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II8IEP 4 AL DIRECTIVE NUMBER: 9487.001A
TITLE: Use of Liquids’ for Wind Dispersal Control
at Hazardous W ste Landfills
APPROVAL DATE:
t PR 2 1986
EFFECTIVE DATE:
ORIGINATING OFFICE:
E FINAL
0 DRAFT
STATUS:
REFERENCE (other documents):
fl AIPP
DIRECTIVE DIRECTIVE £

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&EPA
           United $(•(••
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              Sohd W»ite tnd
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DIRECTIVE NUMBER:
9487.00-1A
            TITLE:  Use of Liquids' tor Wind Dispersal Control
                  at Hazardous Wfcste Landfills

            APPROVAL DATE:

            EFFECTIVE DATE:

            ORIGINATING OFFICE:

            G3 FINAL

            D DRAFT

             STATUS:


            REFERENCE (other documents):
  DIRECTIVE    DIRECTIVE    L

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Tue Use of Liquids for Wind Dispersal Control at Hazardous Waste Landfills
Sjrnrrar of Direcui.e
Directive to Region VIII on control of wind dispersal at landfills.
Requirements of Sections 264.301(f) and 265.302(d) for owners/operators
of a landfill to control wind dispersal
Type or Drec ye (Manual Policy Directive Announcement etc Status
Memorandum to Region VIII
Draft ew
LJC Final e so n
Does tris Directive Supersede Previous Directive Yes No Does It Suppiemenu Previous Directivesi) L ics
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Sg—ature of OSWER Direc•ives Officer
Date

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C 20460
:APR2i 1986
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
OSWER POLICY DIRECTIVE 9487.0O—lA
MEMORANDUM
SUBJECT: Use of Liquids for Wind Dispersal Control at
Hazardous Waste Landfills
A 1 CA”-
FROM: Marcia Williams, Director I
Office of Solid Waste (WH—562)
TO: Robert L. Duprey, Director
EPA Region VIII
Waste Management Division (8—HWM)
This is in response to your request received in November
1985 for guidance concerning the question of under what
conditions, if any, it is acceptable to use water or other
liquid chemical stabilizers to control wind dispersal of waste
in a landfill cell. We believe that the use of nonhazardous
liquids for wind dispersal control at hazardous waste landfills
should not be subject to the restrictions under Section 3004(c)(3)
of HSWA. This use must, of course, be limited to amounts necessary
to comply with wind dispersal control requirements. Such amounts
should be determined by regulatory authorities on a case—by—case
basis.
As stated in your memorandum, Sections 264.301(f) and
265.302(d) require the owner or operator of a landfill
containing hazardous waste that is subject to wind dispersal
to cover or otherwise manage the landfill to control such
dispersal. Since the liquids that are used to control wind
dispersal are usually nonhazardous (e.g., water), a response,
to your question is contained in a guidance we have drafted
concerning Section 3004(c)(3) (which addresses the placement
of nonhazardous liquids in hazardous waste landfills) of the
1984 Hazardous and Solid Waste Amendments (HSWA) to RCRA.
This draft guidance will be sent to the regional offices in
the near future.

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2
OSWER POLICY DIRECTIVE ‘9487.O0—lA
We believe that the language and legislative history of
Section 3004(c)(3) specifically, and of Section 3004(c) generally,
indicate that Congress’ primary concern in banning liquids was to
control the placement of liquids in landfills for treatment,
storage, and disposal. We believe, further, that Congress
did not intend to require owners and operators to apply for
an exemption for uses of nonhazardous liquids in or near a
landfill that are necessary in order to comply with the
technical requirements of the RCRA regulations.
You also inquired in your memorandum how wind dispersal
control, including the use of liquid agents, was being managed
at other sites nationally, and under what conditions. It is
unfortunate that we have littl.e information concerning the
national management of wind dispersal. We do know, however,
that the use of water appears to be a common management practice
for control of wind dispersal for dust and particulate matter.
Other methods include waste containerization, use of cover
material (soil and other waste), and waste treatment before
disposal (e.g., chemical fixation, carbon adsorption).
We hope this response clarifies the issue. If you should
have any additional comments or concerns, please contact
Paul Cassidy, of my staff, at FTS—382—4682.
Let me say finally that we were very impressed with your
full and perceptive analysis of the issue of the limited use of
liquids for controlling wind dispersal.
cc: EPA Regions I — VII and IX — X

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