UnMdStatw
Environmental Protection
OffiC» 0«
Wbttr Enforcement and Ptrmits
Washington, DC 20460
Guidance Manual for the
Identification of Hazardous Wastes
Delivered to Publicly
Owned Treatment Works by
Truck, Rail, or Dedicated Pipe
-------
GUIDANCE MANUAL FOR THE IDENTIFICATION OF
HAZARDOUS VAST! 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 #Pl-23
SAIC Project No. 2-834-03-527-00
-------
ACKNOWLEDGEMENT
This document vas prepared under the direction of EPA Headquarters,
Office of Vater 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 Vaste, 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 Sveeney, and Eric Vashburn of SAIC.
-------
TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY i
INTRODUCTION 1-1
1.1 PURPOSE OP THIS MANUAL 1-1
1.2 LEGISLATIVE AND REGULATORY OVERVIEW 1-1
1.3 ORGANIZATION OF TIE MANUAL 1-2
DESCRIPTION OF RCRA REGULATED WASTES 2-1
2.1 DEFINITION OF SOLID WASTE 2-2
2.1.1 Definition of Solid Wast* 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
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
-------
TABLE OF CONTENTS (Continued)
Page
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
-------
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
-------
EXECUTIVE SUMMARY
Publicly Owned Treatment Works (POTVs) 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.
-------
1. INTRODUCTION
1.1 PURPOSE OF THIS MANUAL
The manual is directed toward two types of facilities. First, guidance
is offered to POTVs 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 (POTVs) 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 POTV 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 OVERVIEV
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 POTVs collection system prior to reaching the property boundary, includ-
ing those wastes that otherwise would be considered hazardous, are excluded
1-1
-------
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 POTVs 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 Vater 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 TSDFs. Under the permit by rule regulation at 40 CFR
270.60(c), a POTV must 1) have a NPDES permit, 2) comply witn 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
1-2
-------
development and implementation of a waste 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
-------
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 vaste 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 Vaste Manifest since, if it was, the waste was
certainly a hazardous waste. However, POTVs may want to ascertain whether
wastes not accompanied by a Manifest are also hazardous since POTVs 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 POTV operator to make a
positive determination. State and EPA Regional hazardous waste program
officials can help POTVs 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 VASTE
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 POTVs property boundary without prior mixing
with domestic sewage.
2-1
-------
subset of solid wastes. Therefore, a material must be considered a solid
waste to be defined as a hazardous vaste. 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 Vater Pollution Control Act, as amended (86 Stat.
880), or source, special nuclear, or byproduct material as
defined by the Atomic Energy Act of 19S4, 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 POTV. While this exclusion,
known as the domestic sewage exclusion, extends to most wastes that reach
POTVs, IT DOES NOT exempt wastes received within the POTV's property boundary
by truck, rail, or dedicated pipeline.
2-2
-------
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 CFR261 (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.
2-3
-------
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, hovever, that the definition of hazardous vaste provided here is the
Federal definition. States may have more stringent or different definitions
of hazardous vaste. See Section 2.3.1.11.
The generator is responsible for determining whether a solid vaste is
hazardous. A generator aust review EPA's hazardous vaste listings to deter-
mine if the solid vaste is a listed hazardous waste. If the vaste is not
listed, the generator either must test his solid vaste using standard methods
(specified in 40 CFR Part 261) or have sufficient knowledge about his waste to
assess vhether it exhibits any of the hazardous vaste characteristics. The
tests must be run on representative samples to obtain results that adequately
characterize the nature of the vaste. If the vaste exhibits a hazardous waste
characteristic, then it is hazardous and must be handled accordingly.
2.2.1 Characteristic Vastes
Any solid vaste that exhibits one or more of the hazardous vaste charac-
teristics is classified as a hazardous vaste under RCRA. For example, if a
sevage sludge exhibited any one of the four characteristics below it would be
considered a hazardous vaste:
• Ignitability
• Corrosivity
• Reactivity
• EP Toxicity.
EPA used tvo criteria in selecting these characteristics as indicators of
hazardous vaste. The first criterion vas that the characteristics be capable
of being defined in terms of physical, chemical, or other properties that
cause the vaste to meet the definition of hazardous vaste in the Act (see
pages 2-2 and 2-3). The second criterion vas that the properties defining the
characteristics be measurable by standardized, available testing protocols.
The second criterion was adopted because the primary responsibility for
2-4
-------
CIHILATM OF A tOt.lt WAIT!
IDCNTiriU IMSTI t D«l«r»l»« II
It eo«li VII •»
FIGURE 2-1. HAZARDOUS WASTE IDENTIFICATION PROCESS
2-5
-------
determining whether a solid waste exhibits any of the characteristics rests
with the generators. EFA was concerned that unless generators vere 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 (ESVA) of 1984 require that the Adminis-
trator promulgate regulations identifying additional characteristics. Section
2.2.1.4 of this guidance describes how EFA plans to expand the coverage of one
of the characteristic tests.
The properties of wastes exhibiting any or all of the existing character-
istics sn leftrred in 40 CFR Parts 261.20-261.24, and are described briefly
below.
2.2.1.1 Ignitability
A solid waste that exhibits any of 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
9 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
2-6
-------
wastes exhibiting the ignitability characteristic are assigned EPA Hazardous
Waste Number D001.
2.2.1.2 Corrosivity
A solid waste 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 0002.
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.
2-7
-------
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 vaste 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 avare 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.
2,2,1,4 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 vater 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 vhich
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.
2-8
-------
TABLE 2-1. CONSTITUENTS AND CONCENTRATIONS FOR EP TOnCTTT
Maximum
Concentration
EPA Hazardous (milligrams
Waste Number
D004
D005
D006
D007
D008
D009
D010
D011
0012
D013
D014
D015
D016
D017
Contaminant
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Endrin ( 1 , 2 , 3 , 4 , 10 , 10-hexachloro-l , 7-epoxy-
l,4,4a,5,6,7,8, 8a-oc tahydro-1 , 4-endo , endo-
5 , 8-dimethano-naphthalene)
Lindane (1,2,3,4,5, 6-hexa-chlorocyclohexane ,
gamma isomer)
Hethoxychlor (1,1, l-Trichloro-2, 2-bis
[ p-methoxyphenyl ] ethane )
Toxaphene (CiaHl9Clg, Technical chlorinated
camphene, 67-69 percent chlorine)
2,4-D, (2,4-Dichlorophenoxyacetic 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)
2-9
-------
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 vhen improperly managed. Consequently, in
devising the test, EPA necessarily had to make certain assumptions about
improper management processes to vhich 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 HSWA, 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 tfaste
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.
2-10
-------
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 ('9'), in contrast, are listed because they may
"cause or significantly contribute to an increase in serious, irreversible, or
incapacitating reversible, illness" even when 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 ('I'), corrosivity ('C') or reactivity ('R').
Constituent(s) which caused EPA to list a waste as EP toxic ('£') 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
-------
The listed vastes 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 vastes. Vastes listed in this manner appear on the "F" list
in Appendix A-l.
• Hazardous vastes from specific sources — These include vastes
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 vastes are
acutely hazardous and include discarded chemical products manufactured
or formulated for commercial or manufacturing use, and vhich consist
of the commercially pure grade of the chemical, any technical grades
of the chemical that are produced or marketed, and all formulations in
vhich the chemical is the sole active ingredient. These vastes vere
listed to account for all acutely toxic chemical products that are
sometimes throvn avay 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, off^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 vaste (ignitability, cor-
rosivity, reactivity, or EP toxicity). These vastes include chemical
products manufactured or formulated for commercial or manufacturing
use, and vhich consist of the commercially pure grade of the chemical,
any technical grades of the chemical that are produced or marketed,
and all formulations in vhich the chemical is the sole active ingred-
ient. Vastes listed in this manner appear on the "U" list in Appendix
A-l.
A generator vno handles listed vastes may petition the Administrator to
have his vaste "delisted." The petitioner must demonstrate to EPA that his
vaste is not hazardous. To demonstrate this, the generator must provide
sampling and analytical data and detailed information on his vaste 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
-------
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.
Without 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 CPU 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 ignitability
2-13
-------
characteristic (F003); and three separate wastestreams frnm the
explosives industry that exhibit reactivity (K044, K045, and K047).
Such exceptions may be subject to change.
2.3 RCRA REGULATORY STATUS OF SELECTED VASTES THAT MAY BE RECEIVED BY POTVS
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 ormay 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.
2-3.1 Selected Wastes
2.3.1.1 Septage Vastes
Septage wastes delivered to POTVs 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 POTV should identify the possible sources
of septage wastes (see discussion on legal and administrative procedures in
2-14
-------
TABLE 2-2. SUMMARY OP SELECTED WASTES
Vaste
Septage Vastes
Metal Finishing
Vastes
Spent Solvents
Pickle Liquor
Leachate,
Contaminated Ground
Vater, and
Impoundment Vastes
Superfund Vastes
Small Quantity
Generator Vastes
Is it RCRA Hazardous?
Potentially
Potentially
Potentially
Potentially
Potentially
Potentially
Potentially
Used Oil
Potentially
Spill Residues
(including
transportation
spills)
Potentially
PCS Vastes
State Hazardous
Vastes
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 with listed
or characteristic wastes?
• Is it a listed metal finishing waste-
stream? If not, does it exhibit a
hazardous vaste 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?
• Vas 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 listed hazardous
waste?
• 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
-------
Chapter 3). Septage vastes 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
vastes, and may be deemed hazardous if the septage has been contaminated with
listed or characteristic wastes. Accordingly, a POTV should exercise great
care in the management of septage wastes received by truck, rail, or dedicated
pipeline that it knows or suspects jnay 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 wastevater 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 vastestreams. (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
CFR Part 403), metal finishing wastes sent directly to a POTV 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 pretreatmeivt of the waste
prior to its delivery to the POTV. Where a metal finishing waste is diluted
or mixed with other wastes at the manufacturing facility, a POTV would apply
the combined wastestream formula (as described in 40 CFK 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
2-16
-------
TABLE 2-3. LISTED METAL FINISHING WASTES
Hazardous Vaste
Number
(Hazard Code)
F006
(T)
F019
(T)
F007
(R,T)
F008
(R,T)
F009
(R,T)
F010
(R,T)
F011
(R,T)
F012
(T)
Listed
Hazardous Vaste
Vastevater treatment sludges
from electroplating operations
except from the following
processes: (1) sulfuric acid
anodizing of aluminum; (2) tin
plating on carbon steel;
(3) zinc plating (segregated
basis) on carbon steel;
(A) aluminum or zinc-aluminum
plating on carbon steel;
(5) cleaning/stripping
associated vith tin, zinc, and
aluminum plating on carbon
steel; and (6) chemical
etching and milling of
aluminum.
Vastevater treatment sludges
from the chemical conversion
coating of aluminum.
Spent cyanide plating bath
solutions from electroplating
operations.
Plating bath residues from the
bottom of plating baths from
electroplating operations
where cyanides are used in the
process.
Spent stripping and cleaning
bath solutions from electro-
plating operations where
cyanides are used in the
process.
Quenching bath residues from
oil baths from metal heat
treating operations where
cyanides are used in the
process.
