determinations,
all of the other techniques listed here may be used by POTVs as surrogate
measures for making hazardous waste determinations.  All of these tests share
one disadvantage:  none of the tests is a sure-fire approach for determining
whether a waste is hazardous.  On the other hand, some of the techniques are
more advantageous for some reasons (e.g., detection limits), while disadvan-
tageous in other senses (e.g., time and cost).

3.3.2.1  Equipment, Time, and Costs of Monitoring
     As suggested in Table 3-3, monitoring just prior to a generator's
discharge may not be a reasonable approach based on the time needed for
analysis (e.g., Series 7000 metals analysis may take up to 3 days).  In these
cases, the POTW may choose to conduct monitoring at the generator's facility
or, alternatively, employ a holding tank for storage of the hauled wastes
prior to discharge to the treatment system.  However, a FOTV storing hazardous
wastes on site would be subject to permit by rule requirements.  Thus, this
type of monitoring approach may defeat the purpose of the waste monitoring
plan.  In other cases, the constraining factor may not be the time necessary
for analysis, but the cost of that analysis (e.g., GC/MS scans for volatiles
may cost 2-3 times the unit costs, up to $900, as shown in the table) if the
analysis is to be performed at a commercial laboratory on a "quick turnaround"
basis.  While the unit costs decline sharply when the POTW owns the equipment,
the capital cost of equipment (and the personnel needed to run that equipment)
may be cost-prohibitive to most POTWs.  In light of these costs, the POTW may
limit the analytical frequency, even if the generator is expected to pick up
analytical costs.

3.3.2.2  Selection of Parameters for Waste Analysis
     Selection of sampling parameters should be based on the POTW's knowledge
of potential sources of hauled waste.   To develop an efficient, cost-effective
                                     3-29

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vaste analysis strategy, POTVs may conduct a tvo-phased plan.  In the first
phase, the POTV can test for specific indicator parameters using simple  tests,
such as pH, color, and OVA or HNU (for organic vapors).  In the second phase,
more extensive analysis can be performed if the initial tests indicate a
potential problem.  The use of specific tests at the point of discharge  can be
tailored to wastes generated from specific industries or industrial processes.

     The RCRA characteristic tests for ignitability, corrosivity, and reactiv-
ity are applicable to POTV operational and worker/health and safety concerns.
However, as suggested above, time and resource costs may prohibit continuous
monitoring for these characteristics.  This is particularly true for the
reactivity and EP toxicity tests.

     A POTW may use Table 3-3 to suggest alternative monitoring methods.  For
example, the EP toxicity test may be time (2 days or more) and cost ($20K
capital, $250-650 unit) prohibitive for a POTV to adopt as part of a regular
vaste monitoring plan.  The operator may choose to monitor for the metals at
the EP toxic concentrations as opposed to conducting the more expensive  EP
toxic test.  If a larger concentratipn is found than that determined to  be EP
toxic (see Table 2-1), the POTV can refuse to allow the discharge of the waste
to the POTV.  Vhile this is an especially stringent approach, in that the EP
Toxic concentrations represent "leached" concentrations and not waste concen-
trations, conducting this level of sampling and analysis may be more cost-
effective for POTVs than engaging in EP toxicity testing procedures.  However,
the POTV may choose to require generators/haulers to conduct EP toxicity tests
if a  total waste analysis reveals high concentrations.

      One factor of concern is that hazardous constituents mixed with septage
wastes are likely to be bound in a solid matrix.  The  time and associated cost
of analyzing for pollutants in this matrix is greater  than that required for  -
analyzing pollutants in the water matrix.  Unlike industrial/commercial
generators, septage haulers ordinarily do not possess  the resources necessary
to absorb additional testing costs that the POTV may need to impose.
                                      3-30

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.1.
                On the basis of practical  time and cost constraints,  the POTV may  choose

           to limit  the scope and  frequency of analysis.  Where  the POTV views  time  and

           cost constraints of analysis prohibitive, it still may choose to  take samples
           of the hauled discharge for deterrence purposes.


           3.3.3  Example Waste Monitoring Plans

                The  following discussions  describe two different examples of how a POTV

           can use the guidance provided throughout  this section to develop a waste

           monitoring plan to preclude the discharge of hazardous wastes by waste  or

           septage haulers.


           3.3.3.1   Septage Vaste  Case Study

                In this example, the POTV  allows septage haulers to discharge to its wastewater t
           eatment system.  The POTV permits all septage haulers, and allows
           only the  discharge of wastes from domestic sources.  Given this scenario, the
           POTV may  not be very concerned  about routinely receiving hazardous wastes or
           monitoring for their presence due to the  following:

                •  The permitting  system implemented by the POTV for septage haulers only
                   allows for the  discharge of wastes from domestic sources

                •  Any solid wastes generated in a household are excluded from  regulation
                   as a hazardous  waste under RCRA.

           Hazardous Vaste Identification

                There are many petroleum refining industries located within and around
           the POTV  service area;  therefore, the POTV decides to investigate the possi-
           bility that a permitted septage hauler may be collecting hazardous waste  from
           one of these facilities.  The first step  the POTV takes is to obtain informa-
           tion regarding hazardous waste  activities at these refineries.  The  informa-
           tion is gathered from the following sources:

                •  Completed industrial waste surveys that were collected during pre-
                   treatment program development

                •  Discussions with State  hazardous waste officials regarding the  status
                   of the refineries in and around the POTV's service area.

           Based on  review of the  above sources, the POTV discovers that two refineries
           that were treating hazardous waste onsite no longer do so.  According to  RCRA
           program officials, the  facilities now are pursuing alternate disposal methods.
           The POTV  is concerned that these facilities may consider use of the  POTV  as a
           disposal  option and decides to  develop and implement a waste monitoring
           program.
                                                3-31

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     The POTW initiates the development of its waste monitoring plan by
identifying the potential waste types and associated constituents (or pol-
lutant parameters) that could be generated at the petroleum refineries.  By
reviewing Appendix A to this document and any other available information,
(i.e., pretreatment audits, State inspection reports), the POTW determines
that there are five listed hazardous wastes for the petroleum refining
industry:  K048, K049, K050, K051, and K052.  The constituents (or pollutant
"parameters) associated with these listed wastes (as provided in Appendix VII
to 40 CFR 261 and Appendix A-3 to this document) are as follows:

   Listed Waste                         Hazardous Constituents

        K048                           Hexavalent Chromium, Lead
        K049                           Hexavalent Chromium, Lead
        K050                           Hexavalent Chromium
        K051                           Hexavalent Chromium, Lead
        K052                           Lead


Methods Selection and Sampling Frequency

     Based on the above list, the POTW then considers monitoring septage
haulers for hexavalent chromium and lead on a spot-check basis.  After
reviewing Table 3-3,  the POTW decides  that  the costs associated with analyzing
these two pollutants  on a  random basis are within reason and can be recovered
via septage hauler permitting fees  (approximately $25-50 per analyte per
sample, assuming a contract laboratory with ICAP capabilities was used).  The
POTW will sample each of the haulers prior  to discharge, but only analyze a
sample  for hexavalent chromium and  lead a couple of  times a year on a  random
basis for each hauler or when the POTW is suspicious of illegal discharges
from a  hauler.  Due  to  the time required for  these analyses  (about 4 hours,
not including delivery  time  to the  laboratory), and  the POTW's  inability  to
store hauled wastes  onsite,  the POTW will allow hauled wastes  to be dis-
charged, analyzing  the  sample for hexavalent  chormium and lead  after the  fact.
  Should analytical  results show high concentrations  of either  pollutant,  then
the POTW will follow up, take enforcement action as  necessary,  and  increase
monitoring efforts  on the  hauler  of concern.


3.3.3.2 Metal  Finisher Case  Study

      In this section, the  methodology  for developing a waste monitoring plan
described  throughout Section  3.3  is again applied  by way of  example.   A metal
finisher has requested  permission to discharge  metal finishing wastewaters  to
the headworks of  the POTW  via truck.

Hazardous  Waste Identification  and  Associated Auditing

      Upon  being contacted  by the  metal finisher,  the POTW  contacts  the State  -
hazardous  waste agency to  determine if the  metal  finisher  is a hazardous waste
handler.   State officials  verify  that  the metal finisher  is  a  hazardous waste
generator  of  electroplating wastewater treatment  sludges  (F006),  cyanide
plating bath  solutions (F007),  and  cyanide  plating bath  sludges (F008).  The
POTW requests  this information from the State.
                                      3-32

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     The POTV decides to conduct an onsite audit of the metal finishing
facility's production and waste handling procedures.  Audit findings ascertain
that the metal finisher is in the business of zinc plating and chromating
pipe.  The production process involves solvent degreasing iron pipe, subject-
ing the pipe to two consecutive cleanings (one alkaline, one acid), plating
the pipe in a zinc cyanide solution, rinsing the product, immersing it in a
chromic acid bath for purposes of chromating, and passing the pipeline through
a final rinse.

     The POTV also notes that two separate sumps are used to collect alkaline
and acid dip rinses and discharge to a treatment system just prior to lime and
settle.  The metal finisher  is interested in disposing vastevater from its
vastevater treatment system  at the POTV.  The metal finisher plans to contract
with a hauler to deliver and dispose of the waste from the treatment system at
the POTV.

     Vhile the metal finisher insists that the degreasing procedure is a 100
percent recycle operation, on further questioning the metal finisher acknow-
ledges that spills have occurred in the past.  It is also noted that the
cyanide plating solutions, the plating bath sludges, and the wastewater
treatment sludges are sent to a RCRA treatment, storage, or disposal facility.
The POTV verifies this by checking signed copies of hazardous waste manifests
available at the metal finisher.  The POTV also determines the approximate
volume of waste generated by each process by reviewing facility records.

Parameter Selection

     Prior to requesting samples, the POTV reviews the results of the audit in
light of the hazardous waste identification regulations.  By reviewing
Appendices B-l, B-2, and B-3 to this document, the POTV finds that EPA has
published key pollutants and characteristics displayed by each listed waste.
In addition to the F006-F008 listed wastes that the State identified, the POTV
finds that the metal finisher's disposal of trichloroethylene qualifies as a
listed waste:  F001, spent halogenated solvents used in degreasing.

     On the basis of checking with the State, the audit, and the in-house
review, the POTV could request that the metal finisher provide samples of the
following wastes to a laboratory preselected by the POTV (which may be the
POTVs own laboratory in the  case of larger POTVs):  the F006-F008 wastes, and
the treated wastewater.  A sample of the degreasing agent, the plating bath,
and the chromating acid bath also could be requested for analysis.  The POTV
could request the following  analyses by the laboratory:  characteristic tests
of the treated wastewater; cyanide, zinc, chromium, and solvent concentrations
of the listed wastes and the treated wastewater; and specific gravity, and
solids content of all wastes.

     The POTV selected these analyses to determine whether the wastes to be
received from the metal finisher may be hazardous.  The POTV recognizes that
accepting solid wastes from  an industrial facility that is also a hazardous
waste generator opens up opportunities for receiving hazardous waste, and is
seeking parameters and/or concentrations of parameters that might work to
identify whether the metal finisher has surreptitiously mixed hazardous and
nonhazardous wastes.  The mixture concern is of particular interest with
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regard to the listed wastes.  However, the POTW is well-aware that the
wastewater and the listed wastes share the same basic parameters (i.e.,
cyanide, chromium, and zinc) and that a waste monitoring plan aimed specific-
ally at these parameters cannot be expected to distinguish listed waste
mixtures from nonhazardous wastewater.  The fact that these parameters are
hazardous constituents does not necessarily mean the waste is a hazardous
waste.  Continued inspection of the facility, with emphasis toward the
segregation of hazardous and nonhazardous wastes and a review of facility
hazardous waste manifest records, will be necessary to ensure that the POTW
does not receive hazardous wastes.

     The POTW selected laboratory provides the following results to the POTW
regarding the wastes submitted for analysis:

     •  The vapor degreaser is pure trichloroethylene with traces of ferrous
        compounds.

     •  The cyanide solution is characterized by high concentrations of
        cyanide and zinc.

     •  The chromic acid bath is characterized by high concentrations of
        chrome, with lesser concentrations of zinc.

     •  The treated wastewaters meet  applicable pretreatment limits for pH,
        chrome, cyanide, zinc, and trichloroethylene.  As suspected, the
        pretreatment of wastewaters ensures  that the wastewater does not  test
        corrosive.

     •  As suspected,  the wastewater  sludges exhibit higher concentrations  of
        the pollutants above, and a higher solids content than  the wastewater.
        The sludge did not  fail  the corrosivity test.


Method  Selection  and Sampling Program Development

     As a result  of checking with the State, conducting  the onsite audit,
performing the office  review of  the audit in light of the hazardous waste
identification regulations  (explained in Section 2.2 of  this document), and
reviewing the results  of the sample analyses,  the POTW is prepared  to  set a
two-tiered waste  monitoring program.  The first tier imposes self-monitoring
requirements on  the metal  finisher.   The second tier is  a compliance monitor-
ing program that  the POTW will use to detect possible violations of  the
hazardous waste discharge ban.

     As part of  the self-monitoring  requirements,  the metal  finisher  is
required  to submit  results  for each  of  the  parameters covered by  the categori-
cal standards prior  to each discharge event.   The metal  finisher also  is
required  to submit  pH  and  solids analyses  for  each  load.  The pH measurement
provides  for a determination of  whether or  not  the  waste is  characteristic,
while  the solids  content may serve as an indicator  of mixing wastewater  and
wastewater sludges.
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     Knowing that the wastes handled at the metal finisher tend to be cor-
rosive, the POTV also should conduct pH tests on each load as part of the
compliance monitoring program.  All POTVs should consider sampling for all
constituents of concern and preserving the sample for a time sufficient to
allow for analysis if the discharge results in plant upset of other
operational concerns.  These samples should be taken as a precautionary
measure, and need not be analyzed.  More specific sampling recommendations are
provided below for large and small POTVs.

     Larger POTVs also may conduct a verification of the metal finisher's
analytical results for each of the metals parameters from a subset of dis-
charge events.  This can be done most efficiently at the metal finishing
facility and will cost approximately $100 if the POTV has the necessary
equipment and staff.  In addition, larger POTVs may want to subject the metal
finishing discharge to a quick scan for organic concentrations, perhaps using
vapor analysis techniques, during each discharge event.  This will be particu-
larly helpful in determining whether the vapor degreasing agent, trichloro-
ethylene, has been mixed with the wastewater.

