oEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9488.02(85)
TITLE: Summary of EPA's Regulations Concerning Disposal
of Dioxin - Contaminated Wastes by Incineration
or Landfillint?
APPROVAL DATE: '--14-85
EFFECTIVE DATE: l~^~^
ORIGINATING OFFICE: office of solid waste
m FINAL
D DRAFT
STATUS:
[ ] A- Pending OMB approval
B- Pending AA-OSWER approval
: C- For review &/or comment
[ ] D- In development or circulating
REFERENCE (other document*):
headquarters
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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PARTS 264-265 SUBPART 0 - INCINERATOR
DOC: 9488.02(85)
Key Words: Dioxin, Landfills, Incineration
Regulations: 40 CFR Toxic Substances Control Act (TSCA) Part 775,
40 CFR RCRA Part 264 or 265
Subject: Summary of EPA's Regulations Concerning Disposal of Dioxin-
Contarainated Wastes by Incineration or Landfilling
Addressee: Dioxin Generators
Originator: NS Howard M. Fribush, Dioxin Disposal Advisory Group
Source Doc: #9488.02(85)
Date: 1-14-85
Summary:
40 CFR Part 775 under the Toxic Substances Control Act (TSCA) requires
individuals who want to dispose of dioxin-contaminated wastes to submit a
disposal plan to EPA to review and approve. This regulation serves as an
interim rule until a formal regulation is promulgated.*
Generally, the Agency recommends that liquid wastes be disposed by incin-
eration. Solid wastes, such as clothing, laboratory equipment, building parts,
soils and' sludges may be disposed by incineration or landfilling.
Landfills accepting dioxin-contaminated wastes must comply with 40 CFR
Part 264 or 265 and be limited to solid materials. Incinerators that dispose
of dioxin-contaminated wastes must have a permit under TSCA to incinerate PCBs
and interim status under RCRA. Incinerators must be operated under conditions
that are known to destroy 99.9999 percent of the PCBs that are present in the
wastes.
* The January 14, 1985 dioxin ruling stated that as of July 15, 1986, all dioxin
contaminated waste must be sent to facilities certified to handle dioxin con-
taminated wastes.
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•4
9488.02 (85)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
Ms. Violet ladirco
2292 River Road
Niagara Falls, NY 14304
Dear Ms. ladirpo:
Your request for information concerning EPA's dioxin disposal
guidelines has been forwarded to my office. Although the Agency
has not assembled a set of guidelines or recommendations into a
single document, we have established certain policies as well as
a regulation designed to guide persons who wish to dispose of
dioxin-contaminated wastes.
\ The regulation, which I have enclosed, is contained in
40 CFR Part 775 under the Toxic Substances Control Act (TSCA).
->, It requires persons wishing to dispose of dioxin-contaminated
wastes to notify the Agency with a disposal plan. Disposal
is thus subject to our review to ensure that adequate safety
precautions are taken. I have also enclosed several of our
responses to notifications received under 40 CFR Part 7757"
The regulation, however, is only an interim rule until a
formal regulation is promulgated.* A proposal to list dioxin-
contaminated wastes as hazardous wastes will soon be published
in the Federal Register.
rJ- The Agency also has established several policies which
outline its recommendations for the disposal of dioxin-
contaminated wastes. We generally believe that liquid wastes
. can be most safely disposed by incineration. Solid wastes,
such as clothing, laboratory equipment, building parts, soils,
and sludges, may be disposed by incineration or landfilling.
Landfills accepting dioxin-contaminated wastes must comply
with EPA's hazardous waste regulations (40 CFR Part 264 or 265)
and be limited to solid materials. Incineration facilities that
dispose of dioxin-contaminated wastes must have a permit under
TSCA to incinerate PCBs and interim status under the Resource
Conservation and Recovery Act (RCRA). In addition, the incinerator
facilities are required to be operated under conditions that are
known to destroy 99.9999 percent of the PCBs that are present
in the wastes. The efficiency of incineration of dioxin is based
on a chemical (i.e. , PCBs) that is harder to burn than dioxin.