Spent cyanide solutions from
salt bath pot cleaning from
metal heat treating
operations.
Quenching wastewater treatment
sludges from metal heat
treating operations where
cyanides are used in the
process.
Appendix VII
Constituents
Cadmium, hexavalent chromium,
nickel, cyanide (complexed).
Hexavalent chromium, cyanide
(complexed).
Cyanide (salts)
Cyanide (salts).
Cyanide (salts).
Cyanide (salts).
Cyanide (salts).
Cyanide (complexed),
2-17
-------
affect their status as hazardous wastes. However, pretreating characteristic
vastes, such as highly concentrated metal laden rinse waters, nay vork 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
Host 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.
Vhere utilized as a wastewater conditioner (i.e., phosphorus removal,
sludge conditioner) in a POTV, spent pickle liquor can be considered a
recycled material exempt from RCRA regulation. Under RCRA provisions,
2-18
-------
TABLE 2-4. LISTED SOLVENTS
Hazardous Waste
Number
(HazardCode)
F001
(T)
Listed
Hazardous Vaste
The following spent halogenated solvents used in degreasing:
tetrachloroethylene, trichloroethylene, nethylene 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 bottoas from the recovery of these spent solvents
and spent solvent mixtures.
F002
(T)
The following spent halogenated solvents: tetrachloro-
ethylene, nethylene chloride, trichloroethylene, 1,1,1-
trichloroethane, 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
(I)
F004
(T)
The following spent non-halogenated solvents: xylene,
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.
The following spent non-halogenated solvents: cresols and
cresylic acid, and nitrobenzene; all spent solvent
•ixtures/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,
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.
2-19
-------
materials are not solid vastes vhen they can be shovn 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 vill not apply
to truck, rail, and dedicated pipeline discharges consisting solely of spent
pickle liquor from iron and steel facilities used for vastevater 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. Vhere the waste originates from the treatment, storage, or
disposal of a characteristic waste at a RCRA TSOF, the residual is hazardous
only if 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 POTV 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 POTV 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,
2-20
-------
household vastes and residuals resulting from the treatment, storage, and
disposal of household vaste are exempt from regulation as hazardous vaste.
Accordingly, vhere a leachate or other residual vastevater originates from a
solid vaste management facility managing only household wastes, the vastevater
is exempt from regulation as hazardous vaste. Where the facility also accepts
nonhousehold vastes such as industrial or commercial vastes, the residual
vastevater may be deemed hazardous if it exhibits any characteristic of a
hazardous vaste. Consequently, POTVs may vant to evaluate vhether leachate
and other vastevaters from solid vaste management facilities (knovn or
believed to be managing industrial or commercial vastes) 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 vastes such as leachate,
contaminated ground vater, impoundment vastes, and other vastevaters. Vhere
delivered to a POTV by truck, rail, or dedicated pipeline, some Superfund
vastes may be hazardous as defined by RCRA, and therefore may trigger permit
by rule requirements for the POTV managing the vaste. Substances found most
often at Superfund sites include: trichloroethylene, lead, toluene, benzene,
PCBs, and chloroform. Vastes from Superfund sites can contain many other
substances as veil, depending on site-specific characteristics. Before
accepting vastes from Superfund sites, POTV operators should ascertain from
the EPA/State vhether the vaste is hazardous and should ensure that any
necessary local pretreatment requirements are established and vill be met in
accordance vith 40 CFR Part 403.
2.3.1.7 Small Quantity Generator Vaste
It is estimated that 630,000 facilities in the Nation generate less than
1,000 kilograms of hazardous vaste per month. Historically, these small
quantity generators (SQGs) have been subject to less stringent RCPvA disposal
requirements than other generators. Hovever, regulations recently promulgated
by -EPA have significantly tightened these SQG requirements. Nevertheless,
2-21
-------
POTVs should be aware that receiving some wastes that might otherwise trigger
the RCRA permit by rule requirements for the POTV will not trigger those
requirements if the waste originated exclusively with certain SQGs.
When 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 POTV 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,
2-22
-------
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., between 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. POTVs 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 Vater 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
-------
TABLE 2-5. ESTIMATED NUMBER OF SMALL QUANTITY GENERATORS
(100 KG TO 1,000 KG/MONTH) BT INDUSTRY GROUP1:|
Number of
Industry Group Generators
Pesticide End Users 231
Pesticide-Application Services 1,660
Cheaical 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/Wood Manufacture and Refinishing 579
Printing/Ceraaics 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
11'Source: National Small Quantity Hazardous Waste Generator Survey,
AST Associates, Inc., February 1985.
2-24
-------
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 nay 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-
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 nay 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
-------
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 SO 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 Vastes
Some States regulate wastes as hazardous under State hazardous waste laws
that are not regarded as hazardous wastes under Federal RCRA regulations.
a, 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
-------
3. RESPONSIBILITIES OF POTVs 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 vastes.
The most direct method of precluding the receipt of hazardous vaste by
truck, rail, or dedicated pipeline is to prohibit the delivery of any vastes
via these methods and to enforce such a prohibition. This may not be a
desirable or feasible approach, hovever, especially if a POTV services a
community vhere septage vastes are generated.
A second vay POTVs may preclude the delivery of hazardous vastes is by
specifically prohibiting the discharge of hauled industrial vastes, thus
limiting the receipt of hauled vaste to only household vastes. As discussed
in Chapter 2, household vastes are specifically exempted from the definition
of hazardous vaste. Hovever, even under these circumstances, POTVs run the
risk of receiving hazardous vastes as unscrupulous septage haulers may mix
hazardous and household vastes.
POTVs that agree to accept hauled vastes from industrial users face
additional challenges in precluding the receipt of hazardous vastes, given
that some industrial vastes may be considered hazardous. Should POTVs accept
hauled industrial vastes, they must ensure that the vastes 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 vastes comply
vith pretreatment program requirements and standards.
This chapter discusses hov a POTV can develop and implement both regula-
tory and administrative mechanisms to preclude the discharge of hazardous
vastes to its treatment plant via truck, rail, or dedicated pipeline.
3-1
-------
Further, this chapter discusses hov to develop and implement a waste moni-
toring plan that a POTV can use to characterize wastes received by truck,
rail, or dedicated pipeline.
3.1 DESCRIPTION OF POTENTIAL LIABILITIES FOR POTVS ACCEPTING HAZARDOUS VASTE
The receipt of hazardous wastes imposes certain responsibilities on a
facility. Even if a POTV chooses not to accept hazardous wastes 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 known as "Superfund," liabilities.
POTVs may be subject to these liabilities whether or not they are aware of the
receipt of hazardous wastes. POTVs also may be liable under RCRA and CERCLA
for any past releases of hazardous wastes, 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 wastes by truck, rail, or dedicated pipeline without
a RCRA permit or, in a POTV's case, without regard to permit by rule condi-
tions, can lead to enforcement action under RCRA. If a POTV receives hazard-
ous waste without complying with 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 whether or not the POTV operator was aware that the waste received by
truck, rail, or dedicated pipeline was a hazardous waste. Consequently, to
minimize its liability, it is important that a POTV take steps to discover
whether it is receiving hazardous waste by these transport methods. In
addition, a POTV conducting a responsible, well designed program to preclude
the receipt of hazardous wastes by truck, rail, or dedicated pipeline,
although strictly liable under RCRA, would be demonstrating good faith. This
could shift the equities and help reduce POTV liabilities resulting from the
receipt of such wastes.
3-2
-------
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 unknoving
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
-------
provides examples of hov 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
-------
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.
Vhere 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 wastes would also apply to hauled wastes. This section
discusses many of tkes« components. Clf 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
-------
• 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 vaste 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 ami 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. Host 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
-------
To prevent truck, rail, or dedicated pipeline discharges of hazardous
waste to its facility, a POTV 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 POTV 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 POTV 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 Vastes Discharged to a POTV by Truck, Rail, or
Dedicated Pipeline
Sever use ordinances (or equivalent POTV use and treatment rules) for
POTVs 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 POTV through any means other than normal sewer
connections. This type of local ordinance prohibition would be the most
effective way for a POTV 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 POTV 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
-------
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 with nee<
to serve nonsevered
community
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 vith
domestic type sewage
Suggests need for
administrative and
waste monitoring
controls
3-8
-------
* 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 POTV's
service area may not be connected to the POTV 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
6 contains example language that a POTV may wish to include in its local sewer
3-9
-------
use ordinance to prohibit the discharge of hauled industrial waste. As
industrial hazardous vastes nay be mixed vith 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 si«4ge 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
-------
TABLE 3-2. BKOntMEMDED ADMMISTUTin MECHANISMS
rOt nifHrriMC DISCHAICBS OT lAZAlDOUS WASTI
•T TtUOC. IAIL. 01 DEDICATED
Administrative
Control M«chanl*m»
• Permit* (or waat«
generator and/or
hauler
Features
• Highly recommended:
- Eight of refuaal to
accept waetee
- Prohibited or restricted
aubatancea
- Designated dlapoaal altaa
- Monitoring and Campling
- Waata tracking
- Damage liability
- Notification of change of
waste jyps
- Panaltie* and othar
rsasdiss
- Permit revocation
- f»e mymttm
m Others:
- Spill prevention and
notification
- Equipment parforaiance
atandarda
- Liability insurance
Advantage*
Moat diract method of
restricting discharges
Limita and improve*
knowledge of user
unit*
• ?ro»idea (utdanca to
uaara
• Allowa regulatory
* A-si-ns
* Provtd,** rcm«4l«*/*ct*
aa enforcement
•echanlam
Dlaadvantagea
lequtrea resource* to
implement procedure*
to maximise usefulness
and to en*ute com-
pliance
Uaate Tracking
Syatam,
• Completed by Cenerator or
Haulers
- Name, addreaa, and phone
number of facility
- Waste type and volume
- SIC code
a Identifies waatc
* leguiste* discharges
• &><>• la jt*co«*ry of
Illegal hauling
lequires analysis to
ensure accuracy
Beatrlction of
dlcchcrg* points
• Dlacharge point at
treatment plant or in
collection system
• Reatrlct time and flow of
discharge
• SupervUe dtacharge
• Enhances inspection
capabilities
* Allowa Inspection and
aampling of wastes,
variflcation of wast*
tracking records,
supervision of
discharge, and
prevention of
incompatible waatea
from entering plant
If discharge point la
in the collection
ayatem, overalght may
be difficult.
Manifest violatlona
may occur.
3-11
-------
TABU 3-2.