     Smaller POTVs may choose to conduct sampling of the metals constituents
at a lesser fequency as a result of their inability to maintain the necessary
analytical equipment and staff onsite.  However, low capital cost techniques
such as vapor analysis and checks of solids content may be used prior to each
discharge event.  In this way, smaller POTVs may be able to make a rough
determination of any hazardous waste/nonhazardous waste mixing that may have
occurred.  The vapor analysis, as above, can be used to make an assessment of
mixing with degreasing agents.  A review of solids and metal content may
assist in determining whether the wastewaters were mixed wi.th the listed
wastewater sludges.  Smaller POTVs may want to return to the generator to
collect samples (or have the generator discharge into a holding pond), or have
the generator collect the sample of the discharge under POTV supervision, and
analyze the results for the constituents of concern, pH, and solids content.
Since the turnaround time from a commercial laboratory usually will be greater
than the turnaround time from the POTV's laboratory, the laboratory should be
given sufficient notice to allow for scheduling.  As shown in Table 3-3,
analytic costs in a "rush premium" situation will be 2-3 times the cost for
analysis at the POTV's laboratory.  Therefore, smaller POTVs probably will
restrict their use of outside laboratories.
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       4.   RESPONSIBILITIES OF  POTVs  CHOOSING  TO  ACCEPT  HAZARDOUS WASTES

4.1  INTRODUCTION
     POTtfs may choose to accept hazardous wastes delivered by truck, rail, or
dedicated pipeline.  POTVs accepting these wastes are considered  to be
hazardous waste TSDFs and  are subject to applicable RCRA regulations.
However, in an effort to streamline  the permitting process and to avoid
redundancy with respect to the CVA, RCRA exempts POTVs  from individual RCRA
permits incorporating all  of the standards of 40 CFR Part 264.  Instead, POTVs
are deemed to be subject to RCRA permit by rule provisions which  contain the
following requirements [40 CFR 270.60(c)]:

     •  The POTV owner or  operator must have a NPDES permit, issued by EPA or
        a NPDES delegated  State
     •  The POTV must be in compliance with its NPDES permit
     •  The hazardous waste received must meet all Federal, State, and local
        pretreatment requirements (e.g., categorical standards, prohibited
        discharges, and local limits)
     ». The POTV must comply with the following RCRA provisions:
        -  Identification number (40 CFR 264.11)
        -  Use of manifest system (40 CFR 264.71)
        -  Manifest discrepancy reporting (40 CFR 264.22)
        -  Unmanifested waste report (40 CFR 264.76)
        -  Operating records [40 CFR 264.73(a) and (b)(l)]
        -  Biennial report (40 CFR 264.75)
        -  Corrective action if the NPDES permit was issued after November 8,
           1984 (40 CFR 264.101) or permit by rule coverage first occurs after
           November 8, 1984.

Appendix E lists the permit by rule requirements in greater detail.  POTVs
that do not comply with these requirements may not accept hazardous wastes for
treatment, storage, or disposal.  Receipt of hazardous wastes by a POTV not in
compliance with permit by rule requirements constitutes a violation of the
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POTW's permit by rule.  The remainder of this chapter explains the permit by
rule requirements and POTV obligations under these requirements.

     In addition to meeting the statutory and regulatory obligations discussed
in this chapter, POTWs choosing to accept hazardous waste by truck, rail, or
dedicated pipeline may want to impose additional requirements to protect
worker health and plant operations.  This chapter does not provide any
guidance in this area.  However, readers may want to refer to the discussions
that appear in Chapter 3 regarding legal, administrative, and technical
control measures.  Many of these same control measures (e.g., generator
audits, regular sampling) are applicable to POTWs choosing to accept hazardous
wastes for treatment, storage, or disposal. • If a POTV accepts a listed
hazardous waste by these transport methods, the POTW's treatment, storage, and
disposal of the resulting sludge will be governed by RCRA Subtitle C hazardous
waste requirements.  POTWs generating such sludges should contact hazardous
waste officials to assess their storage, treatment, and disposal options.

     POTWs should be aware that the regulatory requirements described herein
are minimum requirements for POTWs receiving hazardous wastes by truck,  rail,
or dedicated pipeline.  Other RCRA statutory requirements, e.g. land disposal
ban, may also be applicable as a matter of law if a POTW receives hazardous
waste.  Both Federal and State NPDES and RCRA permitting authorities may
impose more stringent requirements on POTWs accepting hazardous wastes for
treatment, storage, or disposal.  More extensive effluent sampling require-
ments and additional control parameters (including whole effluent toxicity
testing), among other requirements, might be imposed on permit by rule
facilities.  Each of the various permit by rule requirements is discussed
below.

4.2  COMPLIANCE WITH NPDES PERMIT CONDITIONS

4.2.1  Procedure for Determining Compliance
     As part of  the 40 CFR Part 270.60(c) requirements of a RCRA permit  by
rule, a POTW must be in  compliance with its NPDES permit.  Any violation of a
NPDES permit is  sufficient reason  for EPA  to take joint CWA/RCRA enforcement
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actions.  Thus the POTW should make every effort to ensure complete compliance
with all terms and conditions of its NPDES permit.  EPA will review the
severity of the violations, and appropriate responses, by analyzing the
nature, cause, and extent of any permit violations.  The requirement of "in
compliance with an NPDES permit" is an ongoing obligation.  Consequently,
noncompliance with any NPDES permit condition could result in RCRA 3008(a)
enforcement actions for receipt of hazardous wastes in violation of the permit
by rule, as well as CVA enforcement actions.

4.3  COMPLIANCE WITH PRETREATMENT PROGRAM REQUIREMENTS
     The National Pretreatment Program is designed to protect municipal
wastewater treatment plants from the potential adverse effects of industrial
discharges.  Specific goals of this program are to:

     •  Prevent interference with POTW operations that could result from  the
        introduction of pollutants that are toxic or inhibitory to the
        treatment process.
     •  Prevent the pass through of pollutants to the receiving stream.
        Pollutants that are incompatible, or otherwise unaffected by the
        treatment processes, could have an adverse environmental impact on the
        receiving stream.
     •  Preserve and improve sludge quality so that the chosen method of
        sludge disposal .can be continued and the possibility of more attrac-
        tive sludge reuse and recycle options enhanced.

All industrial users discharging to POTWs are subject to National Pretreatment
Program requirements and standards, as set forth in the General Pretreatment
Regulations (40 CFR Part 403).  EPA required many municipalities (POTWs)  to
develop local pretreatment programs, in pursuit of these goals, to manage and
control effectively all nondomestic wastes discharged to, and subsequently
treated by, their treatment system.  Where PQTWs were not required to develop
local pretreatment programs, States with delegated pretreatment program
authority or EPA Regional offices have the primary responsibility to apply and
enforce applicable pretreatment standards and requirements.
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     As part of the 40 CFR Part 270.60(c) permit conditions of a permit by
rule, the hazardous waste received from an industrial user by a POTV must meet
all applicable pretreatment standards (i.e., Federal, State, and local).
Therefore, it is the responsibility of the POTV to ensure that any hazardous
wastes received by truck, rail, or dedicated pipeline also meet applicable
pretreatment standards and requirements before discharge is allowed.

     Failure of the POTV to ensure compliance with applicable standards and
requirements prior to discharge, or acceptance of hazardous wastes that are
not in compliance with applicable pretreatment standards, can result in
enforcement ac.tions under RCRA Section 3008(a) for violation of the permit by
rule.  Further, CVA enforcement actions could be taken against the industrial
user for failure to comply with applicable standards and/or the POTV for
failure to properly implement its approved pretreatment program as required by
the POTV's NPDES permit.  Enforcement actions could also be taken against the
POTV for violation of its RCRA permit by rule.

     There are three types of discharge limits that may be applied to  indus-
trial discharges:  prohibitive discharge standards, local^limits, and  Federal
categorical standards.  Hazardous wastes received by a POTV by truck,  rail or
dedicated pipeline must meet all of these standards before discharge into the
POTV can be allowed.  Each of the applicable standards is dicussed further
below.

     •  Prohibitive discharge standards — Prohibitive discharge standards are
        required under Part 403.5(a) and (b) of the General Pretreatment
        Regulations.  The standards specifically prohibit the discharge of
        wastes to POTVs that:
        -  Create a fire or explosion hazard
        -  Have a pH of less than 5.0
        -  Contain solid or viscous pollutants that might cause obstructions
           to  the flow in the POTV
        -  Have an excessive oxygen demand
        -  Could cause the  temperature at  the  influent of the treatment plant
           to  exceed 104°F.
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Under these provisions, wastes that are hazardous because of the
characteristics of ignitability (40 CFR Part 261.21), corrosivity
(40 CFR Part 261.22), or reactivity (40 CFR Part 261.23) may violate
these prohibitions, and as such should not be accepted by the Control
Authority.

Local limits — Local limits are developed by the POTV to protect  the
POTV treatment plant operations, sludge quality, and receiving stream.
Since local limits are enforceable as pretreatment standards, any
hazardous wastes discharged to a POTV via truck, rail, or dedicated
pipeline also would have to comply with the local limits set by the
POTV.  POTV officials should determine whether the waste being
discharged is a listed hazardous waste and, if so, examine the
hazardous constituent upon which the listing was made (see Section 3.3
for guidance on identification of hazardous wastes).  This would
provide an indication of the pollutants for which the wastes should be
analyzed.  POTV also should be aware that industrial loading estimates
and subsequent allocations used originally to develop local limits may
change daily based on when a hauled hazardous waste is discharged.
Therefore, POTUs should consider the extreme loading variations that
could be expected to be received from waste haulers when allocating
allowable headworks loadings.

Many local sever use ordinances contain both upper and lower pH
boundaries for acceptable wastes.  These augment the prohibitive pH
standard and may lead to the necessary exclusion of additional
corrosive wastes.  (Officials should be aware that "P" and "U" listed
wastes also can be corrosive.).

Federal categorical pretreatment standards — Federal categorical
pretreatment standards are specific to each type of regulated industry
and contain discharge limitations for wastewaters generated from
specific regulated industrial processes.

Prior to accepting hazardous wastes via truck, rail, or dedicated
pipeline, POTVs will need to:

-  Determine whether the generating industry is covered by a categori-
   cal standard

-  Determine whether the wastes were generated from a regulated
   process

-  Identify the appropriate standards that apply to the wastestream

-  Establish the industrial production rate associated with the
   wastestream (for production-based standards only)

-  Establish the necessary sampling protocol to assess compliance  with
   the categorical standard
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        -  Sample and analyze the hazardous vaste, or require the industrial
           user to perform sampling and analysis, consistent with the estab-
           lished protocol, to ensure compliance with applicable categorical
           standards.

     Information provided by the generating industry may be in the form of an
EPA RCRA hazardous vaste number and a brief hazardous waste description.  In
rare instances, this may provide sufficient information; however, POTVs
generally can expect problems in determining the applicability of categorical
standards based solely upon this information.

     Some RCRA listed wastes provide a clear indication that the electroplating
or metal finishing regulations could be applicable, such as:  wastewater
treatment sludges from electroplating operations, spent cyanide plating bath
solutions, and spent cleaning and stripping solutions from electroplating
processes where cyanide is used in the process.  However, in the case of
solvents listed under F-001, F-002, and F-003, the generic descriptions lack
any information that might indicate the type of industrial processes that
generated the wastes.  In the case of solvents, this determination is crucial,
as solvents are regulated as "total toxic organics" under several categorical
standards.

     POTVs should be aware of the K-listed wastes, which EPA has provided in
groupings according  to the generating industry.  Once again, the problem in
determining the applicability of a categorical standard based on RCRA informa-
tion alone is the lack of information regarding the specific process that
generated the wastestream.

     Having properly identified the categorical waste, sampling protocols must
consider the possible combination of wastestreams, either at the industry, or
for conveyance to the treatment plant.  If this is the case, the Combined
Wastestream Formula  (CWF), as described in 40 CFR 403.6(e), must be applied to
account for possible dilution.  While dilution may be an acceptable method for
treating characteristic properties under RCRA, this cannot be used to achieve  ,
compliance with categorical standards.  While an  industry can be required to
monitor its wastestreams and provide the necessary data for use in the CWF,
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, V
 s
problems can arise if the transporter combines loads from different indus-
tries.  POTVs must establish regulations and procedures to ensure that any
such occurrence would be predicated upon the sampling and analysis of each
contributing wastestream for all pollutants of concern.  EPA's Guidance
Manual, Use of Production-Based Pretreatment Standards and the Combined
Wastestream Formula, (September 1985) provides additional guidance.

4.4  COMPLIANCE WITH RCRA PROCEDURAL REQUIREMENTS
     In addition to pretreatment information and reporting requirements, POTVs
must comply with the procedural provisions cited in 40 CFR Part 270.60(c) of
the RCRA regulations to operate under a permit by rule.  These provisions are
discussed more thoroughly in the following sections.

4.4.1  EPA Identification Number
     All facilities that treat, store, or dispose of hazardous wastes are
required to file a notification of activity and receive an EPA identification
number (40 CFR Part 264.11).  POTVs may obtain this identification number by
submitting EPA Form 8700-12.  A copy of this form is provided in Appendix F-l.
(Mailing addresses are provided in Appendix G).

4.4.2  Manifest System
     The RCRA program establishes a "cradle to grave" tracking system that
accounts for all hazardous wastes from the point of generation to final
treatment, storage, or disposal.  Tracking is accomplished through using the
Uniform Hazardous Vaste Manifest (Appendix F-2) or an equivalent State form.
The permit by rule conditions require POTVs to comply with the manifest
regulations for TSDFs (40 CFR Part 264.71-264.72).  The manifest system is
originated by the generator, continued by the transporter, and completed by
the POTV.  At each step, the appropriate sections of the manifest must be
completed with a copy going to all parties involved in the transaction.  To
complete the circle, the POTV must return a copy of the completed manifest to
the generator, while retaining a copy for its records.
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     The Uniform Hazardous Waste Manifest (EPA Form 8700-22) requires the
following information:


     •  The manifest document number

     •  The name, address, telephone number, and EPA identification number of
        the generator

     •  The name and identification number of each transporter

     •  The name, address, and EPA identification number of the POTV (includ-
        ing the same information for an alternate TSDF)

     •  The DOT shipping name, hazard class, and waste identification number

     •  The total quantity of each waste by weight or volume

     •  The type and number of containers used in transporting the waste

     •  A certification that the hazardous waste has been properly classified,
        described, packaged, marked and labeled, and is in proper condition
        for transportation

     •  A waste minimization certification stating that the generator has a
        program in place to reduce the volume and toxicity of the waste to the
        degree economically practicable to the generator, and that the
        proposed method of treatment, storage, or disposal is that practicable
        method currently available that minimizes the risk to human health and
        the environment.


     Upon receipt of a hazardous waste, the POTV owner or operator must:


     •  Sign and date the manifest

     •  Note any significant discrepancies in the manifest on each copy of the
        manifest (discussed in detail below)

     •  Immediately give the transporter a copy of the signed manifest

     •  Send a copy of the manifest to the generator within 30 days after the
        delivery

     •  Retain a copy of the manifest at the facility for at least 3 years
        after the date of receipt.


     If the waste is  transported by barge or rail, it may be accompanied by a

shipping paper in lieu of the manifest.  The shipping paper should contain all
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of the information required on the manifest except the EPA identification
number, the generator's certification, and the signatures of the intermediate
transporters.  When a shipping paper is used, the generator or initial rail
transporter is responsible for sending three copies of the manifest to the
POTW.  If the manifest is not received by the time the waste is delivered, the
POTV must complete the above-mentioned steps using the shipping paper in place
of the manifest.

     The POTV is required to note any significant manifest discrepancies on
each copy of the manifest.  Manifest discrepancies are differences between the
type and/or amount of hazardous vaste designated on the manifest and that
received by the facility.  A significant discrepancy is defined as:

     •  A difference in weight of greater than 10 percent for bulk shipments
     •  Any variation in the piece count for batch deliveries
     •  Any obvious difference in waste type that can be discovered by
        inspection or waste analysis.

If a discrepancy is found either prior to or after waste analysis, the owner
or operator must attempt to reconcile the discrepancy with the generator or
transporter.  If the discrepancy is not resolved within 15 days after the date
of delivery, the TSDF must send a letter to the Regional Administrator that
includes a description of the discrepancy, the attempts to reconcile it, and a
copy of the manifest.

     Although the permit by rule regulations do not explicity require a POTV
to undertake a waste analysis of manifested waste, the regulations do require
POTVs to report significant discrepancies.  To adequately identify significant
discrepancies it is recommended that, at a minimum, a rudimentary waste
analysis be undertaken.  Only then could a POTV protect itself from violating
the permit by rule by failing to report a significant discrepancy.