The January 14, 1985 dioxin ruling stated that as of July 15, 1905, all dioxin
contaminated waste must be sent to facilities certified to handle dioxin con-
taminated wastes.
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V I hope this information has been helpful to you. If I may
be .,1: any further assistance, please feel free to contact me at
(202) 475-6678.
Sincerely yours,
//
-' "V^
/' /// 7 :
Howard M. Fribush, Ph.D.
Dioxin Disposal Advisory Group
Enclosures
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Name & Address
Date
Waste Description
Disposal
Site & Method
Action
1. Airwick Industries 1/14/84
Carlstadt, NJ
2. Amchem Products Inc. 10/7/81
Ambler, PA
3. Calgon Corp. 10/12/83
Hawthorne, NJ
4. Chemical Waste 10/9/84
Management, Inc.
Oak Brook, IL
5. Chevron Chemical Co. 8/25/83
San Francisco, CA
6. Dow Chemical 7/9/84
Midland, MI
7. Emerg. Environmental 3/12/84
Services, St. Louis,
MO
8. EPA Region II 9/4/83
Edison, NJ
40 Ibs hexachlorophene
No reported TCDD con-
centration
2,4,-D & 2,4,5-T
TCDD concentration
not reported
700 Ibs, 2,4,5-T
(14 ppb)
7500 Ibs TCP
«10ppb)
2,060 gal bulk
liquids. (10.4 ppb)
230 Ibs Silvex
registered pesticides
(0.1 ppm)
687,000 Ibs 2,4,5-T
manufacturing and
processing wastes
(0.28 - 230 ppb)
clean-up debris from
Minker site (< 2.5 ppb)
debris from clean-up
at Newark, NJ site
Incineration at any
facility
Chem Waste Mgmt.
Emelle, AL
Landfill
Rollins, Enyir.
Services
Bridgeport, NJ
Incinerator
Rollins, Deer Park
TX Incinerator
Chem Waste Mgmt.
Emelle, AL
Landfill
Rollins, Deer
Park, TX
Incinerator
Rollins Envr.
Services
Baton Rouge, LA
Incinerator
CECOS International
Niagara Falls, NY
Agency recommended
continued storage
until a disposal
facility becomes
permitted.
Notification submitted
to OPP. Not con-
sidered an adequate
notice.
Recommended continued
storage since Rollins,
Bridgeport not
permitted.
Agency had no objec-
tions.
Agency had no objec-
tion - materials are
solid; thus, no
leaching would occur.
Agency had no objec-
tions.
Agency recommended
disposing at Rollins,
Deer Park, TX
Agency recommended
plan be carried out.
Region unable to
dispose of materials.
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SUMMARY OF NOTIFICATIONS RECEIVED PURSUANT TO
40 CFR 775 ("VERTAC RULE") AND AGENCY ACTIONS
January 14, 1985
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Name & Address
Date
Waste Description
Disposal
Site & Method
Act ion
9. EPA/CRD
10. EPA Region VII
Kansas City, MO
11. EPA Region VII
Kansas City, MO
12. EPA Region VII
Kansas City, MO
6/13/84
3/21/84
7/27/84
4/27/84
13. EPA Region VII
Agency had no objec-
Kansas City, MO
14. Ethyl Corp.
Baton Rouge, LA
10/25/84
6/6/84
15. Hydroscience Inc.
Midland, MI
8/4/80
lab wastes from
analyses in the
TROIKA (l-10ppb)
contaminated clothing,
soils, & debris from
Minker site
72 drums clothing
(0.1 mg)
wastes at two sites
at Neosho, MO
wastes at various
sites in Missouri
water from decon-
tamination of
equipment
laboratory waste
materials
wanted advice
on disposal
Rollins, Baton
Rouge, LA
Rollins, Deer
Park, TX
Incinerator «•
Digester Site -
cap wastes; provide
for long-term ground-
water monitoring
Tank Spill Site-
excarate soil;
incinerate at
Rollins, Deer Park, TX
incineration in
U.S. EPA Mobile
Incinerator
the
filter water; send
to Sauget, IL POTW
Nuclear Engineering
Corp, Sheffield, IL
Landfill
Advised them to follow
the Vertac notifica-
tion regulation.