Hiauiream
rot rutnruc DISOUBOU or IAZABDOOS HAITI
•T TUICK. BAIL. 01 MDICATO fltlLIlK (CoatI*
Adalnlatratlv*
Control Mech«nl»aa
• Inspection* and
aaapllnf/analyal*
Feature*
* Allow* lint-hand
Dl»ady*nt«ie*
Katourc* lnt*n*iv*i
P*r*oan*l, cqulpnant,
co*t of analyil*
Allow* Idtntlftcctloa
of other, noahacardou*
wait** *t facility
th*t «*y DO** • h*i*rd
to th* tjmttm
Baapllnf *ct* •• •
d«t«rr*Dt to
unp*r*iltttd
dlich«r|*«, provld**
Identification of
violator *ft*r tha
***nt
• Survelllanc* and
Inveetlfetlva
technique*
• Survelllanc* and atonltorlng
of poeelble dlacharge
point* for Illegal
discharge*
• Surveillance of eueplcloui
hauler practice*
• Coordination with ICIA
official* and State/locel
law aoforceaent official*
I**ult* In detection
of Illegal dlecKargee
• leeource Intenalve:
Pereoanel. equipment,
coat of analyal*
3-12
-------
trial users subject to a local pretreatment program. POTVs can issue permits
to either the vaste transporter and/or the waste source or generator.
Requiring permits is an effective means of limiting the community of users.
This method of control improves the POTV's knowledge of transporters/
generators and improves its overall ability to ensure that the receipt of
hazardous vaste is prohibited.
For a permit to be effective in controlling wastes discharged to POTVs,
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:
• Rign-t -of c^f-usal ta accept vaste — The POTV 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 vaste types. If the POTV 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 vastestrearns). 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 POTV may want to require
that any new industrial or commercial waste be approved by the POTV
prior to being hauled. The hauler and/or generator could be required
to notify the POTV of requests to haul new or significantly different
•waste from recognized, permitted sources or waste from previously
unrecognized sources. (To implement this requirement, the POTV would
have to clearly define what constitutes a "significantly different"
waste). This ensures that the POTV knows of its introduction into the
system land can adequately characterize this new waste. After this
characterization of wastes is performed, the POTV could accept the
wastes, or deny the discharge because the wastes are hazardous or
otherwise incompatible with the treatment works.
• Vaste tracking — Each permit could require the waste generator and/or
waste hauler to use a waste tracking system that enables the POTV to
track the sources, types, and quantities of wastes delivered to the
3-13
-------
POTV. (Section 4.4.2 provides a discussion of RCRA waste manifest
system.) The use of a vaste tracking system is useful in determining
if a vaste is a RCKA hazardous vaste, in recognizing possible illegal
hauling, or in identifying vastes that have a. potential to cause
upsets or other treatment plant problems. The FOTV could develop and
require the use of a form that provides relevant information on the
hauled vaste, including the source, address, telephone number, time
and date of pickup, vaste type, knovn or suspected pollutants, and
certification that the vaste is not hazardous. (Section 3.2.3.2
provides more information on the implementation of a vaste tracking
system.)
9 Monitoring and sampling — The permit could explicitly allov 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 vaste vhere 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 avare of its responsibilities to determine that its solid vaste
is a hazardous vaste. (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 vhere direct supervision by plant personnel is available
(e.g., at the headvorks or into a holding tank at the plant). This
allows plant personnel to inspect easily the vaste tracking manifest,
verify its information, sample the vaste, and ensure that incompatible
vastes are not dumped into the system. Receipt of hazardous vaste to
a point in the collection system constitutes a violation of RCRA
manifest requirements. Therefore, before receiving solid vastes into
the collection system, the POTV should ensure that such vastes are not
hazardous vastes.
« Pee system — A fee schedule for treatment of hauled vastes can be
described vithin the permit, setting forth baseline charges for a
specific volume of waste as veil 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 vaste 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 vaste hauler violate any conditions of discharge. For example,
hauling vaste in violation of Federal or local limits may carry a
different fine or legal action than violating vaste tracking pro-
cedures or discharging vaste that damages the treatment plant. In
addition, the permit could specify the legal procedures (e.g., shov
cause hearings or issuing injunctions) that vould be available under
3-14
-------
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
-------
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
POTV 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 POTV to develop an
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
-------
POTV to protect itself from receiving hazardous wastes, potentially hazardous
wastes, or dangerous, incompatible wastes.
3.2.2.2 Waste Tracking System
A waste tracking system is another mechanism a PQTW 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 develooinz 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
3-17
-------
the source listed on the waste tracking form. An example vaste 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
-------
In many cases, treatment plant access may result in discharges directly
to the headwords. This is normally allowed at larger POTVs, which can handle
the slug load from the hauler without any detrimental effects on the POTV
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
-------
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"). POTVs
may vant 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
wastesi the POTV may vant 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. Vhile 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 -entry
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
-------
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 POTV
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
-------
3.3.1.1 Identification of Hazardous Wastes from Unknown Generators
Designing a vaste monitoring plan to detect hazardous vastes from an
unknown hazardous vaste generator can be challenging. This will be the case
if the POTV is seeking to detect hazardous vastes mixed vith 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
vastes that may be commonly discharged to POTVs. These discussions should
provide the POTV vith an idea of some of the hazardous vastes and constituents
that may be generated in its service area. POTVs can refine this list by
focusing on industries located in its service area and researching their vaste
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 vaste (there are over 300 RCRA Appendix VIII
hazardous constituents and four hazardous vaste characteristics to consider)
it is recommended that the POTV consider evaluating vastes 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 vaste generators in its
service community including types and quantities of vaste, 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 vaste. This can be
accomplished by performing tests on indicator parameters. For example, if
industries in the community typically generate caustic or acidic vastes, a
simple pH test may be appropriate. Similarly, the presence of spent solvents
may be indicated using an OVA/HNU meter. The example vaste monitoring plans
in Section 3.3.3 of this document provide examples of simple screening tests
3-22
-------
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.
t Some wastes will be generated by industries that are particular to the
region in which a POTU 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 requirraents, the POTV can
use the following mechanisms:
3-23
-------
TAIL! 3-). WASTE (VALUATION PIOCUNIUSl APPLICABILITY AMD COHTEAINTS
Cott
Evaluation Para«ec«r(*)/
Analytical Protocol
ICRA Characteristic Analyses
IgnltebllltyflVlOIO/1020
Corroelvlt»|''/1110/9040
Beactlvlty '/90IO/9030
.and Stctlon 2.1.3
Bf To*lclty(l*/I3lO,
•«ltct) 13-
and/or NS-la*al chcalitl
and experienced
technician!
Under aupervtaon of a
Ph.O. or axperlanced (5*
yra) HS-level chealat.
with IS- and MS-level
•upport ataff (cheeHata
and technician*)
Experienced (2-) yra) IS-
aod/or MS-la*al chealata
and trained technician*
Tim Required,..,
Por Analyala * '
<2 hra
24 hra
ctn»
filtration cpparatua,
fliax/furoac* AAS or
ICAP, CC with electroo
capture detector
Agitation apparatu*, lero
headapace *itractioo
vaaael, ejH»rane
filtration apparatus,
•Mltlpla detector CC,
ICAP or flane/furnace
AAS, and potentially
CC/M8
fla*M/furnace
AAS or ICAP and general
labware
Capital
$800-1.500
$300-1.500
1)00
>$20.000
Unit
$25-70
$75-200
$50-200+
$250-650
(2)
>$30.000 w/o
CC/HS
>$ 100.000
w/CC/MS
$15-20.000* (AAS)
$75.000* (ICAP)
$100-1500+
(4)
$100-$!75
125-50
3-24
-------
TABLE 3-). HASTE EVALUATION PROCEDURES: APPLICABILITY AMD COMSTRAIIITS (Continued)
Evaluation Paraiteler(a)/
Analytical Protocol
CWA Priority Pollutant*/
VarlouaVJ/
Level of
Expertl*e Required
Time Requited
For Analvil*
(3)
Equipment Required
Capital
Cast
Unit
Entire 1.1st
Volatile*
B/N/A Extractable*
Pe*tlclde*/PCB*
Metal* (13 anaiytea)
Under aupervl.lon and
direction of a Ph.D. (2*
year* experience) or very
experienced (5* yean)
MS-levcl chealata with
experienced BS and MS
level support ataff
day*
2-4 hour*
8 hour*
8 hour*
•ee preceding
"Metal." entry
CC, CC/HS and AAS, or
1CAP
CC or CC/HS
CC/HS
CC
AAS or iCAF
$120.000+
$30.0004- (GC)
$80,000+ (CC/MS)
$80.000+
$25,000+
$i5.000-20.000+
for AAS
$75.000* ICAP
$600-1100 (water)
$700-1400 (.olid)
$125-175 (water)
$200-300 (.olid)
$200-300 (water)
$325-450 (.olid)
$150-175 (water)
$175-295 (*olld)
$175-250 (water)
$175-300 (.olid)
RCRA Appendix VIII Co*jpd*./
Varlou/0'
Entire List*6*
Subcategorlea
BlolualneaceDce Te.ta
Organic Vapor.
Chlorinated hydrocarbona,
heterocycllc* and aroaatica,
nitrogen compounds
Sane aa above entry
3+ day*
Experienced BS- or
HS-level chealat or
•Icroblologl.t
Experienced BS- or
HS-level chenlat
hr
hr
CC, CC/HS. and AAS or
ICAP
Photometer
OVA/HNU
$120.000+
$15.000
$64,500-10,000
(8)
$3,500-4.000
(water)
<$IOO
<$100
3-25
-------
TABLE 3-3. HASTE EVALUATION PKOCKDUUS: APPLICABILITY AMD OMSTKAIVTS (Continued)
Colt
Evaluation Parameters)/
Analytical Protocol
TOI
Organic chlorldei
Organic bromides
Organic Iodide*
Organic fluoride*
Level of
Expert lac Required
Experienced BS- or MS-
level chemlat*
(I)
(2)
(3)
(*)
O>
(6)
(7)
Tine Required,..
For Analyst*
-------
• As described above, a first step is to contact State and Federal
hazardous vaste program officials to determine vho the hazardous vaste
handlers (e.g. generators, transporters, and TSDF's) are in your
service area. Ascertain the hazardous vaste types and constituents
handled by these facilities from State/Federal officials.
• Onsite audits or inspections by the POTW of known or suspected
hazardous waste generators would assist in determining vhat 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 POTVs 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 was testreams 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 productio.-i 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
-------
• A review of the generator's records of hazardous waste 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
POTW 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
-------
The time, cost, and expertise constraints listed in Table 3-3 may limit
both the monitoring approach and monitoring frequency selected by a POTV. 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 POTV 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 POTV 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. Vhile the unit costs decline sharply when the POTV owns the equipment,
the capital cost of equipment (and the personnel needed to run that equipment)
may be cost-prohibitive to most POTVs. In light of these costs, the POTV may
limit the analytical frequency, even if the generator is expected to pick up
analytical costs.
3.3.2.2 Selection of Parameters for Vaste Analysis
Selection of sampling parameters should be based on the POTVs knowledge
of potential sources of hauled waste. To develop an efficient, cost-effective
3-29
-------
waste 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 POTV may use Table 3-3 to suggest alternative monitoring methods. For
example, the EP toxicity test may b« time (2 days or more) and cost (S20K
capital, $250-650 unit) prohibitive for a POTV to adopt as part of a regular
waste 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 concentration 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
-------
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 hov 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 Waste 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 Waste 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
-------
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
KOSO Hexavalent Chromium
K051 Hexavalent Chromium, Lead
K052 Lead
Methods Selection and Sampling Frequency
Based on the above list, the POTV 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 tvo 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
POTV 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
-------
The POTV decides to conduct an onsite audit of the metal finishing
facility's production and vaste 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 tvo 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 tvo 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
wastewater treatment system at the POTV, The metal finisher plans to contract
vith a hauler to deliver and dispose of the vaste 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 vastevater
treatment sludges are sent to a RCRA treatment, storage, or disposal facility.