     POTVs subject to a permit by rule are required to file an unmanifested
waste report if hazardous waste is accepted from an offsite source that is not
accompanied by a manifest or shipping paper and is not excluded from the
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manifest requirement by the small quantity generator regulations (see Section
2.3.1.  This requirement does not apply to hazardous waste arriving at the
POTW by dedicated pipeline).  The report must be submitted to the EPA Regional
Waste Management Division or the authorized State agency on EPA Form 8700-13B
(the Biennial Report Form) within 15 days after receiving the waste.  A copy
of this form is provided in Appendix F-3.  The Unmanifested Waste Report must
contain the following information:

     •  The EPA identification number, name, and address of the facility
     •  The date the waste was received
     •  The EPA identification number, name, and address of the generator and
        the transporter, if available
     •  A description and the quantity of each unmanifested hazardous waste
        received
     •  The method of treatment, storage, and disposal for each waste
     •  The certification signed by the owner or operator of the POTW or his
        authorized representative
     •  A brief explanation of why the waste was unmanifested, if known.  •

     When a facility receives an unmanifested hazardous waste that  is pur-
ported to be excluded under the small quantity generator requirements, it is
recommended that the owner or operator obtain a certification from  the
generator that the waste qualifies for the exclusion.  Otherwise, the owner or
operator should file an unmanifested waste report.

4.4.3  Operating Record
     Under the permit by rule conditions, the POTW owner or operator is
required to maintain operating records (40 CFR Part 264.73 (a)-(b)(l)).  The
operating record must contain the following information as it becomes avail-
able, until the POTW ceases to engage in  the treatment, storage, or disposal
of hazardous waste:

     •  A description of the type and quantity of each hazardous waste
        received
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     •  The method and dates of hazardous waste treatment, storage, or
        disposal at the facility, as per Appendix I of the RCRA regulations.

     Appendix I of Part 264 requires each hazardous waste to be described in
the operating record by its common name and, if the waste is listed, by its
EPA Hazardous Waste Number(s) (from Part 261, Subpart D).  If the waste is not
listed, the description must include the production process.  The record also
must describe the waste's physical form (i.e., liquid, sludge, solid, or
contained gas); the estimated or manifest-reported weight, or volume and
density, where applicable (specified in Table 1 of the Appendix); and the
method(s) of treatment by handling code(s) (specified in Table 2 of the
Appendix).

4.4.4  Biennial Report
     Under 40 CFR Part 264.75, owners or operators of TSDFs, including POTWs
with permits by rule, must submit biennial reports to the EPA Regional Waste
Management Division or the appropriate State agency by March 1 of each even-
numbered year.  The report, to be filled out using EPA Form 8700-13B (Appendix
D-3), details the facility's treatment, storage, and disposal activities of
the previous odd-numbered year.  The following information must be included in
the report:

     •  The EPA identification number, name, and address of the facility
     •  The calendar year covered by the report
     •  The EPA identification number for each generator from which hazardous
        waste was received
     •  A description and the quantity of each hazardous waste received during
        the year, listed by the EPA identification number of the generator
     •  The method of treatment, storage, or disposal for each hazardous waste
     •  The certification signed by the owner or operator of the facility or
        his authorized representative.

4.5  CORRECTIVE ACTION
     The November 1984 Amendments to RCRA included a provision (RCRA Section
3004(u)) that requires:
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        .  .  .  corrective action for all releases of hazardous waste
        or constituents from any solid waste management unit at a
        treatment, storage or disposal facility seeking a permit
        under this subtitle, regardless of the time at which waste
        was  placed in the unit.  Permits issued under section 3005
        shall contain schedules of compliance for such corrective
        action (where such corrective action cannot be completed
        prior to issuance of the permit) and assurances of financial
        responsibility for completing such corrective action.

Under this new requirement, permit by rule POTWs with NPDES permits that are
issued after November 8, 1984, or that are first covered by a permit by rule
after November 8, 1984, are subject to RCRA corrective action requirements
({270.60(c)(3)(7).  Unlike  the other permit by rule requirements, corrective
action requirements may result in a POTW being subject to substantial costs
associated with  treating, storing, and disposing of hazardous waste.  Correct-
ive action, under RCRA, encompasses corrective measures  to clean up any
release of hazardous waste  or hazardous constituents  from a solid waste man-
agement unit  that may  result  in hazards to human health  or  the  environment.
Moreover, the requirement  is  not  triggered by whether or not  the  facility  is
in compliance with RCRA and CWA regulations.  Potential  corrective  action
activities include:,   initial  investigations  of  the nature and  extent of any
releases, (e.g.,  sinking  of monitoring wells and sampling and  analysis);
interim measures to  control the contamination;  necessary corrective measures
(e.g., ground water  pumping);  and post-corrective  measure monitoring and
assessment.   Thus,  the term corrective action refers  not only  to  actual
cleanup measures, but any actions that may  need to be taken prior to actual
cleanup.

      The  intensity of corrective  action requirements will depend on the
severity  of  any releases of hazardous waste or hazardous constituents  (see
Section 2.2.2 for a discussion of Appendix VIII hazardous constituents).   The
scope of  the requirement is potentially large in that it would cover not only
 those units  that accepted hazardous waste,  but all solid waste management
 units (e.g., containers, tanks, waste piles, surface impoundments, landfills,
 and perhaps most significant for POTWs, wastewater treatment units).   More-
 over, it  covers not only hazardous wastes, but hazardous constituents from
 solid waste management units.  For example, EPA could require a POTW to pump
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and treat ground water from an aquifer that was contaminated by hazardous
constituents emanating from the POTV's surface impoundments.  Thus, EPA could
mandate cleanup of any solid waste management unit at the POTV that handled
solid wastes, irrespective of whether that unit ever handled hazardous wastes.

     At the very least, POTWs likely will be asked to provide background
information on the number of solid waste management units it operates, the
nature of the waste disposed in those units, any evidence of past releases at
those units, and information concerning the amount of waste handled, the
location of the facility, and unit design information.  POTVs also may be
directed to conduct more indepth sampling for contamination of soil, ground
water, and surface water and air releases.  Finally, corrective measures may
need to be taken.  The corrective action process is more fully described in
the Guidance for Implementing RCRA Permit By Rule Requirements at POTWs.  The
first phase of corrective action, the RCRA Facility Assessments is more fully
described in the Guidance for Conducting RCRA Facility Assessments at POTVs.
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APPENDIX A



RCRA LISTS

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. I
                                               APPENDIX A-l



                                        RCRA LISTED HAZARDOUS VASTES
                                                   A-l

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                        HAZARDOUS  HASTE  FROM  NONSPECIFIC  SOURCES  (F LIST)

                                                 40  CFK PART 261.31
                                                                                             ID tuttutt tot »iui*»'i at
                                                                                            or axe-MumnM piakng on careen
                                              131 a
                                               •m an. arc ana amnamni piaang an caraan oaat and («) amnuu aictimg ane mama ot Hummm
                                                                                                                           (T)
FOOT ----------------  Seam, Cyanaa pMng DMI *okitara Ham ii«eirm»«iig operaaona.                                                <«. T)
KOI -------------  M«n« Muooaa from tna ootMm at piaang MO* from iinuuplaang uuomoiu »*ara eyanrtaa are uaea «i me pracaea         (H. T)
root --------------  Soem «apome, end Maenad, Bern »om»on« (TBJI» «»e»op<«»«» optrnuia «o»m cyoimx «• ima in »• oraeo*.             («. T)
FO1&___ - — __  Omnrtimq imi mulim trnm IK imnt fmm nmM in« imam mmuum *mt t)»mt»t m m«l " n» immn            ;N.T>
                                                                                                                         (*• n
                                                                                                                         (T)
                                                        ClfBOB OOHHM IfOfll OIM W th*O» uBttWfl &••
                                           r ana apam green from nydrogan emonda punlfceBen) from ma omoueaen or manufacmng uaa (aa a (Hi
                                                  r eompoiiem n a fermuiaang pnacaiil of m- or •wacrnorecrtanot et Of imermeaaea uaad to
                        prooue»»i«iroM>aa»a»ii»«»««».(T>«»i.«iriBae^notiriauai HMMI iram v* poauaon at t
                        mm Ngn* gunOM 2.4. J^nemoroononci.L
                            («K*M iiMnmaf «nd warn eveon (ram nrttujx CMOM* ounfcmont (ram m» oredueaon or manufacturing UM IM < IH)
                                                 or i-anmumni n • tormuiMng proeoM ot pwiMnoroenonok or of murnnuMm UMO to
                                            •M iwrn eareon from nyorooon cMono* purification) from «• manufaetunng uaa (a* a raacan.    (H)
                                          or ummumm m a famMamg prptaaal of taffa-. pan». or nnacnorooanxarwa undar

KM __________________________ WaatH in Dip! iiaaaniaiar and tpant careen tram nyoraoan cwonoa punfcawn) (rent «• preducaon of maianala on aqupmani |M>
                         tfr»»Buar» uaad for ma producnon or manufaounoa, uaa (aa • raacant ummut miarirndiaia. or lemeenam m a tarmuaong
                                      from niojnrf punflad 2.4.5HVicMoropnanoi.l.
                                          r and •aam emen from nyoroaan emonda punflcaaeni Iram ma praoucnen of maianala on •quiemant (H)
                                t uaad for me manulanunng uaejaa a raactam. cnamcal marmedMte. or component, M a tormmaang proceaai
                         of tava*. panoj*. or neEaBMerooansana under antenna condnena.
rear		 necareae unuaad formmeaena eernaMng m-. am- or panusrearopnanol or dtacaroed unuaeo formulation eemamug comoounea (H)
                         darned from mew cMoropnenota. (Tha Meng deee not moude fontMeeana eontaMnq Heucmoreonana lynmeiiiea from
                         preeunaad 2.4.i^iKnierecnanol aa ma tote component.).
             	naeiduae riejang tram me mui»aaon or merme) reaanant of tat uunammeiail oim Er>A Hazardous wane No». fOK. FO21.  (T|
                         roa «ax «oai and ran.



              OK41 amenoed By a M 47m July '«. «MO. renaed Dy 4S FW T4MO. NOMmoer 12. tNO 4t m 4117. January 16. t«ai. «6 FH
              2T4TB. Mey 20.1M1. 4t fH $313. Faeruary 10.19*»: M FN Ml. January 4.1*M:» FM I9t9. January <4. 198S1
                                                        A-2

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                              HAZARDOUS  HASTE  FROM  SPECIFIC SOURCES  (K  LIST)

                                                     40 CFR  PART  261.32
                                                                      M«urtau« .wo
                 Ma
                         Bottom Mttitxnt *uaq* Horn tn* tmim** ol ««»i»»«Mrt team «ood pnJMromq pnx«t«»* m»t u»« et*o«oio md/or p»nt»enioroonanoi    (T)
                                         t ttudo* (ram n* production at erirom* T»«o» «nd or«nqa pigment*			                  .   il
                                              > irom ma production o« moMxwl* or*r«»* pqrnmt*    	                  (T>
                                     Hm*m ikidq* »cm «w production ot ««e WHO* oiyn>«nt»,
v
Sanam »**m (ram «• M»t*>i«*r Mnaoar «i in* proaucnon ol *eryionrtni*			_	  iB n
Bottom tram Irom ma •coionrini* oommn « m* proaucnon ol «crriur»lni»  			  (A T>
Bonomt irom M «c«ior«tni* pun«c»«on column «in* praduaon ol «cryior»tr«»		_	—	—	  (T)
Sim bottom* Irom via »i«««»on al oarayt emend*.—	_						-  CH
H**V* *nd* or mMMen tnatn Irom via produuian ol caraon uraemonaa...._			_	  (T)
         (•M bmaiim Ham n* punUcMon cawm «»••«• producttan ol *pcnior»n>uni		_ 	  (T)
                                                                                                         in
                                                                                                         (T)
                                                                                                         (T)
                                                                                                         m
                                                                                                         m
                                                                                                         m
                                                                                                         en
                                                                                                         m
                                                                                                         m
                                                                                                         m
                                                                                                         m
                                                                                                         (H.T)
                                                                                                         in
                                                                                                         in
                                                                                                         in
                                                                                                         m
                                                                                                         in
                                                                                                         m
                                                                                                         tn
                                                                                                         m
                                                                                                         m
                                                                                                         m
                                                 g< vnpt cmana* « MM cnana* monam*!
                                                         al ort*noM *c*ton* trattt
                                                       ol PMTIMC mMndi
                                                        al ptiitmc mmand*
                                                       ol piwtitc «wt>qr«i» Mont mxo nnm
                                                       of rMob*ttt*n* by yi* nMrMOf) ol
                                                                          at i.t.Hncru
                                                      «t in*praduaon at t.i.i
                                                      al 1.1.1-lncnaieamvM
                                                  ootom from «• produnun al 1.1.1-ctcMoroWwia
                                                                       ol (KNeroHiM
                                                       •om K* araduoan ol
                                                         •am •• eraducMn at
                         WMMMIVMWMnlMldl
                                               ma produoan ol M3MA «nd CKOIKK »od
                                  Iron mt Mman ol
                         vwuum «noa*r aaenaro* irom m*
                         w
                                                             oroduG*ori ol crooioM
                                                             tft tft* produciiort ol
                         SM bonom* Irom toMrw f
                                             )*t tram f» oroduaon at **mloion.
                         WMHMMT Ham m*
                         Bdar c*u trom m* Mman al
                                                                   •ad n M prgductan at pr
                                               •om «* pradueHn ot
                                             •rom »» oroduaon ol i«-0

                                                tram no manuUewina tomuuMn wd laadna ol
                          Oino>nd • Hainan (OAT) «M« *am «•
                          SUP o< *muMan MM* •am •• pamMum r*mnt «du«v
                                      t
                                 concal auifSudo* »om m* pnmny pradHCian ol Maal * *ae»« lumwM
                          Soon pew* •quar fcom w**t kMIMig BptrMoni —
                                 control amt'«>ida» irom «aeondii> *«d vr^m)
                                         oon irom too iMawig 01 onuian conm duM/ifeao* "om taeonairy >**d imaung
                                                                      «> m* produofln ot »»i«n«*>y muniittmxM* Horn
   KMT
C6I J: amended b» 45 FR 47gJ3. Jul> .16. 1980: 45 FR '2039. Octbher .'0.  !•»«): re»i$ed bv 45 FR
74980. November 12.  1980: 46 FR 4617. January  16. 1981: 46 FR r476. Ma> 20.
                                                            A-3

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1A3.4.10.
  1.4.4«*8.7
  1
1,24.4.10,1
  1.4.4&SA7
  1.
                                                                                                    tad. O.O<«H>i

                                                                                                    Mid. 0.0a«»>i O- pymnyi
A-4

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A-5

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             DISCARDED COMMERCIAL CHEMICAL PRODUCTS,  OFF-SPECIFICATION SPECIES,
        CONTAINER RESIDUES, AND SPILL  RESIDUES  IDENTIFIED AS TOXIC WASTES (U  LIST)
                                        40 CFR PART 261.33(f)
JOOS
J'-2
.•002
U003
'.004
U009
jooe
J007
UOM
U009
UIM
    tea. tm> «w HI
Ac«e aoa '«o mi
•kctnc tea. mu-umii uii
Action* in
*c«iomm« ii Ti
         J-
-------
                                                                             1C tad. 9C-;c4PO. 2.3-aorono-
                                                           • Pr>o«noi 2 J-4WO-
                                                          2-*«o«(«on« ID
                                                                         3-acraoro-
                                                                           ;.2.3.3.3-n«.»«fii
-------
         APPENDIX A-2

40 CFR PART 261, APPENDIX VIII
LIST OF HAZARDOUS CONSTITUENTS
              A-8

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      Amaroxx VIII—HAZAJUXJTJI
            COHSTITOBm