Ayency recommended
only clothing be
disposed at Rollins,
Deer Parjk facility..
Soils should be
stored.
Agency had no objec-
tions.
Digester Site - Agency
had no objections.
Tank Spill Site - out-
lined its policy for
incinerating soils.
Agency had no object-
ions.
Agency recommended
that filtered water
be analyzed for
dioxin. If dioxin
is found, discharging
not allowed.
Agency had no problems
with disposal plan
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Name & Address
Date
Waste Description
Pi sposal
Site & Method
Action
16. J.M. Huber Corp. 9/17/84
Borger, TX
17. IT Corp. 4/10/84
Knoxville, TN
18. Mclaughlin, Gormley, 11/4/83
King Co.
Minneapolis, MN
19. Mead Compo Chemical 9/24/83
RTF, NC
20. Midwest Research 11/9/84
Institute
Kansas City, MO
21. Monsanto Industrial 4/10/82
Chemicals
Camden, NJ
22. Monsanto Agriculture 9/8/83
products
EL Dorado, AR
23. Monsanto Polymer 8/28/84
Products Co.
Nitro, WV
24. Nalco Chemical Co. 9/3/81
Chicago, IL
25. Nalco Chemical Co. 9/11/84
Chicago, IL
200 Ibs. soils
from T.imes Beach, MO
(100 ppb)
laboratory waste
materials
30 gal. Korlan 8
(a derivative of
2,4,5-TCP)
laboratory wastes
«2 ppb)
lab wastes
contaminated pesticides
(32 containers)
«2.5 ppb)
(2) 55-gallon drums
2,4,5-TCP
«10 ppb)
24 drums of soil,
water, clothing
from drilling
and purging wells.
(375 ppb)
(17) 55-gallon drums
2,4,5-TCP - .099 ppm
17 drums of old
2,4,5-T
(100 ppb)
research tests using
Huber1s AER (pyrolysis
device
Rollins, Deer Park, TX
Incinerator
Ross Incineration,
Grafton, OH
Rollins, Deer Park, TX
Incinerator '
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Name & Address
Date
Waste Description
Pi sposal
Site & Method
Action
26. Neosho Wastewater
Tmt. School
Neosho. MO
10/25/84 wastes at various
sites in Missouri
incineration in the
U.S. EPA Mobile
Incinerator
Agency had no object-
tions.
27. N.Y. Dept. of Envir. 1/25/82
Conservation
28. N.Y. Dept. of Envir. 3/17/83
Conservation 5/23/83
29. N.Y. Dept. of Envir. • 6/24/83
Conservation • 9/27/83
10/6/83
30. Northwestern Univ. 3/18/83
Chicago, IL
31. Occidental Chemical 11/11/82
Corp.
Houston, TX
32. Overnight Trucking 9/9/83
Co., St. Louis, MO
33. Pueblo Chemical 10/22/84
Supply Co.
Garden City, Kansas
150 drums of soil
borings, clothing,
trash
(400) 55-gallon drums
waste materials from
Love Canal
same wastes as above
TCDD range
<1-50 ppb
laboratory standards
and wastes
80,000 gal. Hyde Park
leachate up to 20.2 ppb
TCDD
soils
14,000 gal. washings
of empty pesticide
containers (0.7-7.5 ppt)
CECOS International
Niagara Falls, NY
CECOS International
Niagara Falls, NY
CECOS International
Niagara Falls, NY
Kettleman Hills
Landfills, Kettleman
City, CA
Chem Waste's Vulcanus
Mobil, AL
paving
deep-well
injections at
Chemical Resources,
Inc. Tulsa, OK
Agency had no objec-
tions to planned
disposal.
Agency recommended
against disposal
plan until analysis
performed.
Agency had no objec-
tions to final dispo-
sal plan.
Not covered by TSCA
rule because standards
generated interrnally.
Agency rejected the
proposal under consent
decree.
Agency had no objec-
tions once approval
from EPA Region VII
was obtained.
Agency rejected
disposal plan.
Asked for a more
acceptable plan.