The POTV verifies this by checking signed copies of hazardous vaste manifests
available at the metal finisher. The POTV also determines the approximate
volume of vaste generated by each process by revieving facility records.
Parameter Selection
Prior to requesting samples, the POTV revievs the results of the audit in
light of the hazardous vaste identification regulations. By revieving
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 vastes that the State identified, the POTV
finds that the metal finisher's disposal of trichloroethylene qualifies as a
listed vaste: F001, spent halogenated solvents used in degreasing.
On the basis of checking vith the State, the audit, and the in-house
reviev, the POTV could request that the metal finisher provide samples of the
folloving vastes to a laboratory preselected by the POTV (vhich may be the
POTVs ovn laboratory in the case of larger POTVs): the F006-F008 vastes, and
the treated vastevater. 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 folloving analyses by the laboratory: characteristic tests
of the treated vastevater; cyanide, zinc, chromium, and solvent concentrations
of the listed vastes and the treated vastevater; and specific gravity, and
solids content of all vastes.
The POTV selected these analyses to determine vhether the vastes to be
received from the metal finisher may be hazardous. The POTV recognizes that
accepting solid vastes from an industrial facility that is also a hazardous
vaste generator opens up opportunities for receiving hazardous vaste, and is
seeking parameters and/or concentrations of parameters that might vork to
identify whether the metal finisher has surreptitiously mixed hazardous and
nonhazardous vastes. The mixture concern is of particular interest vith
3-33
-------
regard to the listed vastes. However, the POTV is veil-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 POTV
does not receive hazardous wastes.
The POTV selected laboratory provides the following results to the POTV
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.
s 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 vastevater.
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 POTV 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 POTV 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 wastevater and
wastewater sludges.
3-34
-------
Knowing that the wastes handled at the metal finisher tend to he cor-
rosive, the FOTV 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 POTWs.
Larger PQTVs 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 vill cost approximately $100 if the POTV has the necessary
equipment and staff. In addition, larger POTVs may want to subject the octal
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 vi.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 PQTV 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.
3-35
-------
4. RESPONSIBILITIES OF POTVs CHOOSING TO ACCEPT HAZARDOUS WASTES
4.1 INTRODUCTION
POTVs 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)J:
* The POTV owner or operator oust have a NPDES permit, issued by EPA or
a NPDES delegated State
* The POTV must be in compliance with its NPDSS 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 vith permit by rule requirements constitutes a violation of the
4-1
-------
FOTW'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, POTVs 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 POTVs choosing to accept hazardous
wastes for treatment, storage, or disposal. If a POTV accepts a listed
hazardous waste by these transport methods, the POTVs treatment, storage, and
disposal of the resulting sludge will be governed by RCRA Subtitle C hazardous
waste, requirements. POTVs generating such sludges should contact hazardous
waste officials to assess their storage, treatment, and disposal options.
POTVs should be aware that the regulatory requirements described herein
are minimum requirements for POTVs 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 POTV receives hazardous
waste. Both Federal and State NPDES and RCRA permitting authorities nay
impose more stringent requirements on POTVs 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 VITH 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 POTV must be in compliance with its NPDES permit. Any violation of a
NPDES permit is sufficient reason for EPA to take joint CVA/RCRA enforcement
4-2
-------
actions. Thus the POTV should make every effort to ensure complete compliance
vith all terms and conditions of its NPDES permit. SPA vill 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 CWA 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 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 stream.
Pollutants that are incompatible, or otherwise unaffected by the
treatment processes, could have an adverse environmental impact on the
receiving stream.
9 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 POTVs 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 (POTVs) 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.
4-3
-------
As part of the 40 CFR Part 270.60(c) permit conditions of a permit by
rule, the hazardous vaste 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
vastes 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 vith applicable standards and
requirements prior to discharge, or acceptance of hazardous vastes that are
not in compliance vith applicable pretreatment standards, can result in
enforcement actions 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 vith 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 vastes received by a POTV by truck, rail or
dedicated pipeline must meet all of these standards before discharge into the
POTV can be alloved. Each of the applicable standards is dicussed further
belov.
• 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
vastes 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 flov in the POTV
- Have an excessive oxygen demand
- Could cause the temperature at the influent of the treatment plant
to exceed 104°F.
4-4
-------
Under these provisions, vastes 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) nay violate
these prohibitions, and as such should not be accepted by the Control
Authority.
Local limits — Local limits are developed by the POTV to protec't the
POTV treatment plant operations, sludge quality, and receiving stream.
Since local limits are enforceable as pretreatment standards, any
hazardous vastes 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, POTVs should consider the extreme loading variations that
could be expected to be received from waste haulers when allocating
allowable headworks loadings.
Many local sewer 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 wastestreaa
- Establish the industrial production rate associated with the
vastest ream (for production-based standards only)
- Establish the necessary sampling protocol to assess compliance with
the categorical standard
4-5
-------
- Sample and analyze the hazardous vaste, or require the industrial
user to perform sampling and analysis, consistent vith the estab-
lished protocol, to ensure compliance vith 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 vaste description. In
rare instances, this may provide sufficient information; hovever, POTVs
generally can expect problems in determining the applicability of categorical
standards based solely upon this information.
Some RCRA listed vastes provide a clear indication that the electroplating
or metal finishing regulations could be applicable, such as: vastevater
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. Hovever, 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 vastes. In the case of solvents, this determination is crucial,
as solvents are regulated as "total toxic organics" under several categorical
standards.
POTVs should be avare of the K-listed vastes, vhich 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 vastestream.
Having properly identified the categorical vaste, sampling protocols must
consider the possible combination of vastestreams, either at the industry, or
for conveyance to the treatment plant. If this is the case, the Combined
Vastestream Formula (CVF), as described in 40 CFR 403.6(e), mu-^t be applied to
account for possible dilution. Vhile dilution may be an acceptable method for
treating characteristic properties under RCRA, this cannot be used to achieve
compliance vith categorical standards. Vhile an industry can be required to
monitor its vastestreams and provide the necessary data for use in the CVF,
4-6
-------
problems can arise if the transporter combines loads from different indus-
tries. POTVs must establish regulations and procedures to ensure that any
such occurrence vould be predicated upon the sampling and analysis of each
contributing vastestream for all pollutants of concern. EPA's Guidance
Manual, Use of Production-Based Pretreatment Standards and the Combined
Vastestream Formula, (September 1985) provides additional guidance.
4.4 COMPLIANCE VITH 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.
4-7
-------
The Uniform Hazardous Vaste 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 TSOP)
• 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
4-8
-------
of the information required on the manifest except the EPA identification
number, the generator's certification, and the signatures of the intermediate
transporters. Vhen a shipping paper is used, the generator or initial rail
transporter is responsible for sending three copies of the manifest to the
POTV. 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 waste 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 vithin 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
4-9
-------
manifest requirement by the small quantity generator regulations (see Section
2.3.1. This requirement does not apply to hazardous waste arriving at the
POTV by dedicated pipeline). The report must be submitted to the EPA Regional
tfaste 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 Vaste 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 unmanitested hazardous waste
received
• The method of treatmeal storage, ind disposal for each waste
• The certification signed by the owner or operator of the POTV or his
authorized representative
• A brief explanation of why the waste was unmanifested, if known.
Vhen 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 POTV ceases to engage in the treatment, storage, or disposal
of hazardous waste:
• A description of the type and quantity of each hazardous waste
received
4-10
-------
• 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 vaste to be described in
the operating record by its common name and, if the vaste is listed, by its
EPA Hazardous Vaste Number(s) (from Part 261, Subpart D). If the vaste is not
listed, the description must include the production process. The record also
must describe the vaste's physical form (i.e., liquid, sludge, solid, or
contained gas); the estimated or manifest-reported veight, 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, ovners or operators of TSDFs, including POTVs
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:
4-11
-------
. . . 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
vas 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 FOTVs 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 POTV 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 CUA 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 POTVs, 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 POTV to pump
4-12
-------
and treat ground vater 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, POTVs 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 POTVs. The
first phase of corrective action, the RCRA Facility Assessments is more fully
described in the Guidance forConducting RCRA Facility Assessments at POTVs.
4-13
-------
APPENDIX A
RCRA LISTS
-------
APPENDIX A-l
RCRA LISTED HAZARDOUS WASTES
A-l
-------
HAZARDOUS HASTE F10M NONSPECIFIC SOURCES (P LIST)
40 CFI PART 261.31
UM IM * {Ml
UMdB
of trv or •nonraerww. or of
fmm Mwf OOM nat
or mmuxesmnq UM IM * (Hi
•M mm anon MM ny«aa*i m»iniii g««d emy tor g»« preoneain or u«« o»
ma levK areat (ram ryar 09111 cnonac 0un*Ba«ani tram wm onoucoon a*
urn»r»ia n- «r«- or tmiiimuugfumil or o«c«ra»d UHUMO u»o" eamaono ovnoouno* |M)
or mrm« ri»«n«rn ol
I*. 1 MO. r*n*M O» «« 7*«iO. NeMinev »t'«« 44 Wt Ml 7
tt
A-2
-------
HAZARDOUS WASTE FROM SPECIFIC SOURCES (K LIST)
40 CTt PART 261.32
*«***...».
in
n
Rents „...„. _ (T)
unem mage *ei" <** prooncnon a» tf< renew e»/»«m«.— (rj
i "om me preaucaen ot cf»o^« or>»i ayemi ,T)
naff
'61 J* amendrt b* 4? FR 4783J. July .16. I'M: 45 FR *:OJ9. October .'0. i-»«0: rev.ied b> 4J FR
U980. Novetnb«r II I9SO: 46 FR 4617. J»nu«r> 16. I9«l: 46 FR :'4:6. Mav :o. I^HI)
I
74980
A-3
-------
A-4
-------
A-5
-------
DISCARDED COMME1CIAL CHEMICAL PRODUCTS, OFF-SPECIFICATION SPECIES,
CONTAINER RESIDUES, AMD SPILL RESIDUES IDENTIFIED AS TOXIC HASTES (U LIST)
40 CTl PART 261.33U)
.OOJ
-••J
„" 44
-J'«
.002
0003
.004
JQOS
JOM
J007
L V*H-^0»W-J
u;nc «oa •*"» MMT in
4<
I -Ml I HUIIXIUIWll •»«
H«IW S-WTW iC " "I
.::*
.or
•jiff
.an
ui<«
.U5
.030
,-n
.'•j
,u31
3.UJ
amJ-cmormwroai.!
i«l-<
4ram«CMr«
' :*«»••<• : • Z.3,4 4J<««cnien>-
i-Ou-^«nj«o-
•CM
. *9f
»'»•
.etc
-0»i
3 3 ;>
•-(9*2<~wo«
in
i •uunom it tl
Mui«MMpmm*i*.n
an
• a-ccn
• j;
' 2 3 * C »CIM»OUMM II n
A-6
-------
U1« ...