Acetonltrtle (Ethanenltrile)
Acetophenone (Ethanone. 1-phenyl)
S-(alpha-Aeet0nylbettsylM-
  hydroxyeoumarin and salts (Warfarin)
2-Acetylamtnofluorene  (AceUmlde. N49H-
  nuoren-2-yl>-)
Acetyl chloride (Ethanoyl chlortdt)
l-Acetyl-2-thlourea  (Aceumide. N-(amuv
  othioxomethyl)-)
Aeroleln (2-Propenal)
Acrylmmide (2-Propenamide)
Acrylonitrlle (2-Propenenitrile)
Aflatoxins
Aldrta           (1,2,3.4.10.10-Hexachloro-
  1.4.4aJ.8.Sa.8b-hexahydro-endo.exo-
  I.fc8.t-Dunethanonaphthalene)
Allyl alcohol (2-Propen-l-ol)
Aluminum phosphide
4-Aminoblphenyl([l..r-Blphenyl3-4-anune>
6-Amino-l.la.2.8.8a.8b'hexahydro-»>
  (hydroxymethyl)-»a-methoxy-5-methyl-
  carbamate    azlrinol2'.3':3.4JpyiTOloU.2-
  altndole.4.7-dlone. (ester) (Mltomycin O
  < AzlrlnoC2'3':3.4 JpyrroUx 1.2-a)lndole-4.7-
  dione.              8-aminc-8-t((sinino-
  carbonyl>oxy>methylM.la,2.8.8a.ab-
  hexahydro-8amethoxy -5-methy •)
5-(Aminomethyl)-3-lsoxazolol <3(2H)-Isox»-
  zolone,  5-(anxtnom«thylM  4-Aimnopyri-
  dine (4-Pyrtdlnamine)
Amltrole (lH-1.2.4-Trtazol-3-amlne>
Aniline (Benzenamine)
Antimony and compound*. N.O.S.'
AramlU (Sulfurous add. 2-chloroethyl-, 2-
  (4--2-naphthylamlne
  (Chlornaphazine)
Bls(2-chlorolsopropyl) ether (Propane. 2.21-
  oxyblst2-chloro-])
Bls ester)
  •The abbrevtation N.O.S. (not otherwise
 specified) signifies those members of the
 general class not specifically listed by name
 In this appendix.
Bromoacetone (2-Propanone. 1-bromo-)
Bromomethane (Methyl bromide)
4-Bromophenyl phenyl ether (Benzene. 1-
  broroo-4-phenoxy-)
Brucine (Strychnidln-10-one. 2.3-dlmethoxy-
  )
2-Butanone peroxide  (Methyl  ethyl ketone.
  peroxide)
Butyl benzyl phthalate (1.2-Benzenedicar-
  boxylic acid, butyl phenylmethyl ester)
2-sec-Butyl-4.6-dlnitrophenol      (DNBP)
  (Phenol. 2.4-dlnltro-6-< 1 -methylpropy 1 >- >
Cadmium and compounds. N.O.S.'
Calcium  chromate (Chromic  acid,  calcium
  salt)
Calcium cyanide
Carbon disulflde (Carbon bisulfide)
Carbon oxyfluoride (Carbonyl  fluoride)
Chloral (Acetaldehyde. trlchloro-)
Chlorambucll  (Butanoic   acid.  4-Cbls<2-
  chloroethyDaminolbenzene-)
Chlordane (alpha and gamma laomers) (4.7-
  Methanoindan.   i.2.4.5.8.7,8.8-octachloro-
  3.4.7.7a-tetrahydro-) (alpha and  gamma
  isomers)
Chlorinated benzenes. N.O.S.*
Chlorinated ethane, N.O5.'
Chlorinated nuorocarbons. N.OA'
Chlorinated naphthalene. N.O.8.*
Chlorinated phenol. V.O&.'
Chloroacetaldehyde (Acetaldehyde. cnloro-)
Chloroalkyl ethers. H.O A*
p-Chloroanillne (Bencenamine. 4-chloro-)
Chlorobemene (Bensene. cnloro*)
ChlorobenHlaU   (Benseneacetlc  add.   4-
  chloro-alpha4i-chlorophenylv«lDha-
  hydroxy-, ethyl eater)
2-Chloro-l. 3-butadien* (chloroprene)
p-Chloro-m (Thlouree,  (2-
  chlorophenylV)
3-Chloropropene (allyl chloride)
3-Chloroproplonltrue   (PropanenltrUe.   3-
  chloro-)
Chromium and compounds. N.O.S.*
Chrysene (l^-Bensphenanthrene).
Citrus  red   Mo.  2   (2-Naphthol.  1-U2.5-
  (llmethoxyphenyDasol-)
Coal tan
Copper cyanide
Creosote (Creosote, wood)
Cresols (Cresyllc add) (Phenol, methyl-)
Crotonaldehyde (2-Butenal)
Cyanides (soluble salts  and complexes).
  H.OA*
Cyanogen (Ithanedinltrile)
Cyanogen bromide (Bromine cyanide)
Cyanogen chloride (Chlorine cyanide)
Cyeasin  (beta-D-Olucopyranostde. (methyl-
  Oim-asoxy)methyl-)
2-CyclohexyM.6-dlnitrophenol (Phenol. 2-
  eyclohexyl-4.e-dInltro->
Cydophosphamlde    (2H-1.3.2.-Oxaaphos-
  phortne.  Cbls(2«chloroethyl)ainino]-tetra-
  hydro-. 2-oxide)
Daunomydn  (S.12-Naphthacenedlone.  (88-
  ds)-S-acetyl-10-C(3-amino-2.3.a-trldeoxy>-
  alpha>L-lyxo-hexopyranosyl>oxy]-7.8.9.10-
  tetrahydro4.8.11-trihydroxy.l-methoxy-)
                                               A-9

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DDD    (Dlchlorodlphenyldlchloroethane)
  (Ethane.      l.l-dlchloro-2.2-bts(p-chloro-
  phenyl)-)
DDE (Ethylene. l.l-dlchloro.2.2-bU(4
DibenzCaJlacrtdlne (1.2.7.8-Dlbenzacridlne)
Dlbenz(a.h]anthracene (1.2.S.O-Dlbenzanth-
  racene)
7R.DIbenzoCc.f Icarbazole (3.4.5.8-Dlbenzcar-
  bazole)
Dlbenzo(a.elpyrene (1.2.4>Dlbenspyrene)
DlbenzoCaJilpyrene (lA9.<-Dtbenzpyrene>
DibenzoCaaipyrene (1.2.7.8-Dlbenzpyrene)
1.2>Dlbromo-3-chloropropane (Propane. 1.2-
  dlbnmo-3-cnlore-)
U-Dibromoethane (Ethylene dibromide)
Dlbromomethane (Methylene bromide)
Dt-n-butyl phthalate (U2-Benzenedicarbox-
  ylle add. dibutyl ester)
o>Dlchlorobenzene (Benzene. 14-dicbloro-)
m-Dlchlorobenzene (Benzene. i.3-dlchloro-)
DlehlorobtnoM. M.OA*
  dlchloro-. N.OA*)
S^'-DlehlorobnoldlM  (Cl.r-BtpbenyU-4.4'-
  dtamizM. 34'-dlchloro.)
1.4-Dlebloto.»«ttt«M  (2-Buuoa.  1,4-dlch-
  IOPO-)
DIcbiorodlfluoroBMthant  (ItetluiM,  dlch-
  lorodlfluoro-)
U-Dleblototttua* (BthyUdtnt dlchlortd*)
U-Dlchlora«tbaM (Etbylcn* dlchlortda)
truf 14-DtebloiMUMiw (U-Dlchlorotthy-
                  N.OA' )
2.«.DIebloropaenol (Phenol. 2.»-dlchloro-)
2.4-Dlehloropheaoxyveette add (2.4-D). alto
  and  ««ter» (Aoede add, 2.4-dlchlorephen-
  oxy-, ialU and eiten)
Dlchlorophenylanlne (Phenyl dlchloroar-
  Une)
Dtehlofonropane. X.OA*  (Propane,  dlch-
  loro-. N.OA*)
1.2-Dtehloropropane (Prepylene dtehlortde)
Dtchloropropanol. N.OA*  (Propanol. dich-
  lore-. N.O A«)
Dtehloroprepene. N.O.S.*  (Propene.  dlch-
  lore-. N.OA')
U-Dlchioropropene  (1-Propene.  IJ^lch-
  loro-)
Dteldrtn (lJ4.4,10.10-h«Mchloro-«.7^poxy.
                        '-Btoxlnae)
 Dlethylamne (Antne. dlethyl-)
 NJI-Dlethylhydrajtoe    (Hydraine.   1>
  diethyl)
 O.O-Dtethyl  8-methyl ester of photphora-
  dlthiolc  add  ethyl]-)
DUaopropyinuoraphosphat*  (DPP)  (Phos-
  phoronuoridlc   add.  bUd-methylethyl)
  ester)
Dlmethoate  (Phosphorodtthiolc add. O.O-
  dlmethyl S-C2-(methylamlno>-2-oxoethyl]
  ester
3.3'-Dlmethoxybenzidlne   (Cl.r-BlphenyO-
  4.4'diamine. 3-3'-dlmethoxy->
p*Dlmetnylamlnoacobenzene (Benzenamine.
  NJ(-dlmethyl-4--)
7.12-DlmethylbencCa)anthraeene   (1.2-Ben-
  zanthracene. 7.12-dlmethyl-)
3.3'-Dlmethylbenzldlne (tl.l--Blphenyn-4.4--
  dlamine. 3J'-dtmethyl->
Dlmethylcarbamoyl  chloride  (Carbamoyl
  chloride, dimethyl-)
1.1-Dlmethylhydrazine (Hydrazine,  1.1-dl-
  methyl-)
1.2-Dlmethylhydnzine (Hydrazine.  U-di-
  methylo
3,3-Dtmethyl-l--2-butaaone.  O-
  [(methylamlno)  carbonyUoxlme  (Thio-
  fanox)
tlpha.alpha-Dlmethylphenethylamme (Eth-
  anamine, l.l-dimethyl-2-phenyl-)
2.4-Dlmethylphenol (Phenol. 2.4-dlmethyl-)
Dimethyl phthalate (1.2-Benzenedlcarfooxy-
  lie add. dimethyl ester)
Dimethyl sulfate (SuUurte  add.  dimethyl
  ester)
Dinitrobenzene. V.OA* (Benzene, dinitro-.
  N.O.S.')
*.«-Dtnltro-o-cresol and salts (Phenol.  2.4-
  dlnltro^-methyl'. and salts)
2.4-Dlnltrophenol (Phenol. 2.4-dinltra-)
2.4-Dlnltrotoluene (Benzene. 1-methy 1-2.4-
  dinitro-)
2.6-Dlnitrotoluene (Benzene, l-methyl-2.0-
  dinitro.)
Di-n-octyl phthalate <1.2>Benzenedtearboxy-
  llc acid, dloctyl ester)
1.4-Dioxane (1.4-Dlethylene oxide)
Diphenylamine (Benzenamtne. N-phenyl-)
l.2-Dlphenylhydrazine (Hydrazine.  1.2-dl-
  Phenyl-)
Di-n-prapylnitrosaBilne (N-Nltro«o-di-n-pro-
  pylamine)
Disulfoton        (Q.O-dlethyl        8-C2-
  (ethylthio)ethyl] phosphorodlthloate)
2.4>Dlthiobluret  (Thloimldodiearbonlc  dia-
  mide)
Endosulfan (5-Norbornene. 2.3^Umethanol.
  1.4J.6.7.7-hexaehloro>. cyclic sulflte)
Endrin  and metabolites  (1.2.3.4.10.10-hex-
  achloro-«.7-epoxy.l.4.4aJ.o.7.S.aa-
  fffTahyUro eodo,eiMto 1.4:5,8-
  dimethinonaphthalene. and metabolites)
Ethyl earbamate (Urethan) (Carbamic add.
  ethyl ester)
Ethyl cyanide (propanenltrile)
Ethylenebisdlthlocarbamic  add.  salts and
  esters  (1.2-Ethanedlylblscarbamodlthloic
  add. salts and esters
 Ethyleneimine (AzWdine)
 Ethylene oxide (Oxirane)
 Ethylenethiourea (2-Imidazolldlnethione>
 Ethyl methacrylate (2-Propenoic  add.  2-
  methyl-. ethyl ester)
 Ethyl methanesuUonate (Methanesulfonic
  add. ethyl ester)
 Fluoranthene (Ben»U^]fluorene)
 Fluorine
                                               A-10