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Name & Address
Date
Waste Description
Disposal
Site & Method
Action
34. Rohm &, Haas 7/25/83
Delaware Valley
Bristol, PA
35. SCA Chemical 9/7/82
Services
Chicago, IL
36. SCA Chemical 4/26/83
Services
Sommerville, MA
37. SCA Chemical 4/9/84
Services
Sommerville, MA
38. Syntex Agribusiness 3/81
Palo Alto, CA
39. Syntex Agribusiness 10/26/84
Springfield, MO
(100) 55 gal. drums—'
soil & decontamination
material (24 ppb)
Silvex (13.6 ppm TCDD)
(— 500 gallons)
40,000 gal. Hyde Park
leachate up to 20.2 ppm
250 Ibs. laboratory
waste materials
still bottoms & cleanup
Denny Farm Site
wastes at various
sites in Missouri
CECOS International
Niagara Falls, NY
or Williamsbury, OH
SCA's, Chicago, IL
Incinerator
SCA's, Chicago, IL
Incinerator
SCA's, Chicago, IL
Incinerator
on-site destruction
of still bottoms
incineration in the
U.S. EPA Mobile
incinerator
Agency had on objec-
tions to disposal
plan. Rohm & Haas
of material.
Not covered by rule.
SCA incinerated - 200
gallons.
i
SCA withdrew proposal
following discussion
with Region V.
Agency did not object
to proposed plan.
Agency had no object-
ions.
Agency had no object-
ions.
40. Tenn Valley Auth. 7/18/83
Knoxville, TN
41. Thompson-Hayward 4/18/84
Chemical Co.
Kansas City, Kansas
1 drum 2,4,-D/2,4-5T
(5700 ppb)
31 drums 2,4,5-T
(1.26 ppb)
soils
Rollins
Deer Park, TX
paving
Agency recomtiended
continued storage.
Part of ORD's FY 84
plan.
Agency had no objec-
tions once it reviewed
the remedial plan.
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Name & Address
Date
Waste Description
Disposal
Site & Method
Action
42. TH Agriculture &
Nutrition Co.
Kansas City, Kansas
43. Union Carbide Co.
RTF, NC
44. Union Carbide
Agricultural
Products Co.
St. Joseph, MO
45. Union Carbide Acjr.
products Co.
St. Joseph, MO
46. Union Carbide Agr.
Products Co., Inc.
Research Triangle
Park, NC
47. veterans Administra-
tion Albuquerque, NM
48. Vetac Chemical Co.
Jacksonville, AR
49. GAP Corp.
Linden, NJ
11/16/84 10,000 cu yds.
sludge sediment,
soil, liner wastes
from closure of
their surface
impoundments
«0.8 ppb)
6/1/82 16 drums 2,4,5-T
(0.1 ppm )
11/23/82 8,200 gal. water
from triple rinsing
containers with
2,4,5-T NOT DETECTED
7/23/83 wastes from rinsing
equip, used to package
2,4,5-T
7/27/84 insides of buildings
(up to 700 ppb) upon
shipment, cone.
expected to be 3 ppb.
2/14/84 lab wastes
6/23/82 trash from cleanup
— 1 ppb
9/83 2 drums 2,4,5-T
— 5 ppb TCDD
SCA Chemical
Services Landfill,
Ft. Wayne, IN
Agency had no objec-
tions since dioxin
concentration was so
low.
Chem Waste Mt)mt.
Emelle, AL
Landfill
St. Joseph, ,:o
POTW
St. Joseph, MO
POTW
Rollins, Deer Park, TX
Incinerator
Rollins, Deer Park, TX
Incinerator
CECOS International
Williamsburg, OH
No specified method
Agency had no objec-
tions to disposal
plan.
Agency granted waiver
and indicated other
regs may apply.
Agency granted waiver
and indicated other
regs may apply.
Agency had no objec-
tions, but made
several recommenda-
tions on the disposal
plan.
Agency had no objec-
tions.
Agency had no objec-
tion. Vertac unable
to dispose of wastes.
EPA - ORD Cincinnati
accepted the mate-
rials.
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