U1«.,_
ut«a,._
UW
U1«*
'0-
uaif
u2ii .,
uisa I
uai» —j
U34* , TtaOM
UJJO i Ti
UJH , TI
ua2i J TI
IL999 O-T»M
U0t1 I IH.ll4.Tn
uaat,
U2Z7
uzzt i r«
U2» J Tn
Ul»1 ; Tn
sw'oa?
o. i j.4*rt«
0» , J.4.$.Ti«
U234
M«M .i I.J.S-TO
azu i<*aa«
im.n
n«.n
UZM- Ti
UZ37 unot 5(l»U
U23? : Una*
U043
U24C
U23*
UJOO
A-7
-------
APPENDIX A-2
40 CFR PART 261, APPENDIX VIII
LIST OF HAZARDOUS CONSTITUENTS
A-8
-------
Ammoc vm— HAZAXDOYJS
Contnrunm
AcctoniMl* (Etaancaltrlle)
Acetophenone (Etaanoae, l-phenyl)
3* alpha-Aeetanyibeiay I M-
hydroxycoumaria and aaitt (Warfarin)
3-Acetylamlnonuorene (Acetamide, N-OH-
nuoren-3-yIM
Acetyl eWorld* (Ethaaoyi chloride)
l-Acetyl-3-thlourea (Acetamide. N-- )
Acroleln (3-Propenal)
Aerylamide (2*Prapenamide)
AeryloaitrUe (2-PropenenltrUe>
Aldrin a.2J,4.lO,10-Hexachlorc~
l.4.4aJ.8.8a.8b-hexahydro-«ndo.exo-
Allyl alcohol (2-Propen-l-ol)
Aluminum phosphide
4-Amlnobiphenyl -4a-methoxy-i-methy I-
carbamatc azirinoC2'.3-:3,43pyrroloC1.2-
aHndole~4.7-dione. (ester) (Mltomycln C)
< AzlrtnoC J-3':3.4)pyTrolo( l.2-a)lndole-4.7-
dlone. S-*jruno-8-t((*mino-
cart>onylx>xy)metliyl]-l.li.2.8.8*.8b-
hex»hydro-«*methoxy -S-methy- >
S--3-tJoxazoloi (3(2H)-Uoxi-
xolone. 5-<»minomethyl)-) 4-Anunopyrt-
dine (4*Pyrldtnamine)
Amitrol*
BW2-cnloroeUiyn ether (Ethane, l.l'-
oxyWiH-chlitra-))
H Jf -Bl»< s^aloroetayD-a-napbthylamlae
(Calomaphactae)
Btt<3-ehloroUwpropyl) ether (Propane, 2.T-
oxybU(3-ttUorc- j)
BtMehloromethyl) ether (Methane,
oxybtitealero-])
Bi«(3-«thylhexyl) phthalate (1.2-Bem*nedl-
cmrboxyUc add. bu<3-«thylhexyl> eater)
"The abbrevnoon K.O.S. (not otherwue
specified) Hftiifiw tho»e members of the
»en«ral clau not speclficaUy luted by name
In ihu appendix.
Bromoacttone (2-Propanone. 1-broinc-)
Bromomethane (Methyl bromide)
4-Bromophenyl phenyl ether (Benzene, 1-
bromo-4-phenoxy-)
Brucine (Strychmdln-io-one. 2,3-dlmethoxy-
2-Butanone peroxide (Methyl ethyl ketone.
peroxide)
Butyl benzyl phthalate (l.2-Benzenedlcar-
boxy lie acid, butyl phenylmethyl ester)
2-w(e-Butyl-4.«.dlnitrophenol (DNBP)
(Phenol. 2,4-dlnltro-6-< 1 -methyl propy 1)-)
Cadmium and compounds. N.O.S.*
Calcium chromate (Chromic acid, calcium
salt)
Calcium cyanide
Carbon dituUlde (Carbon bliulllde)
Carbon oxyfluoride (Carbonyl Huortde)
Chloral (Acetaldehydt. trlchlorc-)
Chlorambucil (Butanolc add. 4-Cblj<2-
chloroethyDaminolbensene-)
Chlordane (alpha and gamma Lsomeni (4.7-
Methanolndaa. l.X4.S.8.7.8.8-octachlorc-
3,4.?,?a-tetrahydro-> (alpha and tamma
Isomen)
Chlorinated bens*nea, N.OA"
Chlorinated ethane. N.O A'
Chlorinated nuorocarbona, N.O-3.'
Chlorinated naphthalene. N.O-3.*
Chlorlaated phenoL N.O A*
Chloroacttaldeayd* (Acetaldehyde, chloro-)
Cnloroalltyl ethera, N.O.S.*
p-Chloroanllia« (Benamnamlne, 4-chJoro-)
Chlorobenaene (Benaene. chloro-)
Chlorobenxllau (B*nMneac«Uc add. 4-
chlorc-alpha-(4-chlorophenjl>-alpha-
hydroxy.. ethyl Mtcr)
2-Chloro-l. 3-butadlen* (chloroprene)
p-Caloro-m-cra«c4 (Phenol, 4-chloro-4-
methyl)
1-Chloro-JJ-epoxypropane (Oxlrane, 3.
(chloromethylV)
3-Chloro«thyl vtayl ether (Ethen*. (Kalor-
oethoxy)-)
Chloroform (Mathan*. tncfalorc-)
Chloromethane (Methyl chloride)
Chloromethyl methyl ether fM«o«nM.
chloromethoxy-)
3-Chloroaaahthalea* (Naphthalene, beta-
chloro-)
3-Chlorophenol (Phenol, o-chloro-)
Uo-ChlorophenyUthlourae. (Thioure*. (3-
caloropheaylK)
J-Caioropropene (aliyi chloride)
J-Caloroproplonltrtl* (Propaneajtrtta. s-
chloro-)
Chromium aod compound*. N.O A*
Chrytene (U-BenJBJhenanthr«ne)
CJtrm red No, 3 (3-Naahthoi l-t(3.5-
dtmethox7phenyl>aao]-)
Coal tan
Copper cyanide
Crweat* (Crtoaou, wood)
Creeoli (CreayUc add) (Phenol, methyl-)
Crotoaaldehyde (3-But«nal)
Cymaidea (*oluble talu and eoi&BUxea)
N.O.S.*
Cyano««n (Ithanedlnltrtle)
Cyaaofcn bromide (Bromine cyanide)
Cyanorm chloride (Chlorioe cyanide)
Cycaaln (beta-O-Olueopyraaoalde. (methyl-
ONN-*ioxy)methyl-)
2-CyelohexyM.«-dlBitrophtaoi (Phenol. 3.
cyclohexy 1-4.8-dlnllro- >
Cyclophoaphamlde (2H-1.3.2,-Oxatapho*-
phortac. CbW2
-------
ODD (Dlchlorodlphenyldlchloroethane)
(Ethane. i.l-dichloro-2.2-bt»(p-chloro-
phenylH
DOC (Ethylene. l.l-dtehloro-2.2-bis(4-<:hlor-
ophenylM
DOT (DlchlorodlphenylUlchloroeihane)
(Ethan*. l.l.l-irtdHoro-2,2-bi»(p dllaopropylth-
locartoamate)
DlbenstaJilacrldine ( 1.2.9.«-Dtbemcrtdlne>
Dlbentlajjacrtdine <1.2.7.8-Dloenzaertdine>
Dlberttta.hlanihnc*ne (1.2.9.e-Dlbenzanth-
recent)
TH-Dtbenaotc^lcartotzola (3.4.3.t-Dlbenzcar-
bazole)
Dlbenxola^lpyrene ( U2.4^-Dtbe«pyr«ne>
DtbexBtfaJUpjTwifa (U2J.«-DtbenzpyT
DtbenaoCaaipyrana U.Z7.».DlbenxpjrT*ne)
1.2-tbrnmo I eMcmimupaiia (Propane. 1.2-
1.2-D1broao*thaae (Ethyle
dtb
lde)
DlbroaanatbaiM (Metfaylene bromide)
Dt^outyl phthaUte (U-Benzenedleartox-
ylle t^il dlbutyl
U-dlchioro-)
OtehloroboMM. N.OA* (
1.4-dlehloro.)
(tl.l'-Blph«nyl1-t.4'.
)
(3-BuUM.
lore-)
DtefalorodUhMraMttuiM (U«Ui«n«, dlctt-
torodlfiuoro*)
U-DteblocMChaM (
Oleblacocthrtaa*. K.OJ.* (ZUMO*. Dtcbloroprop«M (1-:
loce>>
Dleldrm
(Amaa. dtathylo
NJ«-DtathylhydraaliM (HydnalxM. 1>
dtethyl)
O.O-OWthyt 8-m«Uiyl «at«r of pbocpboro-
dttbtoie add (Phewptoorodlthlotc add.
O.O-dtathyl 8-m«thyl wur
O.O-CM«thylpho«phortc add. O-p-nltro-
pbtnyl e«ur (Pboaphorte add. dlcthyl p-
nitnpbcnyl aatcr)
Dtathyl pbtbalaM (U-B«aMiMdieartoxyUc
add. dtethyl aaur)
O.O*Dttthyl O-J-pyrmsinyl pho«phoroth-
loat* (PhoapboroUUole add, O.Odleihyl
O-pyraxinyl tMT
DletbylftUb«at«rol .
alpha.alpti*-dlethyl. biMdlbrdroccn phoa-
phatc. (E)-)
Dlhydroulrole (Benzene. 1.2-mettoylen»-
dloiy-4-propyl-)
3.*-DUiydroxy-Hph»-
men
Dkmethoate (Phoephorodlthloic icid. O.O-
dlmethyl S-E3--2-oxoethyl)
eater
3.3'-Olmethoxybenzidtne (Cl
4.4'diaznlae. 3-3'-dtmethoxy->
P-Otmethylaaiinoacobenzene (Benaenamlne
(1.2-Ben-
N J«-dtiaeihyl-4-( pbtny laao >• »
XU-DtmathylbemUlaathracetM
aDtbraecoe. l.lJ-dUnetnyl-)
SJ-'Dtmethylbenddtae Ul.l -Blph«nylM.« •
dlamina. 3J--
1.1-Dimethylhydnztae (Hydnttne, l.i-dl-
methyl-)
U-Dimethylnydruine (HydrmUne. U-dl-
methyl-)
3.3-DUnethyM-(methylthlo)-2-buunone. O-
C(methylamlno> earbonylloxlme (Thio-
laaox)
alpha.alpha.Dlmethylphenetnyla)nine (Eth-
anamiae, l.l-dlmethyl-2-phenyl-)
2.4-Clmethylphenol (Phenol. 14-dlmethyl-)
Dlmeihyl phthalate (1.2-Benaenedlearboxy-
lie add. dimethyl eater)
Dimethyl suUat* (Sultuilc add. dimethyl
eater)
Dlnitrobensene, N.OA* (Benzene, dlnltro-.