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 3-Pluoroacetamide (Acetamlde. 2-fluoro->
 PluoroaceUe add. sodium nit (Acetic add.
   fluoKK Mdlum nit)
 Formaldehyde (Methylene oxide)
 Formic add (Methanolc add)
 Olyddylaldehyde (l-Propanol-2.3-epoxy>
 Halomethane. N.O A«
 Hepuchlor        (4.7-Methano-lH-tndene.
   1.4.S.6.7.«.S-heptachloro-3«,4.7.7a-
   tetrahydro-)
 Hepuchlor   epoxlde  (Alpha,  beta,  and
   gamma isomers)  (4.7-Methano-lH-lndene,
   1.4.5.6.7.8.S-heptachloro-2.3-epoxy-3a.4.7.7-
   tetrahydro-, alpha, beta, and gamma iso-
   men)
 Hexachlorobenzene (Bensene. hexachloro-)
 Hexachlorobutadlene       (1.3-Butadlene.
   U.2.3.4.4-hexachloro->
 Hexachloraeyclohexane  (all isomers)  (Un-
   dane and isomers)
 Hexachlorocyclopentadlene  U.3-Cyclopen-
   tadlene. 1.2.3.4.5.5-hexachloro»>
 Hexachlorodlbenzo-p-dloxins
 Hexachlorodlbenzorurans
 Hexachloroethane  (Ethane. l.U.2.2.2-hex-
   achloro-)
 1.2.3.4.10.10-Hexachloro-1.4.4a.9.8.«a-
   hexahydro-1.4:S.8-endo.endo-
   dlmethanonaphthalene (Hexachlorohexa-
   hydro-endo.endo-dlmethanonaphthalene)
 Hexachlorophene  (2.2'-Methylenebls(3.4,6-
   trlchlorophenol) >
 Hexachloropropene (1-Propene.  1,1.2.3,3.3-
   hexachloro-)
 Hexaethyl    tetraphosphate   (Tetraphos-
   phoric acid, hexaethyl ester)
 Hydrazine (Dlaralne)
 Hydrocyanic acid (Hydrogen cyanide)
 Hydrofluoric acid (Hydrocen fluoride)
 Hydrogen sulflde (Sulfur hydride)
 Hydroxydlmethylanine  oxide  (Cacodytic
   acid)
 Indeno(1.2.3-cd)pyrene           U.IO-U.2-
   phenylenopyrene)
. lodomethane (Methyl iodide)
 Iron dextran (Ferric dextran)
 Isocyanic  acid,  methyl  eater (Methyl Uo-
   cyanate)
 Isobutyl alcohol (1-PropanoL 2-methyl-)
 Isoaafrole (Benzene. 1.2>methylenedloxy-4-
   allyl-)
 Kepone  (Oecachlorooctahydro-l.3.4-Meth-
   ano-2H
   methyl-l-oxobutoxy)methyi}-2.3.3.7a-
   tetrahydro-lH-pyTTOliztn-l-yl eiter)
 Lead and compound*. N.O.3.'
 Lead acetate (Acetic acid, lead salt)
 Lead phosphate (Phosphoric acid,  lead salt)
 Lead    subacetaM   (Lead.   btxacetato-
   OttetrahydroxytriO
 Mtieic anhydride (2.5-Furandione)
 Malete hydraalde (U-Dlhydro-3,«-pyrtdazin-
   edlone)
 Malononltrue (PropanedlnltrUe)
 Melphalan      (Alanine.       3-(p-blK2-
   chloroethyl)amlnolphenyl-. L-)
 Mercury ^''min*'-* (Fulminic  add. mercury
   •alt)
 Mercury and compounds. N.O.S.*
 MethacrylonitrUe   (2-Propenenltrlle.   2-
   methyl-)
 Methanethlol (Thlomethanol)
 MethapyrUene      (Pyridlne.       2-((2-
   dlmetnylamlno)«thyU-2-thenylamlno-)
 Metholmyl    (Acetlmidlc     add.     N-
   [(methylrarhamoyPoxylthte-.     methyl
 Methoxychlor (Ethane, l.l.l-trlchloro-2.2*-
   bls(p-methoxyphenyl>>)
 2-MethylazWdine (1.2-Propylenimine)
 3*Methylcholanthrene
   (BenzCj]aceanthrylene.      1.2-dihydro-3-
   methyl-)
Methyl  chlorocarbonate  (Carbonochloridlc
  add. methyl nter)
4.4'-Methylenei jM2
  droxy-2-methyl-)
Methyl  methaerylate (2-Propenole add. 2-
  methyl-. methyl ester)
Methyl methanesuUonate (MethanetuUonlc
  add. methyl ester)
2-Methyl-2-(methylthlo)proplonaldehyde-o-
  (methylcarbonyt)   oxime  (Propanal.  2-
  methyl-2-(methylthlo>-.               O-
  C(methylamlno)carbonylloxlme)
N-Methyl-N'-nltro-N-nitrosofuanidlne (Oua-
  nldine. N-nltroso-N-methyl-N'-nltro-)
Methyl  parathlon (O.O^lmethyl -3-U-
  methyl-2-pyrrolldinyl)-. and salts)
Nitric oxide (Nttrocen (II) oxide)
p-NltroanUine (Benzenaoune. 4-nltro-)
Nltrobenztne (Benzene, nitro-)
Nitrogen dioxide (Nitrogen (IV) oxide)
Nitrogen  mustard and hydrochtoride  salt
  (Ethanamine. 2-chloro-. N-<2-chloroethyl>-
  N-methyl-. and hydrochloride salt)
Nitrogen  mustard  N-Oxlde and hydrochlo-
  ride salt  (Ethanamine. 2-chloro-.  N42-
  chloroethyD'N-metbyl-. and hydrochlo-
  ride salt)
Nitroglycerine   (1.2,3-Propanetriol.   trial-
  trate)
4-Nltrophenol (PhenoL 4-nltro-)
4-Nltroquinoline-l-oxide (QulnoUne. 4-nltre-
  l-oxide-)
Nltroaamine. N.O A»
N-Nltrosodi-n-butylamine   (1-Butanamine.
  N-butyl-N-nitroao-)
N-Nltrosodiethanolainlne   (Ethanol.   2.21-
  (nitrosolmino)bls-)
N-Nttrosodlethylamlne   (Ethanamine.   N-
  ethyl-N-nltroeo-)
N-Nltrosodlmethylamlne  (Dtmethylnltrosa-
  mine)
N-Nltroao-N-ethylurea (Carbamide. N-ethyl-
  N-nltroso-)
N-Nltraeomethylethylaoilne  (Ethanamine.
  N-methyl-N-nitroso-)
N-Nltroso-N-methylurea   (Carbamide.  N-
  methyl-N-nitroMK)
N-Nltroao-N-methylurethane    (Carbamic
  add. methylnitroeo-, ethyl ester)
N-Nltroeomethylvtnylamine  (Ethenamine.
  N-methyl-N-nltroeo-)
N-Nltrosomorphollne (Morphollne. N-nltro-
  so-)
N-Nltrosonomlcotlne (Nomlcotine. N-
  nltroso-)
N-Nltrosopipertdine  (Pyridlne. hexahydro-.
  N-nltroso-)
Nltrosopyrrolldlne (Pyrrole, tetrahydro-. N-
  nltroso-)
N-Nltrososareosine (Sarcosine. N-nltroso-)
S-Nltro-o-toluldine (Benzenamine. 2-methyI-
  5-nltro-)
Octamethylpyrophosphoramide    (Dlphos-
  phoramlde. octamethyl-)
Osmium tetroxide (Osmium (VIII) oxide)
7-OxabicydoC2.2.llheptane-2.3-dlcarboxyllc
  acid (Endothal)
                                               A-ll

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Paraldehyde    (U-S-Trtoxane.   2.4.6-trl-
  methyl-)
Panthion  (Phosphorothiotc  add.  O.O-
  dlethyl O-(p-nltropheayl> ester
Pentachlorobenzene (Benzene,  pentachloro-

Pentachlorodtbenzo-p-dloxins
Pentachlorodlbenzofurans
Pentachloroethane (Ethane, pentachloro-)
Pentachloronltrobenzene (PCNB) (Benzene.
  pentachloronltro-)
Pentachlorophenol (Phenol, pentachloro-)
Phenacetin    (Acetamide.     N-<4-ethoxy-
  phenyl)-)
Phenol (Benzene, hydroxyo
Phenylenediamine (Benzenediamiae)
Phenylmercury acetate (Mercury, acetato-
  pheayl-)
N-Phenylthlourea (Thiourea. phenyl-)
Phosgene (Carbooyl chloride)
Phosphine (Hydrogen phosphide)
Phosphorodlthioic  add.  O.O-dlethyl  8-
  KethylthionnethylJ ester (Phorate)
Phosphorothlotc add.  O.O-dlmethyl O-tp-
  «dimethylamino)suUonyl)phenyU  ester
  (Pamphur)
Phthalic add esters. N.OA' (Benzene. 1.2-
  dicarboxyllc *^*1. ester*. N.O A*)
Phthalic anhydride  (1.2-Benzenedlearboxy-
  Ue add anhydride)
2-PicoUae (Pyridtne. 2-methyl-)
Polyehlorlnated biphenyl. N.O A'
Potassium cyanide
Potassium silver cyanide (Artentued-). dl-
  cyano-, potassium)
Pronamide  (3.S»Dichloro-N-U.l-dlmethyl-3-
          *«w«
 l>Propane sultoae (l^Oxathiol
  oxide)
 n-PropylamizM (1-Propanamtne)
 Propyltbiouraea     (Undeeamethylenedia*
  mine.   Njr-Ms(2-«hlorooeniylX   dlhy-
  droehloride)
 J-Propyn-1-ol (Propartyl alcohol)
 Pyridiae
 Reserpine.  (Yohlmbmn-l$-c*iooxyUe  add,
  U.17-dtoethoxy.l8-t(3.4.5-
  tilmetboxybenzoyl)oxy]-. methyl ester)
 Resordnol (1.3-Bensenediol)
 Saocharm and salts (1 J-BenzolsothlasoUn>3-
  one. l.l-)
 Strontium sulllde
 Strychnine and  salts  (Strychnldln-10-one.
  and salts)
 1.2.4.5-Tetrachlorobenzene       (Benzene.
  1.2.4.5-tetrmchloro-)
 2J.7.a-TetrMhl0rodlDeno-p-dioxla (TCOD)
  (Dlbemo-p-dloxto. 2J.7>tetraehlora-)
 Tetrachlorodibemo-p-dioxins
 TetrachlorodibenBofunas
 TetMChloroethane. N.OA* (Ethane, tetra-
  chloro-. N.OA*)
 1.1.1.2-Tetrachlorethane  (Ethane.  1.1.14-
  tetrachloro-)
 1.1.2.2-Tetrmchlorethane  (Ethane.  1.1A2-
  tetnchlora-)
 Tetnehloroethane   (Ethene.  1.1.2.2-utrv
  chloro-)
 Tetrachloromethane (Carbon tetrmehloride)
 U.4.6,-Tetrachlorophenol (Phenol.  24.4.6-
   tetrachloro*)
 Tetraethyldithiopyrophosphate (Dithlopyr-
   ophosphoric add. tetraethyl-ester)
 Tetraethyl lead (Plumbane. tetraethyl-)
Tetraethylpyrophosphate  (Pyrophosphoric
  adde. tetraethyl ester)
Tetranitromethane (Methane, tetranitro-)
Thallium and compounds. tt.QA*
Thailie oxide (Thallium (IH) oxide)
Thallium (I) acetate (Acetic add. thallium
  (I) salt)
Thallium (I) carbonate (Carbonic add, dith-
  •Ilium (I) salt)
Thallium (I) chloride
Thallium (I) nitrate (Nitric add. thallium
  (I) salt)
Thallium lelenltC
Thallium (I) sulfate (SuUurtc add. thallium
  (1) salt)
Thioacetamide (Ethanethioamide)
Thiosemicarbazide   (Hydrszinecarbothloa-
  mide)
Thiourea, (Carbamide thio-)
Thiuram  (Bisidimethylthioearbamoyl)  dl-
  sulfide)
Toluene (Benzene, methyl-)
Toluenediamlne (Otaminotolueae)
o-Toluidine  hydrochloride (Benzenamlne. 2-
  methyl-, hydrochloride)
Tolylene dUsocyanate (Benzene. 14-dUso-
  cyanatomethyl-)
Toxaphene (Camphene. octachloro-)
Trtbromomethsne (Bromoform)
1.2.4-Trichlorobenzeae (Benzene. 1 4.4-trich-
  lore-)
1.1.1-Trtehloroethane (Methyl chloroform)
1.1.2-Trlchloroethane  (Ethane.  1.1,2-trlch-
  lore-)
Trichloroethene (Trtchloroethylene)
Trichloromethanethiol      (Methanethiol.
  trichloro-)
Trichloromonofluoramethane   (Methane.
  trlchlorofluoro-)
14.5-Trichloropheaol  (Phenol.  2.44-trich-
 2.4.e-Trichloropheaol  (Phenol.  2.4,6-trich-
  loro-)
 2.4.9-Trichlorophenoxyacetic add (2.4.5-T)
  (Acetic add. 2.4.S-trlchlorophenoxy->
 2.4.S-Tnchlorophenoxypropionie add (2.4.5-
  TP) (Silvex)  (Propionoic  add.  2-<2.4.5-
  trtehlorophenoxy >• >
 Trichloropropane.  N.OA* (Propane, trich-
  loro-. N.O-S.*)
 1.2.3-Trlchloropropane (Propane. 1.2.3-trich-
  lore-)
 O.O.O-Trtethyl  phosphorothioate  (Phos-
  phorothioic acid. O.O.O-trtethyl ester)
 syra-Trtnltrobenzene  (Benzene.  1.3.5-ulni-
  tro-)
 Trti(l-«zrtdlnyl) phosphine  sulftde (Phos-
  phine sulfide. trisU-aztrtdlnylo
 Trls(2.3-dibronwpropyl) phosphate d-Pro-
  panol.  2.3-dlbromo-. phosphate)
 Trypan   blue   (2.7-NaphthalenedUulfonlc
  acid.   3.3'-C(3.3'-dlmethyl( l.l'-blphenyl )-
  4.4>-dlyl)bls(azo>lbis(5-aBiino-4-hydraxy-.
  tetrasodium salt)
 Uradl    mustard    (Uradl     5>(bls(2-
  chloroethyl)aminol-)
 Vansdic add. ammonium salt  (ammonium
  vtnadate)
 Vanadium pentoxide (Vanadium (V) oxide)
 Vinyl chloride (Etnene. chloro-)
 Zinc cyanide
 Zinc phosphide
                                                 A-12

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           APPENDIX A-3

   40 CFR PART 261, APPENDIX VII
BASIS FOR LISTING HAZARDOUS VASTES
               A-13

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   Arrarexx VII—BASIS rox LISTING
           HAZAUOOS WASTX
                                                                               HUVOOU* con*mu«nu tor «ncn
  No.
FOOL.


woa-
noa.
«0*..
FOOT..
FOM-
F00»_
F010-
FOIL
F01J-
mai.
 F024
                  *. i»cnio>om«Bnn«. tacmeionxm-
          tncMorawiun*.  t i .Z-tneMofewMn*.
                  i.t.i.2-i«v»e-i>

 K001
Anwnony, csAon tcvMCMQnrtd
^"9MOi< tm (potycycK wvMhc

             . i.
                                                      A-14

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                      ?PA
                      aui        naurdoui con«itu»m» to> »nicn HUM
 V-  '
4
                                                                          A-15

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                APPENDIX B



EXAMPLE POTV SEVER USE ORDINANCE LANGUAGE

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     POTVs may wish to consider the following alternatives for sewer use
ordinance language to prohibit the discharge of hazardous wastes to POTV
headworks from a truck, rail, or dedicated pipeline.  Three different examples
are provided which address the three major degrees of regulatory control that
may be considered by a POTW:  (1) prohibiting the discharge of all hauled
wastes; (2) prohibiting the discharge of wastes from industrial sites; (3)
prohibiting the discharge of wastes containing industrial process waste; and
(4) prohibiting the discharge of hazardous wastes to the POTVs headworks.  For
POTVs that choose to permit haulers or generators, additional language is
provided which is applicable to the last three sample ordinances.

1. Example Sewer Use Ordinance Language for Prohibiting All Vaste Discharged
   to a POTV by Truck, Rail, or Dedicated Pipeline
     "No wastes, including any liquid, solid or septic wastes which are
generated at residential, commercial or industrial facilities, shall be
discharged to the sanitary sewer system by means other than a permanent sewer
connection to the public sewer system and in accordance with the regulations
contained in Section 	 of this ordinance.  This includes wastes which are
transported via truck, rail, or any other transportation means.  Further the
discharge of hazardous wastes (as defined in Section 1004 of the Resource
Conservation and Recovery Act) into a pipeline connected to th« public sewer,
which is dedicated to only the discharge of hazardous waste, is prohibited."

2. Example Sewer Use Ordinance Language for Prohibiting Wastes from Industrial
   Sites Discharged to a POTV by Truck, Rail, or Dedicated Pipeline
     "Haulers of septic wastes removed from residential customers are subject
to the terms and conditions for discharge as contained in Section 	 of this
ordinance.  Only septic wastes from residential sewage disposal systems (i.e.,
septic tank waste, cesspool waste) may be discharged into the public sewer
system by waste haulers at the discharge point specified by the (City, County,
Superintendent, etc.).  Any wastes, including septic wastes, removed by a
hauler from nonresidential, industrial, or commercial customers are specifi-
cally prohibited, and may not be discharged to the public sewer system.
Discharge of such nonresidential wastes into the public sewer system will
constitute a violation, and will subject the hauler to the penalties provided
for in Section     of this ordinance."
                                     B-l

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3. Example Sever Use Ordinance Language for Prohibiting Wastes from Industrial
   Processes Discharged to a POTW by Truck, Rail, or Dedicated Pipeline
     "Haulers of septic vastes (i.e., septic wastes, cesspool waste, portable
toilet waste) removed from residential, commercial, and industrial customers
are subject to the terms and conditions for discharge as contained in Section
_ of this ordinance.  Waste haulers must discharge hauled wastes at the
discharge point specified by the (City, County, Superintendent).  Wastes from
industrial or commercial sources are prohibited and may not be discharged by a
hauler to the public sewer system.  Discharge of such nonseptic wastes into
the public sewer system will constitute a violation of this ordinance, and
will subject the hauler to the penalties provided for in Section _ of this
ordinance."
A.   Example Sewer Use Ordinance Language for Prohibiting Hazardous Wastes
     Discharged to a POTV's Headworks
     "The discharge of hazardous wastes (as defined in Section 1004 of  the
Resource Conservation and Recovery Act) into a pipeline connected to  the
public sewer, which is dedicated to only the discharge of hazardous waste is
prohibited.  The discharge of hazardous wastes to the headwords of the  plant
by truck or rail is also prohibited.

