VEB-18-1992 15=10 FROM BOOZ.flLLEN & HfiMILTON TO 912065530124 P.02
9487,1986(14)
RCRA/StJPERFUND HOTLINE MOKTHLY SUMMARY
DECEMBER 86
-T rrue • 3" sadgting Units and Miairmm Technology standards
the owner/operator of an existing landfill unit which is
holding P006 waste, wants to remove all the waste frcrc the
landfill in order to stabilise it. Once the waste is stabilized,
it will be put back in the same landfill and the landfill will
then be closed, will this action Grange the status of the
landfi II £rom an existing unit to a replacement unit? If she
landfill was then considered a replacement unit, would it
have to fleet cidnijium technology requirements under §3004(u)
of BCRA before the stabilized waste is replaced?
A uedt is considered a replacement if it is taken out
of service and all or substantially, all waste is removed
from it, and then reused. If the removal, stabilization,
and replacement of the waste is part of closure, and no new
waste is being added to the landfill/ then SPA does not consider
that the unit has been "reused". Therefor*, the landfill would
retain its status as an existing unit and would not haw to
meet minimum technology standards prior to replacing the waste.
Sourt«! fertaar* Pact (202) 382-7703
Susan Setaedes (202) 382-7706
Heaville
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