N.OA')
4.«-Dtnttro-o
-------
3-Pluoroacetamide (Acetamlde. a-Ouoro-)
FluoroaeeUc add. sodium salt (Acetic add.
fluoro-. todlum salt)
formaldehyde 2.3-«poxy>
Haiomethane, N.O.S.*
Heptachlor (4.7-Metaaao-lH-ladene.
l,4,S.d.7.S.»-hept*chJoro-3a.4,7.ta.
tetrahydro-)
Heptachlor epoxlde (alpha. beta, and
mama Uomers) (4.7-Methano-lH-ladene.
l,4.S.6.7.8.a.heptachloro-3,3-epaxy>3a.4.7.7-
utrmhydro-. alpha, beta, and camma tsc-
men>
Hexachlorobenxene (Benaeae. hexachloro-)
Hexachlorobuudleae (1.3-Buudlene.
1. 1,2,3.4.4-hexaehJorO" >
BexacalorocyeiohexaBe (all liomcn) (Un-
dan* and Isemers)
Hexaehlorocyelopentadiene UJ-Cyelopen-
tadlens. l,J,3.4.S,$-hexachloro->
HexachJorodibensc-p-dioxins
Hexachlorodlbensofuran*
Hexaehloroethane (Ethane. 1.1.1.2,2.2-h«x-
achloro-)
1.2.3.4.10.10-Hex*chloro-1.4.4a,S.».8«-
hex»hydro-l.4-i.»-endo.endo-
dtaiethanonaptitnalen* (HexaclUorohexa-
hydro-endo.endo-dlmethanonaphthalene )
Hexachlorophen* (l2--M*thylenebU<3.4,fl-
trlehlorophenol ) )
Hexachloropropcne d-Propene. 1.1.2.3.3.3-
hexaehloro-)
Hexacthyl ictraphocphau 1.3.4*Meth-
ino-2H<7eiobutalcdlpentalen*2-one>
Liitoearpine (2-Buteaoic acid. 2-methyl-, ?•
t(2.3-dlhydroxy-2-< l-methoxyeUiyD-S-
methyl- 1 -oxobutoxy miethyU-3.3. 3.7a-
tetrahydro-lH-pyrrollx4n-l-yl etter)
Lead and compound*. N.OA*
Lead acetate (Acetic acid, lead «alt)
Lead phocphate (Phocphortc acid, lead salt)
Lead tubacetau (Lead. biKacetato-
O rtetrahydroxytrl- )
Ualtie anhydrld* (2^-rurandione) ,
Maiete hydraslde ( U-Dlhjrdro-3.»-pyrtethyl]-2-thenylamino-)
MetaoUayl (Aeetlmidic acid. N-
umeUur)c*rtj*ajorlwxy)Uilo-. methyl
ester
Methoxrchior (rthan*. l.l.l-trtchJoro-2,2--
bi« p-methoxypheay t >• )
2-Methylactridiae (1.2-Propylenimlne)
3-Metaylcholasthreae
(BeoxCJlaeeanthryleoe. l,2-dihydxo-3-
methyl-)
MaloaoalMl* (Propan*dlnitrtle)
(
Methyl chlorocarbonau (Carbonochlortdlc
add. methyl ^ter)
4.4'-Methylenei «K2-chJoroanlllne) (Benzcn-
amlne. 4.4'-methylenebU^ 2-chioro-)
Methyl ethyl ketone (MEK) (2-Butanone)
Methyl hydranne (Hydrasine. methyl.)
2-MethyUactOQJtrU« (Propanenitrtle. 3-hy-
droxy-a-methjl-)
Methyl methacrylaU (2-Propenolc »cld, 3-
methyls methyl e*t*r>
Methyl aethaneeulTonate (MethanatuUonlc
add. methyl e*ter>
2-Methyl*3-< methylthlo )proplonaldehy.>
Naphthalene
1.4-Xaphthoqutnone ci.4*Naohthalene-
dlone)
1-Naphthylamine (alpha-Naphthylamine)
2-Naphthylaolne (beta-NaphthylaaUnc)
l-Naphthyl-2-thlourea (Thlourea. 1-naphth-
aienyl-)
Nickel and compound*. N.O.S.*
Nickel carbonyl (Nickel tetracarbonyO
Nickel cyanide (Nickel (H) cyanide)
Nicotine and saiu (Pyridlne, (S)-3-(l-
methyl-2-pyrroUdlaylK and *alU)
"Ntmrrxlde (Nltroeen (II) oxide)
p-Nltroanlllne (Beiuenamine. 4-nitro-)
Nltrobenxine (Bemetxe. oitro-)
Nltrofen dioxide (Nltrocen (IV) oxide)
Nttrofta muKard and hydroehlortde salt
(Bthanamtne. 2-
N-methyl-. and hydroehlortde salt)
Nltrofftn mustard N-Oxide and hydroehlo-
rtde salt (Ithanamine. 2-ehloro-. N-(3-
ehloroethyl)-N-m«thyl-. and hydroehlo-
rtde salt!
Nitroglycerine (l.2J-Prop*netriol. trial*
true)
4-Nltropheaol (Phenol. 4-nitro-)
4-NltnxjulnoUne-l-oxide (Qulnollne. 4-nitro-
l-oxide-)
Nltroaamlae, N.O A*
N-Nltroeodi-n-butylamine (l-Butan*mine.
N-butyl-N-Bitroao-)
N-Nitrosodiethanolamta* (Zthaaol. if-
(nitroeoiaiiao )bis*)
N-Nltrosodlethylamlne (Ithanamine, N-
ethyl-N-nlfaroso.)
N'Nttraeodlmethylamlae (Dtmethylaltraaa'
mine)
N-Nltroeo-N-*thylure* (Carbamide. N-ethyl-
N-altroso>>
N'NltroaoiBMhylethylamin* (Ethanamine.
N-methyl-N-nlcroso-)
N-Nltroao-N-methylurea (Carbamide, N-
Doethy l-N-nitro§o-)
N'Nltroso-N-methylurethane (Carbamic
add. methylaitro*c-, ethyl ester)
N-NltroeomethylTUvylamlne (Xthenamine.
N-methyl-N-nltro«o-)
N-Nltro»omorphoUne (Morpholine. N-nltro-
*o>)
N-Nltrosonomlcotine (Nomicotlne. N-
oltroso-)
N-Nltrosopiperidlne (Pyridlne. hexahydro-.
N-nitroeo-)
NltrosopyrroUdine (Pyrrole, tetrahydro-. N-
nltroso*)
N-Nltrosoearcosine (Sarcostae. N-nJtraeo->
5-Nltro-o-toluldlne (Benzenamiae. 3-methyl-
5-nitro-)
OctamethylpyrophosphoraiBide (Dlphoe-
phoramlde. octamethyl-)
Osmium tetroxide (Osmium (VXH) oxide)
7-OxHjlcrcJoCX2.1] heptane-2,3-dlcartoxy lie
add (Endothal)
A-ll
-------
Paraldehyde
Ptmhion (Pho*phorothioic add. O.O-
diethyl O- ect*r
Pentachlorobensene (BenMae, peottchioro-
Ptnuehlorodlbenio-p-dlox&tt
Pentichiorodihemofuraaa
Penucnloroethane (Ethane. penttehloro-)
penuchloronitnbeozene (PCKB) (Benzene.
pentachloronltro-)
Pentachloropheool (Phenol pentachloro-)
Phenaeetln (Acetamide. N-<4-ethoxy-
phenyl)-)
Phenol (Benzene. hydroxy-)
Phenyleaediamine (Benzenedlamlne)
Phenylmercury acetate (Mercury. acetate-
phenyl-)
N-Pheayltaloum (Thlourea. phenyl-)
Photteae (Carbonyl chloride)
Phoephlne (Hydroffen phoipbld*)
pbMvboraditblote *dd. O.OdMhyl ft-
«ur
O.O-dte»«thjrl O-tp-
PbUulle Kid tsttra. N.OJL* (
AeutooxyUe Mid. «*t«x N.OA*)
Phthmlie tabydild*
3-PlcoliM (PjrldlB*. 2-m
Polyebloriaued bloh«nyU N.O-S-*
Pot4Mlum eycald*
ey«nldt
Pranurid*
propyny i )
diby-
oxld*)
a-PropyUaiiM yl>-.
draehlarldc)
J-Prepyn-1-ol (Propwsyl cleohel)
Pyrtdtm
BjMrptaq (Tohimb»n-l»oxyK m«thyl MUT>
(l.3-B«n»«n«dtoU
•fitrhirtn uid Mitt < 1,7 n*nuiliii(lil>nillii 1
on*. 1.1-dioxldc, and Mitt)
S«l«nlou» acid (Seltnium dioxide)
Selenium nilflde (Sulfur Mlenlde)
Seienoure* (CvbamiiBldoMleoole add)
Stiver «n• )
Strontium mUide
Strychnine and aiu (Stryehnldln-lO-one.
andalu)
1.2.4J>Tetr«efUorob«o»ne (Bensene.
1.2.4>MtneiUoro- )
(TCOO)
TttraenJoredibeaaefuraiM
Tttrmenlocoetbaae, N.OA* (Xthaae. t*um-
ehloro-. N.OA*)
l.;.1.2-Tetr»daloT«th»oe (Ethane. 1,1.1.2-
tetnchloro-)
l.l.J.2-Tetnchlor*tnaae (Ethane, 1.14L2-
Utrachloro-)
TetneaJoroetbaae (Hb«ne. l.U2J-utrv
crUoro-)
Tetrmehlotom«thaoe (Carton Utrachlortde)
2J.4.<.-Tetnehloropn«noi (Phenol. 24.4.A-
tetnehloro-)
TetrmethyldJthJopyropho*ph*u (Dtthioprr-
ophowhorte acid, tetrmetnyl-ecter)
Tttraethyl lead (Piumbeae, Utraethyt-)
T*trMtaylpyropho*phftU (Pyropaoaphorle
adde. utrMthyl Ǥter)
Tetrultromethmae (Methane, t*tnaitro>>
Thallium and compound*. M.OA*
Thalllc oxide (ThalUum (III) oxide)
Thallium (I) aeeuu (Acetic add. thallium
(I) nit)
Thallium (I) carbonate (Carbonic add. dlth-
alllura (I) talt>
Thallium (I) chloride
Thallium (I) nitrate (Nitric add. thallium
(I) «alt)
Thallium atlenlte
Thallium (I)
Thloacetamide fyth>rt*Thlffarnl/tf'
ThlOMmicarbazide (Hydracinecarbothlo*-
midt)
Thlourea (Carbamide thlo-)
Thiuna (BWdlmethyltbiocarbamoyl) dl-
lulflde)
Toluene (Bemene, methyl*)
Tolueaedlamrae (Dlaminotoluene)
o-Toluldtne hydrochlortde (Bensmamine. 3-
methyl-. hydroehlortde)
Tolylene dilaocyanau (Bensene. IJ-dilao-
cyanatomethy I*)
Toxaonene «>^ph*T^. octaehlora-)
TnbromomethaM (Bromolorm)
1.2,VTrichlorobenxtne (Benwne. 1^.4-uieh-
loro-)
1.1.1-Triehloroethane (Methyl chloroform)
l.U-Trtchloroethane (Ethane. l.U-tnch-
IOTO-)
Trtehloroethene cmchloroethylene)
Tnchloromethanetniol (MethanethioL
trtchloroo
TricaloromonoOuoromethane (Methane.