5.   Example Sewer User Ordinance Language for Requiring a Permit to  Discharge
     Hauled Wastes
     "Any person engaged in  the hauling of septage wastes to the public sewer
system shall be permitted to do so.  A hauler shall obtain a permit from  the
(office, department, etc.).  Permitted haulers shall be responsible for
complying with all the terms and conditions contained in the permit,  in
addition to Section _ of this ordinance.  Any person discharging to the
public sewer system without  a permit will be subject to the penalties provided
for in Section     of this ordinance."
                                      B-2

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        APPENDIX C
EXAMPLE VASTE HAULER PERMIT

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                          EXAMPLE WASTE  HAULER  PERMIT
I.    AUTHORIZATION
     (Waste Hauler Name)
     Located at:(Waste Hauler Address)
     Is hereby granted this waste hauler permit in accordance with the
application filed on 	, 19	, in the office, of   (POTW)   ,
located at 	POTV Address	.  And, in compliance with the provisions
of the Federal Water Pollution Control Act as amended and provisions of
ordinances of the City of 	 and in conformity with plans, specifica-
tions, and other data submitted to the administrator in support of the
application, all of which are filed with and considered as part of this permit
under the following conditions and requirements:

II.  DISCHARGE REQUIREMENTS
     Designated Disposal Point(s)
     The waste-hauler must discharge all wastes at the following designated
area:  	.	.  Discharge may not
occur without prior notice to the plant operator-and without supervision by
plant personnel.

     Use of Waste Tracking System
     The waste hauler must use the POTW waste tracking form to record every
load that is pumped and delivered to the POTW.  Failure to accurately record
every load, falsification of data, or failure to transmit the form to the
plant operator prior to discharge may result in revocation of this permit or a
fine of up to $	 per offense.

     POTW Authorization for Hauling Industrial Waste
     Any waste which may be identified as a commercial waste or waste from an
industry identified by a SIC number must be presampled prior to pumping, and
the results of that sampling approved; and/or reviewed and determined by the
Administrator of the program to be safe for disposal to the POTW.  POTW
                                     C-l

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authorization must be presented to the septage hauler by the industry prior to
having waste pumped and hauled.  Any industrial waste that is incompatible
with the POTW operations or that violates Federal, State, or local restric-
tions may not be hauled to the POTV.

     Sampling of Waste
     Prior to discharge of hauled waste the waste hauler shall allow the POTW
operator or a designated representative to sample the waste to ensure com-
pliance with discharge limits and requirements.  The hauler may be required to
suspend the discharging of waste until the analysis is complete.  The POTW
reserves the right to refuse permission to dump any load that is suspected of
being incompatible or is so determined through sampling and analysis.

     Compliance with Categorical Pretreatment Standards
     Any waste transported from a industry subject to categorical pretreatment
standards must meet the applicable Federal categorical standards.  The gen-
erator must provide proof to the POTW of such compliance, and the POTW must
authorize the hauling of .categorical industrial waste, prior to pumping by the
permittee.

     Prohibitive Discharge Standards
     The permittee is prohibited from discharging wastes with the following
characteristics  [as dictated by 40 CFR 403.5(b)];

     •  Pollutants that will create a fire or explosion hazard
     •  Pollutants that will cause corrosive structural damage, but in no case
        discharges with a pH lower than 5.0
     •  Solid or viscous pollutants in amounts that will cause obstruction to
        flow
     •  Oxygen demanding pollutants discharged at a concentration or volume
        that will cause interference
     •  Heat in  amounts that will inhibit biological activity; in no case
        should discharges cause the POTW influent to exceed 104'F
                                      C-2

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 \.K             •  Any other  type of waste  that  may not  be  treatable  by  the POTW,  or will
 .;•'•-.                interfere  with the  operation  of the POTW (i.e.,  oil and  grease,
 ;•'-]                radioactive wastes,  or toxic  and hazardous wastes).

:. •             Local Discharge Limitations
               The permittee is prohibited  from discharging wastes which exceed the
          following limitations:

               Arsenic                	 mg/1
               Cadmium                	 mg/1
               Chromium               	 mg/1
               Copper                 	 mg/1
               Cyanide                	 mg/1
               Lead                   	 mg/1
               Mercury                	 mg/1
               Nickel                 	 mg/1
 .;             Silver                 	 mg/1
               Zinc                   	 mg/1
               Selenium               	 mg/1
               Grease and  oil         	 mg/1
               pH                     	 maximum
               pH        •             	 minimum

          III.  RESPONSIBILITIES AND  LIMITATIONS
               The permittee is responsible for protecting the domestic wastewater
          treatment works  from any contributing discharges which would  inhibit, inter-
 •:.         fere, or otherwise be incompatible with the operation or maintenance of the
          collection system  or treatment plant  including the use or  disposal of
          municipal sludge.

               Liability Insurance
               The permittee must carry liability insurance in such  amount and in such
:-"         form as shall  be determined by the POTV.   Such insurance shall afford bodily
          injury limits  of liability  of 	 for  each person injured and
          	 for each occurrence.   Evidence of such insurance  coverage shall
                                                C-3

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be provided to the POTW.  Nothing herein shall in any manner preclude the
permittee from obtaining such additional insurance coverage as may be deemed
necessary for his or her own protection.

     Notification of Change
     The permittee must notify the Administrator of any nev introductions or
contributions or any substantial change in pollutants being discharged.  Such
notification must include the source of the waste, identification of the waste
being discharged, the nature and concentration of pollutants in the discharge,
time, date, and cause of the change.

     Nontransferability
     In the event of any change in control or ownership, the permittee shall
notify the FOTV.  Also, the new owner shall be notified of this permit and its
limitations to afford the new owner an opportunity to apply for a new permit
without interruption of business or production.

IV.  ACTIONS FOR VIOLATION
                                             •
     Failure of the permittee to comply with any terms or conditions of this
permit will subject the permittee to the following actions:

     Cease and Desist
     Upon notification of permit revocation the permittee shall cease and
desist from discharging until a revised permit has been issued or the matter
has been resolved by court action.

     Remedies
     If any person violates any order of the administrator, a hearing board or
officer, or otherwise fails to comply with any provisions of this permit, or
discharges sewage, industrial wastes, or other wastes, into the POTW contrary
to  the provisions of this permit, Federal or State pretreatment requirements,
or  contrary to any order of the City or [POTW Name],  the City or  [POTW name]
may commence an action  in a court of record for appropriate legal and equi-
table relief.  In such  action, the City or [POTW name] may recover from the
                                      C-4

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defendant reasonable attorney fees, court costs, deposition and discovery
costs, expert witness fees and other expenses of investigation, enforcement
action, administrative hearings and litigation, if the City or [POTW name]
prevails in the action or settles at the request of the defendant.  Any person
who violates any of the provisions of this permit shall become liable to the
City or [POTW name] for any expense, loss, damages to the City, or to the POTW
occasioned by such violation.  In addition, upon proof of willful or inten-
tional meter bypassing, meter tampering or unauthorized metering, the City
shall be entitled to recover as damages three (3) times the amount of actual
damage.

     Misdemeanor
     Any person who violates or fails to comply with any provision of this
permit and permit conditions issued hereunder, shall be guilty of misdemeanor.
The penalty for such misdemeanor shall be a fine not to exceed 	 or by
imprisonment not to exceed 	, or both.  Each day in which any such
violation occurs or persists shall be deemed a separate and distinct offense.

     Penalty for False Statement and Tampering
     Any person who knowingly makes, authorizes, solicits, aids or attempts to
make any false statement, representation or certification in any permit
application, record report, plan or other document filed or required to be
maintained pursuant to this permit, or who falsifies, tampers with, bypasses
or knowingly renders inaccurate any monitoring device, testing method or
testing samples required under this permit shall be guilty of a misdemeanor,
and upon conviction thereof shall be punished by a fine not to exceed 	
or by imprisonment, not to exceed 	 or both.

     Remedies Cumulative
     The remedies provided for in this permit, including recovery of costs,
administrative fines and damages shall be cumulative and in addition to any
other penalties, sanctions, fines and remedies that may be imposed.
                                      C-5

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     Permit Revocation
     Revocation will be determined at the discretion of the program
Administrator.
Signed by:
Authorized POTW Representative:
Permittee:
                                      C-6

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        APPENDIX D
EXAMPLE VASTS TRACKING FORM

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                         EXAMPLE WASTE TRACKING FORM
                                                                Time
                                                                Date
WASTE HAULER INFORMATION
Company Name 	 Hauler I.D.# or Permit #_
Address
Telephone Number
Truck Make and Model
Truck Capacity       ""                        Truck License
Other permits:  Authority;                        Number:
SOURCE(S) OF WASTE
1)  Name of Company/Residence
    Name of Owner/Contact 	
    Address
    Telephone Number 	
    Type of Establishment (e.g., Home, Restaurant, Industry)
    If industry, list applicable SIC code(s) 	
    Has waste been sampled?  Yes 	    No
    If yes, attach results.
    If no, list suspected waste constituents?
    Is the waste a RCRA hazardous waste according to the criteria listed in 40
    CFR 261?
    Have additives been mixed with waste (e.g., solvents, enzymes, etc.)? 	
    If yes, please list. _______________________________________________
    Total quantity hauled from source 	 gal.
    Time waste was pumped? 	 Date 	
                                     D-l

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2)  Name of Company/Residence
    Name of Owner/Contact 	
    Address
    Telephone Number 	
    Type of Establishment (e.g., Home, Restaurant,  Industry)
    If industry, list applicable SIC code(s) 	
    Has waste been sampled?  Yes 	    No
    If yes, attach results.  .
    If no, list suspected waste constituents?
    Is the waste a RCRA hazardous waste according to the criteria listed in 40
    CFR 261?  	
    Have additives been mixed with waste (e.g., solvents, enzymes, etc.)?	
    If yes, please list. 	
    Total quantity hauled from source 	 gal.
    Time waste was pumped? 	 Date 	

3)  Name of Company/Residence .	.	
    Name of Owner/Contact 	
    Address 	
    Telephone Number 	
    Type of Establishment (e.g., Home, Restaurant, Industry) 	
    If industry, list applicable SIC code(s) 	
    Has waste been sampled?  Yes 	    No 	
    If yes, attach results.
    If no, list suspected waste constituents?
    Is the waste a RCRA hazardous waste according to the criteria listed in 40
    CFR 261?	
    Have additives been mixed with waste (e.g., solvents, enzymes, etc.)?	
    If yes, please list. 	
                                      D-2

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    Total quantity hauled from source 	 gal.
    Time waste was pumped? 	 Date 	

I hereby certify that the information listed above is true and accurate.
	 (Waste Hauler)
Verified by: 	 (POTW Operator)
                                     D-3

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                  APPENDIX B

PERMIT BT RULE REQUIREMENTS EXPANDED TO INCLUDE
       SECTIONS  INCORPORATED BT REFERENCE

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9 270.60 Permit* bjr nil*.
  Notwithstanding any other provision
of this part or Part 124. the following
shall  be  deemed  to  have  a RCRA
permit if the conditions listed are met:

  (c) Publicly owned treatment works.
The owner or  operator  of a POTW
which accepts  for  treatment hazard-
ous waste, if the owner or operator
  (1) Has an NPDES permit:
  (2) Complies  with the conditions ui
that permit: and
  (3) Complies with the following reg-
ulations:
  (l>-<5> amended  by 45 FR
 86973. December 31.  1980)
   (I) Sign and date each copy of the
 manifest or shipping paper (if the
 manifest has not been received) to
 certify that the hazardous waste
 covered by the manifest or shipping
 paper was received:
   (2) Note  any significant discrepancies
 (as defined in } 264.72(a)) in the
 manifest or shipping paper (if the
 manifest has not been received) on each
 copy of the manifest or shipping
 paper.
 [Comment: The Agency does not intend
 that the owner or operator of a facility
 whose procedures under I 264.13(c)
 include waste analysis must perform
 that analysis before signing the shipping
 paper and giving it to the transporter.
 Section 2M.72(b). however, requires
 reporting an unreconciled discrepancy
 discovered during later analysis.)
   (3) Immediately give the rail or water
 (bulk shipment) transporter at least one
 copy of the manifest or shipping paper
 (if the manifest has not been received);
   (4) Within 30 days after the delivery.
 send a copy of the signed and dated
 manifest to the generator however, if  .
 the manifest has not been received
 within 30 days after delivery, the owner
 or operator, or his agent, must send a
 copy of the shipping paper signed and
 dated to the generator and
 [Comment: Section 262.23(c) of this
 chapter requires the generator to send
 three copies of the manifest to the
. facility when hazardous waste is sent by
 rail or water (bulk shipment).]
   (5) Retain at the facility a copy of the
 manifest and shipping paper (if signed in
 lieu of the  manifest at the time of
 delivery) for at least three years from
 the date of delivery.
   (c) Whenever a shipment of
 hazardous waste is initiated from a
 facility, the owner or operator of that
 facility must comply with the
 requirements of Part 262 of this chapter.
 [Comment: The provisions of J 262.34
 are applicable to the on-site
 accumulation of hazardous wastes by
 generators. Therefore, the provisions of
 J 262.34 only apply to owners or
 operators who are shipping hazardous
 waste which they generated at that
 facility.)
                                             E-l

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  (ill) 40 CFR 264.72. Manifest discrep-
ancies:
        IM4.72  Manifest discrepancies,
          (•) Manifest discrepancies art
        differences between the quantity or type
        of hazardous waste designated on the
        manifest or shipping paper, and the
        quantity or type of hazardous waste a
        facility actually receives. Significant
        discrepancies in quantity are: (1) For
        bulk waste, variations greater than 10
        percent in weight and (2) for batch
        waste, any variation in piece count such
        as a discrepancy of one drum in a
        truckload. Significant discrepancies in
        type are obvious differences which can
        be discovered by inspection or waste
        analysis, such as waste solvent
        substituted for waste  acid, or toxic
        constituents not reported on the
        manifest or shipping paper.
          (b) Upon discovering a significant
        discrepancy, the owner or operator must
        attempt to reconcile the discrepancy
        with the waste generator or transporter
        (e.g.. with  telephone conversations). If
        the discrepancy is not resolved within
        15 days after receiving the waste, the
        owner or operator must immediately
        submit to  the Regional Administrator •
        letter describing the discrepancy and
        attempt* to reconcile it and a copy of
        the manifest or shipping paper at issue.
  (iv) 40 CFR 284.T3U) and (bXI). Op.
erating record:
         12*4.73  Opera** record.
           (a) The owner or operator must keep a
         written operating record at his facility.
           (b) The following information must be
         recorded, as it becomes available, and
         maintained in the operating record until
         closure of the facility:
           (1) A description and the quantity of
         each hazardous waste received, and the
         method(s) and date(s) of its treatment
         storage, or disposal at the facility aa
         required by Appendix I:
Appendix I.— Recordkeeping Instructions
  The recordkceping provision* of I 204.73
specify that in owner or operstor must keep
• written operating record •( his facility. This
appendix provides additional instructions for
keeping portion* of the operating record. See
I 284.73(6) for additional recordkaeping
requirements.
  The following information must be
recorded, as it becomes available, and
maintained m the operating record until
closure of the facility in the following
manner
  Records of each hazardous waste received,  i
treated, stored, or disposed of at the facility
which include (he following:
  (1) A description by its common name and
the EPA Hazardous Waste Numberfs) from
Part 281 of this Chapter which apply to the
waste. The waste description also must
include the waste's physical form. i.e.. liquid.
sludge, solid, or contained gas. If the waste is
not listed in Part 281. Subpart 0. of this
Chapter, the description also must include the
process that produced it (for example, solid
filter cake from production of —. EPA
Hazardous Waste Number WOS1).
  Each hazardous waste Hated in Part 201.
Subpart 0. of this Chapter, and each
hazardous waste characteristic defined la
Part 281. Subpart C of this Chapter, has a
four-digit EPA Hazardous Waste Number
assigned to it This number must be used for
recordkeepinf and reporting purposes. Where
a hazardous waate contains more than one
listed hazardous waste, or where more than
one hazardous waste characteristic applies to
the waate. the waste description must include
all applicable EPA Hazardous Waste
 Numbers.
   (2) The estimated or manifest-reported
weight or volume and density, where-
 applicable, in one of the unite of measure
 specified in Table 1:
   (3) The method(s) (by handling code(s) as
 specified in Table 2) and date(e) of treatment
 storage, or disposal.
                                                E-2