trtehloronuoro-)
2.4J-Trtehlop>phenol (Phenol. XO-trleh-
loro»)
ii,«-Trtchlorot>henol (Phenol. 2.4.«-trieh-
loro-)
2.4.5-TnchlorophenoxyaeeUe add (2.4.J-T)
(Acetic add. 2,4.5-ulchlorophenoxy->
2.4.ft-Tnchloropri«noxypropionic add (2.4.5-
TP) (SUvex) (Propionoic add. 24 2.4.3-
trtehlorophenoxy >- >
Trtchloropropane. N.O.3.* (Propane, trtch-
lore-. N.OA*)
1,2.3-Trtchloropropane (Propane. 1.2,3-irlch-
lore-)
O.O.O-Trtethyl pho*phorotnlo*te (Pho»-
phorathioie add. O.O.O-tnethyl ester)
aym-Trtnitrobertxene (Benzene, 1.3.3-ulru-
tro-)
TMttl-azrtdtnyl) photphine tuUldc (pno*-
phlne sulTlde. tri«l-aciridlnyl-)
True 13-41 bromopropyi) phoephate U-Pro-
panoL 13-dlbromo-. phoepnatet
Trypan blue (2.7-NaphtnalenedUul/onic
add. J.3'-t(3.3-dlm«thyUl.l-blphenylv-
4.4>-diyl>bif(aio))bi«(S-amlno-4-hydroxy-.
tetnaodlum talt)
Uradl muturd (Urmdl V(bls(3-
chloroethyDaminol-)
Vanadic agtd. •jrtrfi**M*"f^ salt (ammonium
vmnadate)
Vanadium pentoxide (Vanadium (V) oxide)
Vinyl chloride (Ethene. ehloro-)
Zinc cyanide
Zinc phoephide
A-12
-------
APPENDIX A-3
40 CFR PART 261, APPENDIX VII
BASIS FOR LISTING HAZARDOUS WASTES
A-13
-------
Arrareoc Vtl—B*«« torn Lavma
HAZAIOOOS WASTE
f*4
Ctnyw (MEMOfMM. i.l.i tnrfnujroafliyn
mciWMMh**. i«r*r*yo«tfw>M
A-14
-------
3U*
MM*
SO
Miuroou* conuiu«nn tor onen MIM
A-15
-------
APPENDIX B
EXAMPLE POTV SEJffiR USE ORDINANCE LANGUAGE
-------
POTVs may wish to consider the folloving 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 POTV: (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 Sever Use Ordinance Language tor 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 sever 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 the 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 Dischargedtoa POTV by Trucfc, Rail, or Dedicated Pipeline
"Haulers of septic wastes removed from residential customers are subject
to the terras 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
-------
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 wastes (i.e.. septic wastes, cesspool waste, portable
toilet waste) removed from residential, commercial, and industrial customers
are subject to the terns and conditions for discharge as contained in Section
of this ordinance. Waste haulers must discharge hauled vastes 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 sever systes will constitute a violation of this ordinance, and
will subject the hauler to the penalties provided for in Section of this
ordinance."
4. Example Sewer Use Ordinance Language for Prohibiting Hazardous Vastes
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 headworks of the plant
by truck or rail is also prohibited.
5. Example Sewer User Ordinance Language for Requiring a Permit to Discharge
Hauled Vastes
"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 sever system without a permit will be subject to the penalties provided
for in Section of this ordinance."
B-2
-------
APPENDIX C
EXAMPLE WASTE HAULER PERMIT
-------
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 (POTV) ,
located at POTV Address And, in compliance with the provisions
of the Federal Vater 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 POTV waste tracking form to record every
load that is pumped and delivered to the POTV. 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 S per offense.
POTV Authorization for Hauling Industrial Vaste
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 POTV. POTV
C-l
-------
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 POTV
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 POTV
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 pretreatfflent
standards must meet the applicable Federal categorical standards. The gen-
erator must provide proof to the POTV of such compliance, and the POTV 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)J;
* 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 POTV influent to exceed 104'F
C-2
-------
• Any other type of waste that may not be treatable by the POTV, or will
interfere with the operation of the POTV (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
Marrnry 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
-------
be provided to the POTV. Nothing herein shall in any manner preclude the
permittee from obtaining such additional insurance coverage as nay be deemed
necessary for his or her own protection.
Notification of Change
The permittee must notify the Administrator of any new introductions or
contributions or any substantial change in pollutants being discharged. Such
notification must include the source of the waste, identification of the vaste
being discharged, the nature and concentration of pollutants in the discharge,
time, date, and cause of the change.
Nontransferabili ty
In the event of any change in control or ownership, the permittee shall
notify the POTV. 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 POTV contrary
to the provisions of this permit, Federal or State pretreatment requirements,
or contrary to any order of the City or [POTV Name], the City or [POTV name]
may commence an action in a court of record for appropriate legal and equi-
table relief. In such action, the City or [POTV name] may recover from the
C-A
-------
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 [POTV name]
prevails in the action or settles at the request of the defendant. Any person
vho violates any of the provisions of this permit shall become liable to the
City or [POTV name] for any expense, loss, damages to the City, or to the POTV
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
-------
Permit Revocation
Revocation vill be determined at the discretion of the program
Administrator.
Signed by:
Authorized POTV Representative:
Permittee:
C-6
-------
APPENDIX D
EXAMPLE WASTE TRACKING FORM
-------
EXAMPLE WASTE TRACKING FORM
Time
Date
WASTE HAULER INFORMATION
Company Name Hauler I.D.I or Permit i_
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 vaste been sampled? Yes No
If yes, attach results.
If no, list suspected vaste constituents?
Is the vaste a RCRA hazardous vaste according to the criteria listed in 40
CFR 261?
Have additives been mixed vith vaste (e.g., solvents, enzymes, etc.)?
If yes, please list.
Total quantity hauled from source ______________________________
Time vaste vas pumped? Date
D-l
-------
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 vaste constituents?
Is the vaste a RCRA hazardous vaste according to the criteria listed in 40
CFR 261? ._=_-
Have additives been mixed vith vaste (e.g., solvents, enzymes, etc.)?
If yes, please list.
Total quantity hauled from source gal.
Time vaste vas pumped? Date
3) Name of Company/Residence .
Name of Ovner/Contact
Address
Telephone Number
Type of Establishment (e.g., Home, Restaurant, Industry)
If industry, list applicable SIC code(s)
Has vaste been sampled? Yes No
If yes, attach results.
If no, list suspected vaste constituents?
Is the vaste a RCRA hazardous vaste according to the criteria listed in 40
CFR 261?
Have additives been mixed vith vaste (e.g., solvents, enzymes, etc.)?
If yes, please list.
D-2
-------
Total quantity hauled from source gal.
Time waste vas pumped? Date
I hereby certify that the information listed above is true and accurate.
(Waste Hauler)
Verified by: (POTV Operator)
D-3
-------
APFENDIZ E
PERMIT BT RULE REQUIREMENTS EXPANDED TO INCLUDE
SECTIONS INCORPORATED BT REFERENCE
-------
9 270.60 Permit* by ml*.
Notwithstanding my other provision
o( this part or Part 124. the following
shall be deemed to have a RCRA
permit if the conditions listed are met:
(O Publicly owned treatment works.
The owner or operator of a POTW
which accepts for treatment hazard-
ous waste, if the owner or operator
(I) Has an NFDES permit;
(2) Compiles with the condition* wi
that permit: and
(3) Complies with the following reg-
ulations:
-<5> amended by 45 FR
IM73, December 31. 1980)
(1) Sign and date each copy of the
manifest or shipping paper (if the
manifest hss not been received) to
certify that the hazardous waste
covered by
-------
(lit) 40 CFR 264.72. Manifest discrep-
ancies
f tt*v4s>*^fi
(a) Manifest discrepancies art
differences between tha quantity or typa
of hasardoua wasta designated on tha
manifest or shipping papar. and tha
quantity or typa of hazardous wasta a
facility actually racaivas. Significant
diacnpaneiaa in quantity ara: (1) For
bulk waste, variations greater than 10
percent in weight and (2) for batch
waste, any variation in piece count such
aa a discrapancy of one drum In a
truckload. Significant discrepancies in
type ara obvioue differences which can
be discovered by inspection or wasta
analysis, such aa wasta solvent
substituted for wasta acid, or toxic
constituents net reported on tha
manifest or shipping papar.
(b) Upon discovering a significant
discrepancy, tha owner or operator must
attempt to reconcile the discrepancy
with tha waata generator or transporter
(e.g~ with telephone conversations). If
tha discrepancy is not resolved within
IS days after receiving tha waste, tha
owner or operator must immediately
submit to tha Regional Administrator a
letterdeaeribing tha discrepancy and
attempt* to reconcile it and a copy of
the manifest or shipping papar at issue.
and (b)(l). Op.
ermtinc record:
ftsM.73 Ofeteone. record.
(a) The owner or operator must keep a
written operating record at his facility.
(b) The following information must be
recorded, aa it becomes available, and
maintained in the nptr*^ng record until
closure of the facility:
(1) A description and the quantity of
each hazardoua wasta received, and the
methods) aad date(s) of its treatment
storage, or disposal at the facility aa
required by Appendix b
Appendix L— Recordkeepuig Instructioae
The recordkeeping provisions of | 254.73
specify that «n owner or operator must keep
• written operating record tt his facility. Thi«
appendix provide* additional instruction* for
keeping port/on* of (he operating record. S«*
f M4.73(bl for additional recordkaeping
requirement*.
The following information must be
recorded, a* it becomes available, and
maintained in the operating record until
closure of the facility in Die following
manner
Records of etch hasardou* wa*t* received.
treated, stored, or disposed of at the facility
which include the following:
(1) A description by its common name and
the EPA Hazardous Watte Numbers) from
Part 261 of this Chapter which apply to the
waste. The waste description also must
include the waste's physical form. i.e.. liquid.
tludge. *olid or contained ga*. If the waste la
not listed in Part 261. Subpari 0. of this
Chapter, the description also must include the
pfocese last produced it (for example, solid
Alter cake from production of ^—, EPA
Hazardous Waate Number WMU.
Each hasardoua waste liated in Part 2ai.
Subpart 0. of this Chapter, aad each
hasardoua waale characteristic defined la
Part m. Subpart C of this Chapter, has e
four-digit EPA Hazardous Waste Number
assigned to it This number must be used for
recardkeepiftf aad reporting purpose*. Where
a haaardoiu waste contain* more than one
liated hasardou* waata. or where more than
one hasardou* waste characteristic appliec to
the waste, the waste description must Include
all applicable EPA Hazardous Wasta
Numbers.
(2) The estimated or manifest-reported
weight or volume and density, where
applicable, in one of (he units of measure
specified in Table t:
0) The meihod(s) (by handling code<*) sa
specified ia Table 2) and dateis) of treatment
storage, or disposal
S"o»t rant iZOOO *MJ .