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 Table 1—Handling Codas for Treatment.
 fttafMV. tfTli DtoOOMl M+ltttrff
   Enter the  handling coded) listed below
 that most closely represents the technique(s)
 used at the facility to treat, store, or dispose
 of each quantity of hazardous waste received.
 1. Storaie
   SOI  Container : barrel, drum. etc. >
   S02  Tank
   SOI  Waste pue
   S04  Surface impoundment
   SOS  Other (specify)
 2. Treatment
     lai Thermal Treatment
   T06  Liquid injection incinerator
   TOT  Rotary kiln incinerator
   TOS   Ruidized bed incinerator
   TM   Multiple hearth incinerator
   TIO   Infrared furnace incinerator
   TU   Molten salt destructor
   T12  Pyrolysis
   T13  Wet Air owdauon
   TU  Calcination
   TM  Microwave discharge
   Tie  Cement kiln
   T17  Limekiln
'   lift  Other(epeeily)
     (b| Chemical Treatment
   T19  Absorption mound
   T20  Abeorptioa Bald
   T21  Chemical fixation

   T23  Chemical precipitation
   •^24  Chemical reductton
   T2S  Chiorinatioa
   T2>  Chloriaolyaia
   TZ7  Cyanide destruction
   T2»  DagradatiM
   T29  Detoxification
   T30  Ion exchange
   T31  Neutralixauon
   T32  Osonatioa
   T3>  Photolysis
   T34  Oth^-(specify)
     (c) Physical Treatment
       (1) Separation of components
   T3S  Centrihutatioo
   TM  CUrificartoa
   TJ7  Coagulation
   T3a  Decanting
   T39  Encapsulation
   T40  Filtration
   T41  Flocculation
   T42  Flotation
   T43  Foaming
   T44  Sedimentation
   T45  Thickening
   T46  Ulfraflltration
   T47  Other (specify)
       (2J Removal of Specific Components
        AbaorDtion-molecalar sieve
T4t
TSO
TSI
TS2
T53
T54
T55
T5«
        Activated carbon
        Blending
        Catalysts
        Crystallization
        Dialysis
        Distillation
        Electrodialysis
        Electrolysis
                                                               T57 Evaporition
                                                               T58 High gradient magnetic separation
                                                               T59 Leeching
                                                               T60 Liquid ion exchinge
                                                               TBt Uqvnd-tiquid extraction
                                                               T62 Reverse osmont
                                                               T63 Solvent recovery
                                                               T64 Stripping
                                                               TU Sand filter
                                                               T66 Other (specify)
                                                                  (d) Biological Treatment
                                                               T87 Activated sludge
                                                               T88 Aerobic lagoon
                                                               T89 Aerobic tank
                                                               TTO Anaerobic lagoon
                                                               TU Composting
                                                               T72 Septic tank
                                                               T73 Spray irrigation
                                                               TU Thickening filter
                                                               TTS Tricking filter
                                                               T78 Waate stabilization pond
                                                               TTT Other (specify)
                                                               TT8-79 (Reserved 1
                                                              3. DUpoaal
                                                               DM Underground injection
                                                               D8t Landfill
                                                               O82 Land treatment
                                                               D83 Ocean disposal
                                                               D84 Surface impoundment (to  be closed
                                                                 aa a landfill)
                                                               OSS Other (specify)
                                                     (v) 40 CFR 264.75. Biennial report.


                                                              1 264.75  Biennial report.
                                                               The owner or operator must prepare
                                                              and submit a single copy of a biennial
                                                              report to the Regional. Administrator
                                                              by March.  1  of each  even  numbered
                                                              year. The biennial report must be sub-
                                                              mitted  on  EPA form  8700-13B. The
                                                              report  must  cover facility  activities
                                                              during the  previous calendar year and
                                                              must include:
                                                              (:<>4.75 amended by 48 FR 3981. January
  (a) The EPA identification number.
name, and address of the facility:
  (b) The calendar year covered by the
report;
  :c>  For off-site facilities  the  EPA
identification  number of each hazard-
ous waste  generator from which the
facility  received  a  hazardous waste
during the year, for  imported  ship-
ments, the report must give  the name
and address of the foreign generator.
  
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          (e) The method of treatment, stor-
        age,  or disposal for each hazardous
        waste:
          (f) [Reserved]
           The most recent closure cost esti-
        mate under i 204.142. and. for disposal
        facilities, the most recent post-closure
        cost estimate under i 264.144: and
          fh) The  certification signed by  the
        owner or operator of the facility or his
        authorized representative.
  (vi) 40 CFR 284.76.
waste report: and
UnmanifestrU
        1264.76  Unmanifeittrf *MM report.
          If a  facility  accepts  for  treatment.
        storage,  or  disposal  any  hazardous
        waste from an off-site source without
        an accompanying manifest, or without
        an accompanying shipping paper  as
        described  In  1263.20(e)(2)  of  this
        Chapter, and if the  waste is not ex-
        cluded from the manifest requirement
        by i 26.1.S  of this Chapter, then the
        owner or operator must prepare and
        submit a single copy of a report to the
        Regional Administrator within fifteen
        days after receiving the waste. The on-
        manifested waste report must be sub-
        mitted on  EPA form 8100- 13B. Such
        report must be designated 'Unmani-
        fested Waste Report' and include the
        following information:
        [264.76 amended by 48  FR 3981. January
        28. 1983)
          (a) The  EPA identification number.
        name, and address of the facility:
          (b) The date the facility received the
        waste;
          (c) The  EPA identification number.
        name, and  address  of the generator
        and the transporter, if available:
          (d) A description and the quantity of
        each unmanifested  hazardous  waste
        and facility received:
          (e) The  method of treatment, stor-
        age,  or  disposal  for each  hazardous
        waste:
          (f)  The  certification  signed by the
        owner or operator of the facility or his
        authorized representative: and
          (g) A brief explanation of why the
        waste was  unmanifested. if known.

        (Comment'  Small quantities of hazardous
        wute ire excluded from regulation  under
        this  Part and do  not  require a manifest.
        Where a facility receives unmanifested haz-
        ardous wastes, the Agency suggests that the
        owner or operator obtain from each genera-
        tor a certification that the waste qualifies
        for exclusion. Otherwise,  the Agency sug-
        gests that the owner or operator file an un-
        manifested  waste report for the hazardous
        waste movement.!
  (vii) for NPOES permits issued after
November 8.1984. 40 CFR 284.101.


        §264.101 Corrective action for solid waste
        management units.

        [264.101 added by 50 FR 28742. July 15.
        198S]

         (a) The owner or operator of a facility
       seeking a permit Tor the treatment, storage
       or disposal of hazardous waste must insti-
       tute corrective action as necessary to pro-
       tect human  health and the  environment
       for ail releases of hazardous waste or con-
       stituents  from  any solid waste  manage-
       ment unit at the facility, regardless of the
       time at which waste was placed in such
       unit.
         (b) Corrective action will be specified in
       the permit. The permit will contain sched-
       ules of compliance for such corrective ac-
       tion (where such corrective action cannot
       be  completed prior to issuance of the per-
       mit) and assurances of financial responsi-
       bility  for  completing   such  corrective
       action.
                                      <4> If the  waste meets all Federal.
                                     State, and local pretreatment require-
                                     ments  which would be  applicable to
                                     the waste  if it were being discharged
                                     into the POTW through a sewer, pipe.
                                     or similar conveyance.
                                              E-4

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APPENDIX F
  FORMS

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              APPENDIX F-l

NOTIFICATION OF HAZARDOUS WASTE ACTIVITY
           (EPA FORM 8700-12)
                 F-l

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                                    i«.,«. •.' fft.ir.icw, ,,„
                                                                                                             iCSO C-011
                                                                                                                          rt 9
                                                                     204>>0
                                  Notification of Hazardous Waste Activity
                                Only
                                                                                                    •"••»•>« '••-r 10 :-e ."ii'wvf j.-.\ »„/
                . Nam* cf Installation
                .  Installation Mailing Addrwa
               II Location of Inxtatla
                                                               SlrMt or flout* NumlMr
               v. Ownvnhte
                                                                                                      S TycM at Ownvrtnip /tnttr cod»t
                                           A Nam* at mutilation s Ltaii Owm*r
               VI. Tvo« of Regulated Wa«t« Activity IMark 'X' in tht appropriate boxes. Refer to instructions
                                A. Hitirtfous WMM Aetivitv                                   8. U**d Oil f u*l Actn»it«*«
                                           Q 10 LMStnan 1.000h«/m«
 O l«. G*n*r*tei
 O 2. Tran*port*r
 Q 3. Tr*M*r.'Slor*c/Oilpo**>
 D 4. Underground l«M«O>Ort
 D S.M«rk*tortumHuardeutWMMF«M<
      ItfHtr T in*T in*n> «fl*r*»or M*rt
       D b. OtMr MartMMr
       D e tum*r
                                                                                    'Jf '
                                                                                               «00ro«r<4M 6o«*s P*/OM^
                                                                                Q a G*n«f»to« Marketing to Bur n*r
                                                                                O b Otn*r Mark*t*r

                                                                                DcSurrw
                                                                              7. Specification UMd Oil M*l
                                                                                 (Or On-Sit* 8um«r) Who rtrmt
                                                                                 tt» Oil  ***ta tH» 9p*ctflcation
VII. Wast* Fuel Burning: Typvof Combustion O«vie«/*
-------
A. Hetardoue Weete* trom Hornpecitic Source* Enter »ne eet» i» necetMry
S. Maiarde>* Watte* from Si
   epecttic teurcM your MMaitMien h«ndM« UM •demonai MIMW rf n*ctuafy
              . Enter trw lowr-«<9ii number from 40 CfH P»n 261.32 to* Men '••'•o f"»i»'3oj« »«su irom
          11
                             14
                                               J7
                                                                  22
                                                                  21
                                                                                     17
                                                                                     23
                                                                                     29
                                                                                                        30
C. Ciiiiiiniilil OimlMl r>iogie»i end reMeren lebareienee your ineteiietien nendtee. UM edditnnel vnen it neeetMry
                             SO
                                                SI
                                                                                     S3
E. Cneibffertemie •< MenHeted Meterdoue Weewe. Mert TT m me ttOMt correepending te me ener»aeri«tie» at norut«ea fteurdeui we«e»
  your mnellMon nendM ,'See 40 CFM r*wu 7«/.7l - 2$t.3
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                     APPENDIX P-2

           UNIFORM HAZARDOUS VA6TE MANIFEST
                  (EPA FORM 8700-22)
                               F-4
.>£^i£*^>£^^^

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n jasa prim or typa    (form designed for use on elite (12-pitchl typewriter I
Form Approved. OMB No. 20OO-O404 Expires 7-31 •<
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V
UNIFORM HAZARDOUS 1 . Generator $ us EPA ID NO. DOI5IIl±*i
WASTE MANIFEST I I i I I I I I I i 1 f^TT
V Tienerator t Nam* and Mailing Aooress
•». Generator's Phone ( )
5. Transporter 1 Company Nam« 6.
1 !
/ transporter 2 Company Nama 8.
1 !
9. Designated facility Name and Site Address 10
1 |
US EPA 10 Number
1 1 1 1 1 1 ! 1 '
US EPA 10 Number
1 1 1 | 1 1 ! 1
US EPA 10 Number
1 1 I 1 1 1 II
11. US DOT Dentation /Including Proper Shipping Nerne. Hezerd Cltss. end ID Numoerl
No.
a.
b.
1 I
1 1
sC.
* v • . *' • • f r . ,
• 1 1
d.
1 I
"" " ' ' '-'-'.' ^b^-- TV ' - . :
15. Special Handling Instructions and Additional Information
2. Page 1 Information
is not re
of law
A. State Manifest Docwm
in the snaded areas
quired by Federal
in* Number
k
B. State Generator's ID
C. State Transporter's 10
0. Transporter's Phone
E. State Transporter's 10
F. Transporter's Phone •
G. State Facility'* 10
H. Facility's Phone
liners 1 3.
Total I
Type Quantity W
II II
1 1 1 1
II 1 1
1 1 1 1
",


X wJ.fte.



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*


16 GENERATOR'S CERTIFICATION: 1 hereby declare that the contents of this consignment are fully and accurately described above by
proper shipping name and are classified, peeked, marked, and labeled, and are in all respects in proper condition for transport by highway
according to applicable international and national government regulations.
Unless 1 am a small quantity generator who has been exempted by statute or regulation from the duty to make a waste minimization certification
under Section 3002(b) of RCRA. 1 also certify that 1 have a program in place to reduce the volume and toxicity of waste generated to the degree
have determined to be economically practicable and 1 have selected the method of treatment, storage, or disposal currently available to me whicr
minimizes the present and future threet to human health and the environment.
Printed/Typed Name


Printed/Typed Name
1 8. Transporter 2 Acknowledgement of Receipt of Materials
Printed/Typed Name
1 S.Oiscrepancy Indication Space
Signature
Month 0*y Yt
III!)

Signature
Month 0»y y,
III!!

Signature
Month Otf Y,
1 1 1 ! 1

20.Facilny Owner or Operator: Certification of receipt of hazardous materials covered by this manifest except as noted in Item 19.
Printed/Typed Name
Signature
Month. Dty Y
1 ! 1 i 1
 EPA Form 8700-22 (Rev. 4-86) Previous edition is obsolete.
                                                                P-5

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         APPENDIX P-3

BIENNIAL HAZARDOUS WASTE REPORT
      (EPA FORM 8700-13B)
               F-6

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                                                                                        OM8«: 2050-002* Exptaei 12-3MC
                                         ENVIRONMENTAL PROTECTION AGENCY
              FACILITY  BIENNIAL  HAZARDOUS  WASTE  REPORT  FOR   1983
                                  This report is for the calendar year ending December 31, 1983.
                                Read All  Instructions Carefully Before  Making Any Entries on Form
          I. NON-REGULATED STATUS
             See instructions before completing this section.
             This facility did not treat, store, or dispose of
             regulated quantities of hazardous waste at any
             time during 1983	D
                                                         Explain your non-regulated status in the space below.
              print/type with elite type (12 characters per inch)

         II. FACILITY EPA I.D. NUMBER
                                           T.AC

         I F|  !   I  I'  !  i   I   I  I   1  I   '  I   11 I
          I   2
         III. NAME OF FACILITY
                                         13 14 15
                                                           This Facility's Non-Reftilated Sutui is Expected to Apply:
                                                              D   For 1983 Only         Q   Permanently
                                                                       O   Other (explain
                                                                           in comment stctlon)

                                                                 003 ENTRY (OFFICIAL USE ONLY): Q
                                                                                                              69
'1
         IV. FACILITY MAILING ADDRESS

         131  •   i  i   :  .   •   •
IS 16
Street or P.O. Box.

141  i   '  •   i  '
          15  16
         City or Town
                                                                                       45
                                                                   State    Zip Code
          V. LOCATION OF FACILITY (if different than section IV above)

         1 51  i   •  '•   .  :   i   .  :   i  •   I  .   '  i   :   !  '   .  I
          15 16
         Street or Route number
                                                     i. i
          15 16
         City or Town
                                                                   41  4^|47
                                                                   State   Zip Code
         VI. FACILITY CONTACT
         121  i   i  i   i  i   i   i  i
          IS 16
          Name (last and first)
         46
         Phone No. (area code & no.)
                                             VII. COST ESTIMATES FOR FACILITIES

                                             $  I  I   I  I   I  I   I  I   !   I  1.  I     $
                                                 16         19        12
                                     A. Cost Estimate for Facility Closure
B. Cost Estimate for Post Closure Monitoring
  and Maintenance (disposal facilities only)
          VIII. CERTIFICATION
              I certify under penally ot law that I have personally examined and am familiar wii(i the miormalion submitted m this and all attached
              document*, and that based on my inquiry 01 those individuals immediately responsible tor obtaining the information. I believe that the
              submitted information it true, accurate, and complete. I Jm aware that 'here are ^unmeant penalties tor submitting false information.
              including the possibility ot fine and imprisonment
               Prinl/Tvpe Name           Title
        EPA Form S7«M3B(5-«0) (RtvtsaeJ 11-«3)
                                            Signature 01 Authorized Representative

                                              F-7
              Date Signed
                                                                                                       Page 1 of.

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          APPENDIX G



STATE HAZARDOUS WASTE CONTACTS

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                        Alphabetized State Listing Of Hazardous Waste Contacts
Alabama

Land Division
Alabama Department of Environmental Management
State Capitol
Montgomery. AU 36130
(2051271-7730

Alaska
EPA Region X
Waste Management Branch
MS-530
1200 Sixth Avenue
Seattle. WA 98101
(2061442-2777
To Obttin Information of forms Contact
American Samoa Government
Department of Public Works
Pago Page. American Samoa 96799

(Commercial Can 633-4119)
Moil Your Complotod forms To.
US EPA Region IX
Tones and Waste Management Division
21S Fremont Street
San Francisco. CA 94105

Arizona
To Ootoin Information or forms Co fine t

Arizona Department  o' Health Services
2005 N Central. Room 301
Phoenix. A2 85OO5

(602) 257-0022
MaW Your Compared forms To.
US EPA Region (X
Tones and Waste Management Division
215 Fremont Street
San Francisco. CA 941 OS

Arkansas
Arkansas Department of Pollution Control
Solid and Hazardous Materials
P 0 Box 9583
imieRoc*. AR72219

(501)562-7444

California
To Obttirt Information or forms Conttct

California Department of Health Services
TOXIC Substances Control Division
714 P Street
Sacramento. CA 95814
(916)324-1781
Mill Your Comotttod forms To.
US EPA Region IX
Toxics and Waste Management Division
215 Fremont Street
San Francisco. CA 94105

Colorado
Colorado Department of Health
Waste Management  Division
4210 E llthAve
Denver. CO 80220

(303) 320-8333
Commonwealth of North Mariana Islands
To Obtain Intormttion of forms Contact

Oeoartment of Public Heaitn and Environmental Services
Division o' Environmental Quality
Saioan Mariana islands 96950
Overseas Ooerator  6984
CaDie address  GOV NMl Saioan
M»il Your Comolfted forms To
U S EPA Region IX
Tones and Waste Management O'v.s.or
215 Fremont Street
San Francisco  CA 94105

Connecticut
Connecticut Department of Environmental Protection
Hazardous Materials Management Unit
State Office Building
165 Capitol A«e
Hartford. CT 06106
(203)566-5712

Delaware
Delaware Department of Natural Resources and Environment
Solid Waste Management Branch
PO Box 1401
Dover OE 19901

(302) 736-4781
District Of Columbia
Department of Environmental Services
Pesticides and Hazardous Materials Division
5000 Overlook Ave . S W
Washington. DC 20032
(202) 767-8422
Florida
Solid Waste Section
Florida Oeoartm-nt of Environmental Regulation
Twin Towers Of :e Bldg  Rm 421
2600 Blair Stone Road
Tallahassee PI 32301

(904) 488-0300

Georgia
Land Protection Branch
Environmental Protection Division
Georgia Department of Natural Resources
270 Washington St. S W
Room 824
Atlanta. QA 30334
I4O4) 656-2833
Guam
To OOttin Informttion or forms Conner
Jim Branch. Administrator
Guam EPA
PO Box 2999
Agana. GU 96910
(Overseas Operator) 646-8863
Moil Your Comp/ereo* forms To
U S EPA Region IX
Toxics and Waste Management Division
215 Fremont Street
San Francisco. CA 94105
                                                    G-l

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To Oots«i Inlormttion or form* Contact

Hawaii Department of Health
Environmental Protection and Health Serv
Noise-and Radiation Brancn
P 0. Bei 3378
Honolulu. HI 96601
(808)458-3079

Motl Your Comprftfa* form To.

U.S EPA Region IX
Tosics and Watt*  Management Division
21 5 Fremont Straw
San Francisco. CA 94105

Idaho
EPA Region X
Waata Management Branch

1200 Si«h Avenue
Seattle. WA 98101

(206)442-2777
                                    sea Division
To Obtom Intormotton or forms Contact
Illinoia Environmental I
                     lection Ager
Division of Land Pollution Control
2200 Chureh.il Road
Springfield. IL 62706

(217) 782-6761

Mat/ Your Completed fount To:

RCKA Activities
U.S.EPA Ra«ion V
Wane Management Onnaion
PO.Bo«A3S87
Chicago. IL 60690
RCRA Activities
U.S. EPA Raojon
P 0. Boa A3887
Chicago. IL 60690

(312)886-6148
U.S. EPA Region VII
RCRA Branch
726 Minneaota Avenue
Kanaaa City. KS 66101
(816)374-6534
Kansas Department o< Health and Environment
Bureau of Waste Management
Forbes Field. BMg. 321
Topoka. KS 66620

(913)862-9360

Kentucky
Division of Waste I
                lanagemem
Kentucky Department for Environmental Protection
Fort Boone Plan. Building No. 2
l8ReiiiyRoad
Frankfort KY 40601
(502) 564.6716
 Louisiana Department of Environmental Quality
 Solid Waste Management Division
 PO Boa 94307
 Baton Rouge. LA 70804

 (504)342-1227

 'N row dispose of KM Itttod or eftoroetorittie wotto in
 LOUIMHO you mutt /lave an CM ID Numoor
Maine

Maine Department of Environmental Protection
Bureau of OH and Hatardous Materials Control
Division of Licensing and Enforcement
State House—Station 17
Augusta. ME 04333

(207)289-2651

Maryland

Maryland Department of Health and Mental Hygiene
Waste Management Administration
201 West Preston St..
Baltimore. MO 21201

(301)383-5740

Massachusetts

Massachusetts Department of Environmental Quality
Division of Solid and Hazardous Waste
One Winter Street
Boston. MA 02108

(617)292-5861
RCKA Activities
U.S. EPA Region V
Waste Management Division
PO. BoiA3587
Chicago. IL 60690

(312)886-6148
                                                                To OttOMt Information or forms Comoet:
                                                                Minneaota Pollution Control Agency
                                                                Solid and Hatardous Waste Division
                                                                1935 West County Rd.. 8-2
                                                                Roaevilie. MNSB113
                                                                (612)297-1779
                                                                Mod Your ComtHotod form To:
                                                               ' RCRA Activities
                                                                U S. EPA Region V
                                                                Waste Management Division
                                                                P 0. Bo* A3587
                                                                Chicago. IL 60690
Division of Solid and Hazardous Waste Management
Mississippi Department of Natural Resources
PO BOB 10385
Jackson. MS 39209

(601)961-5078

Missouri

Missouri Department of Natural Resources
Waste Management Program
PO 8oi1368
Jefferson City. MO 65102
(314)751-3241

Montana)

Montana Department of Health and Environmental Science:
Solid and Hazardous Waste Bureau
Cogswell Building. Room 8201
Helena. MT 59620

(406)444-2821

Nebraska

Nebraska Department of Environmental Control         %,
Hazardous Waste Management Section                 ;
PO BOB 94877
Lincoln. NE 68509

(402)471-2186                                •   ,
 EPA Form 8700-12 (P.ev. 6-86)
                                                  G-2

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>   4
                  To Obtoin informttnn Or formt Contoct:

                  Nevada Department of Conservation and Natural Netourcet
                  Division of Environmental Protection
                  Capitol Complw
                  Carton City. NV 89701
                  (702) 888-4670
                  Moil Your Comoioio4 forms To:

                  U.S. EPA Region IX
                  ToKict and Watt* Mtnegement Oivition
                  21 5 Fremont Street
                  SenFraneitco.CA94lOS

                  Now Hampshire
                  Now Hampshire 0«o«nm*nt of Haaith and Waifar*
                  Offiea of Watt* Management
                  Hearth and Wetfero Building
                  HannOriv*
                  Concord. NH 03301

                  (803)271-4808
                  To Ootom Inrormot ion or formt Contoct:

                  New Jartav Department of Environmental Protection
                  Owtaion of Watta Management
                  Haiardout Watta Adviaory Program
                  32 E. Hanover Straat
                  P.O. Bo* CN028
                  Tramon. NJ OM2S
                  (609)292-8341

                  MoU Yotir Comptoioo' fount To.

                  U.S. EPA Magion II
                  Air and Wane Management Oivtaion
                  2$ Ndcral  Pieaa
                  NawYork.NY1027i
                  Haiardoua Waste faction
                  NawMa«ieo Environmamai Improvamant Oivition
                  •.0. In 9M
                  (SOS) 9144020 En. 340

                  nMW i Octl

                  To OoMMt Informotion or form* Contoct

                  Now Vork Oaoartmant of Environmamai Contarvation
                  Oiviawn of Solid and Hazardous Watta
                  Mamfam Section
                  80 Wort «d.. Boom 209
                  Albany. NY 12233-0001

                  (518)457-0630

                  Mori Your CwrWeMO* formt To:

                  U.S. E*A Region II
                  Air and Waata Management Oivition
                  26 Federal Pirn
                  New York. NV 1027*
Solid and Maaardoua Watte Management Branch
Environmental Health Section
Oepenment of Human Naeoureet
OiMawn of Heeitn Servwea
306 Nortn Wilmington Street
• 0. Bra 2091
«at«gn. NC 27602-2091
(919)733-2171

North Dakota

North Dakota Department of Health
Oivition of Haxardout Waate
Management and Special Studiat
1 200 Miaaouri Ave.. Noom 302
liamarck. NO 58601

(701)224.2366
                                                               Ohio

                                                               ACMA Activitiea
                                                               US E»A«agionV
                                                               Watte Management Divition
                                                               P 0. Boi A3687
                                                               Chicago. IL 60690
                                                               (31 2) 886-61 48

                                                               Oklahoma

                                                               U.S. EPA Region VI
                                                               Air and Haiardout Material! Oiviaion
                                                               1201 Elm Street
                                                               Inter-Firtt Two  Building
                                                               Oailat. TX 75270

                                                               (214)767-9886
                                                               Oregon
                                                               EPA. Region x
                                                               Watta Management Branch
                                                               MS 530
                                                               1 200 Siith Avenue
                                                               Seattle. WA 98 101

                                                               (206)442-2777
                                                               for Information On Stoto Mo^
                                                               Oregon Deoenmem of Erwironmemel Quality
                                                               Hanrdoua and Solid Waate Management Ohneton
                                                               P.O 8o»1760
                                                               Portland. OR 97207

                                                               (803)229-6913
                                                               Penntytvente
                                                               U.S. EPA Region III
                                                               Watte Management •ranch
                                                               MS3HW34
                                                               841 Cheetnut Street
                                                               Phiiadeiphio. PA 191 07
                                                               (215)697-7384

                                                               Puerto Htoe  '
                                                               To Obi fin infortnotion Or formt Contoet

                                                               Environmenul Quality Boerd
                                                               Land Pollution Control ATM
                                                               P.O. BOB 11488
                                                               Santurca. PR 0001 0-1 4M

                                                               (809) 722-0439

                                                               Mod Your Comftoioo" formt To;
                                                               U.S. EPA Region II
                                                               Air and Waate Management Ohnewn
                                                               26 Federal Piasa
                                                               New York. NY 10278

                                                               Nnodo latand

                                                               Rhode laiand Oepenment of Environmental Management
                                                               Oivition of Air- and Hatardowa Matariala
                                                               204 Cannon Bldg.
                                                               75 Oavit Street
                                                               Providence. Rl 02909
                                                               (400 277-2797
                                                                                          rot
Bureau of Solid and Haiardout Wane Management
South Carolina Department of Health and Environmental Control
2600 Bull Street
Columbia. SC 29201

(803) 758-6681
South Dakota
South Dakota Department of Water and Natural Reaoufoaa
Office of Air Quality and Solid Wane
Joe Feat Building
Pierre. SO 57601
(608)773-3329

Ta
                                                                                  Oivition of Solid Waate Management
                                                                                  Tennetaee Department of Health and Environment
                                                                                  Cuttoma HouM. 4th Floor
                                                                                  701 Broadway
                                                                                  Nathviiie. TN 37203
                                                                                  (618)741-3424.2177.3969
                  EPA Form 9700-12 (9-88)
                                                                      G-3

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Tamaa
Commore/a/. Mumc**. 'aovrM Situ. *«*«*• Carwacr

Ta»aa Daoartmom of Moaith
Buraau at Sol* Witt* Manaoamam
1100 Wttt 49t« Straot. T-902
Auatin. TX 79739

(512)489-7271
Intottntl Hinitort Comacr

Toiaa Oooortmom of Wotor ftoaourcao
Industrial Solid WMW Soction
Capital Station
Auatm. TX 79711
(812)478-2014

Utati
Utan Daoanmsnt of Moaith
8uroau of Solid and Haiardaua Wi
Stata Offwo 9uitdma. Room 4231
    fctt 41100
San uaM City. UTI414IOMO
vartnom Ajancv of li
Air and Solid Waato
Stat* Ott*a Iwidinf
79 draw Strtdt
Mom»*iior.VTOMOa

(•02IS2S-MM
                   ifo«Miamal Canaarvanon
fa Oa*a*
Division of Natural Moaw
                 i Or firm C9MKC
Hatsfdaua Waato f*ro«f«m
Oooanmom of Conaorvation and Cultural Affairs
f*0. 9o«4340
Cnariono Amaiio
Si Thomaa.V100901

(9091774.3320

M*t XOMT CamXHrao' forma' To;

U.S. l»* ftOfMfl II
Air and waato Manooomom Omoion
28 Fooarai *iaia
Now York. NY 10279
Viftinia OoMnmam of Moami
 lOtQovomorStroat
 fti«nmond.vA2321S

 It04)7t«.|271
                                                            WaoMnfton

                                                            U.S. (»A Moajon X
                                                            Waata Manoiomom traneri
                                                            MS 830
                                                            1200 Sum Avonuo
                                                            Soani*. WAM101
                                                            (206)442-2777

                                                            for torormanot on Sttt* ^aovirafftom*

                                                            Waanington Oooartmont of leotogv
                                                            Hourdoua waata Saetion
                                                            Olymoia. WA »«804

                                                            |206)48»-«300

                                                            WOO! VtffMNO

                                                            WOK Virginia Ooaartmont of Natural Naaourcoa
                                                            Otviaion of Wator Maoureaa
                                                            1201 Oroononor Stroot
                                                            laat Cnanotton. VW 21311
                                                            (304)3t4.M3t
                                                            Fa OavaMi M»of»t*artan or forma Camacr
                                                            WiaoanaM Oaoanmant of Natural Moaourcoa
                                                            turoau of toM Waato Manaoamam
• 0. to* 7921
Modwon. Wl S3707

(•Otl2tt-2111
Afarf Xawr CamoMwoo1 forma fa.

MCftA Actnrmoa
U.S. I*A Hogion V
Waato Monogamom Otmaion
•0. lMA3St7
CMeafO.tt.90CW
                                                            I»A Notion VIM
                                                            Waato Monoaomont Oiwaton (9HWM4N)
                                                            Ono Oan»ar *iaco
                                                            SIMM 1300
                                                            9991 Stlt Stroot
                                                            Oorwor. CO 90202-2413

                                                            (3031293.1902
 |f>A form 9700-12 (Mov. 9-99)
                                         *UAGOVERNMENTPHHTMQOFFICE: 1087-7 16-002/ 60701


                                      G-4

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