— C
C
•'0
Tnr
u/C
E-2
-------
Table 1— Handlist Code* for T(MlnMaU
Staref*. and DlipoeaJ Methode
Enttr UM handling codetsi listed below
that matt ctoeely represents UM techniques)
us«4 at tne facility to treat, star*, or dispose
of each quantity o< hazardous waste received.
1. Storage
SOt Container barrel, drum. etc. i
S02 Tank
S03 Waste pue
S04 Surface impoundment
SOS Otber i specify)
2. Treatment
. tai Thermal Treatment
TN Liquid injection incinerator
TOT Rotary lula incinerator
TO*. Fluidized bed incinerator
TO* Multiple hearth incinerator
T10 Infrared furnace incinerator
Til Molten salt destructor
T1S Pyrolyiw
T13 Wet Air oxidation
TU Calctnatiofl
T1S Microwave discharge
Tt« Ciaiert tola
TV tune kila
TiM Otter (apecarf)
(b| QMtmcal TrMO&ewt
Tt» Abscrotic* monad
T20 Abeorpooc Qoid
Ta Cba«i>f •! &xauon
T2S rh«»if tl Jrij*f *•"-
TZ3 ChegmraJ preoawtatioa
-r!4 Cheaue
T23
T28
T27
TJ»
T!T EvuportHon
T58 High gradient mtjnrde *ep«retioa
T59 Uechinf
T60 Uquid ion txchanfe
TV! Liquid-liquid ixtractton
T62 Reverse oimom
T63 Solvent recovtry
TS4 Sutopuif
TU Sand Alter
TM Other I specify)
Id) Biological Trvatment
T87 Activated iludfe
T6B Aerooic IMOOH
T89 Aeroaic taflfc
TTO Anaerobic l&foon
T7| Compoatinf
T72 Septic taflM
T73 Spray imcaiion
TT4 Thieitenm« fitter
T7$ Tnckin» filter
TTS Waate stabiliaaiion pond
TTT Other < specify >
Tta-f» (Reserved I
3. DUpoaaJ
D80 Undertraund injection
D«i LandflU
O»2 Land tremunent
O<3 Ocemn dUooaaJ
DM Surface impoundment (to be cloaed
aa a landfill)
oas
T30
T31 Nentreliiitmn
TS2 Oioaat}e«
TU ntotoiytia
T34
(c) Riyncil Treetmeni
(1) S*pex*tioa ol component*
T3S OatnhiMtioe)
TM CUhflcanoa
T37 CoafuiatMei
T3A Oecantint
T» EncapmUuoo
TM rUirauoo
T4t Flocculatioa
T42 RoitUoo
T*3 Foaminf
T44 S*din»ef>utte«
T45 Thicketung
T<« UttraAlncion
T4f Other (epeeifyi
(21 Renwvai of Specific Component!
T44 Ab*orDOott-moi«cal«r tnv«
T«* Acn«e««d carbon
T30 BUndiaf
TS1 Caiaiytu
TU Cryttaiiisafloe,
TU Ditlym
T54 Ottuiiatioa
T53 Qectrodieiysis
T54 Qectrolyni
(vi 40 CFR 264.tS. Biennial report.
« 2M.7S Btormtel retwet.
Trie owner or operator must prepare
and submit a single copy of a biennial
report to the Retional . 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:
[164.75 amended by 48 FR 3981, January
<*> The EPA identification number.
name, and addresa 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:
-------
»e> The method of treatment, stor-
age, or disposal {or each hazardous
waste:
The certification signed by the
owner or operator of the facility or his
authorized representative.
(vi) 40 CFR 2*4.76, Unmanifesi
waste report: and
I M4.7C UMM*lfe*C*4
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 |203.20 The EPA identification number.
name, and address of the generator
and the transporter, if available:
(d) A description and the quantity of
each unmantfested 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 faculty or his
authorized representative: and
(f ) A brief expjuiation of why the
wast* was unmanifested. if known.
(Comment Small quantities of hazardous
waste are excluded from regulation under
this Part and do not require t manifest.
Where a facility receive* unmanifeiied haz-
ardous wastes. the Af ency succesu that the
owner or op«rmtor oDtain (ram each tenerm-
tor a certification that the waste qualifies
for exclusion. Otherwise, the Agency sue-
tests that the owner or operator (lie an un-
manifested watte report for the hazardous
waste tnovem*nt.l
[vii) for NPDES permits issued after
November t, 1964. 40 CFR 284401.
$264.101 Corrtctitt action for soiM waste
units.
[264.101 added by 50 FR 28742. July 15
1985J
(a) The owner or operator of a facility
seeking s permit for the treatment, storage
or disposal of hazardous waste mu« insu-
tute corrective action as necessary to pro-
tect human health and the environment
for all releases of hazardous waste or con-
stituents from any solid waste manage-
ment unit at the facility, refardlest of the
time at which waste was placed in suvh
unit.
(bl Corrective action will be specified m
the permit. The permit will contain sched-
ules of comDliancc for such corrective ac-
tion (where such corrective action cannot
be completed prior to issuance of the per-
mit) and assurance* of financial responsi-
bility for completing such corrective
action.
'4> If the v.aste meets all Federal.
State, and local pretreatment require-
ments which *ould be applicable to
the waste if it were being discharged
mio the POTW through a sewer, pipe.
or similar conveyance.
E-4
-------
APPENDIX P
FORMS
-------
APPENDIX F-l
NOTIFICATION OF HAZARDOUS WASTE ACTIVITY
FORM 8700-12)
F-l
-------
OC
i&EPA Notification of Hazardous Waste Activity
;« * •*•.* «a c» -* s
JO'O 0' ».» «*)3u'C» Cj-ik-
IV. Installation Contic
VI. Typo of Rtmulatad V¥a«t» Activity (Mart 'X' in tht tppropntt* bo*»s. Rtftr to instruction.
•. Uw«
O '
U I. Tr»rnon
VII.
„.-,.-}: Typo of Combustion Dovic*r««w*r - -._... ..—. ——.—__..,„ ....
» fe* «r »H-10*tit*toon ut*4 on futl it tutn+a. $4* *ttttueli9ttt tor mttmtmt* ft eomtumon «*«
O A. UtiMy ioiior Q • i«duMn«i toitof U C
VIII. Mod* of Transportation Itrtnspontrt inly — tm*r 'X' in tht iporapriat*
D A A* O I "••) G C
Q 0 WMW Q C
IX. first Of Subs«qu«m Notification
M«ft 'X' in tn« «ep'oe'>M« 001 to incitm Cl
F-2
-------
MUTCM your mtuii««ioff n*««N**
k. fflt*f IK« few-01911 nuflWw from 40 Cf* **n 26! 12 to* ttt" i>*i*0 "Mtrao^t *•«* I
UM MMtnionM (Artu rf *KMMTV
13
If
II
I»
21
J7
tt
21
23
24
WlMll If** m« toxfm/tTf
-------
APPENDIX P-2
OHIPORH HAZARDOUS WASTI MANIFEST
(SPA PORK 8700-22)
P-4
-------
rt*i*«iirimor tvea if arm diugnfd for ui» on »lit»H2-iMct>ltYPfwriifri
f
i
a
i
N
e
*
A
T
0
ft
•
i
T
*
A
N
S
f
O
M
T
I
ft
f
jk
c
1
L
1
T
y
UNIFORM HAZARDOUS i. <.•"»•»•• us EPA UNO. oJ*"1*"'
WASTE MANIFEST i i i i f^T1""-
1 Generator s Phone 1 )
i i 1 I;
ill1 1 i
1 i 1 1
1 1 . US DOT Description Hnctuding Proper Stuffing Ntmt. Mutt* Cltts. tn4 ID Humour!
No.
a.
b.
c.
I
d.
^orm Aot>roi»a. OMB No. 2QOO-O4O4 Stoirtt 7 31
^ is not reauired by Federal
fc
8. State Generator a ID
C. State Transporter • 10
0. Transporter's Phone
E. State Transporter s 10
f. Transporter s Phone)
G. State Facility a 10
H. Feciiitya Phone
liners 13- 1*. I
Total Unit t-
Type Quantity VWVoi Wmaj Max
I
15. Special Handling Instructions and Additional Information
' 8 GENERATOR'S CERTIFICATION: 1 hereCy declare inn m« ctmtcnts of thit con*iqnm«nt ar« fully am) »ccur»t»lv 0**criO*a aDov* Ov
proow vutxxng rum* *nd ir« etM«i4i«d. pMUO. mvrkad. and UriMMd. and ar* m all rno«cti in prop*? condition for transport cry n^hway
Unl«M 1 am a small quamirv g*n«mor wno his b*»n •i»mtrt»d bv tutun or rtgulation from th« duty to makt a want minimization cxtificatior
under Sactmn 3O02(bl of RCRA. 1 also eartity mat 1 hav« a program m placa 10 reduce th* volume and toxieitv of waste generated to the degree
have uetermmed to be) economically praeticiBle and 1 have selected the method of treatment, storage, or disposal currently available to me wnicr
minimizes tne preeant and future tnreat to rujman health and the envtronment.
Prtmed/Typad Name ' Signature Month 0*r ''•
' 1 1 1 ! 1
1 7 Trartsoorter I ActnowKdoemem at Recawt of Matemalt
Pnnted/TypeKI Name Signature Mont/i Oar •'•
1 1 1 * !
1 S.Tranaponer 2 Acknowtedgemant of Recawf of MatenaU
Pnmed/Typed Name Signature Month Dty f-
1 1 1 ' 1
1 S.Oiscreoancv Indication Space
20. Facility Owner or Operator Certification of receipt of hazardous materials covered by this manifest e«ceot as noted in Item 19
Primed/Typed Name Signature Month, Oty Y
1 1 1 ' I
EPA Form 870O-22 (Rev. 4-H) Previous edition is obsolete.
F-5
-------
APPENDIX F-3
BIENNIAL HAZARDOUS WASTE REPOR'
(EPA FORM 8700-13B)
F-6
-------
\m shaded arm o*5«.
ENVIRONMENTAL PROTECTION AGENCY
FACILITY BIENNIAL HAZARDOUS WASTE REPORT FOR 1983
This report is for the calendar year ending December 31, 1981
Read All Instructions Carefully Before Making Any Entries on Form
12-31-U
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 G
Explain your non-regulated status in the space below.
• printrfyp* with etft* type (12 characters per inch)
II. FACILITY EPA I.D. NUMBER
T.A C
i jF'i i i .!!'!' •I|'. i i "I i
1 2
13 1415
III. NAME OF FACILITY
This Facility'i Son-fief ulat«d Status it Expected to Apply:
D For 1983 Only G Permanently
a Other (explain
in comment Mctlon)
O03 ENTRY (OFFlOAt USE ONLY): Q
IV. FACILITY MAILING ADDRESS
131 ' • i J __
15 16
Street or P.O. Box
'5 16
City or Town
45
State Zip Code
V. LOCATION OF FACILITY (if different than section IV above)
15 16
1
Street or Route number
15 16
City or Town
41 4^ 47
Stale Zip Code
VI. FACILITY CONTACT
15 16
Name (last and first)
46
Phone No. larea code & no.)
VII. COST ESTIMATES FOR FACILITIES
16 19
A. Cast Estimate for Facility Closure 3. Cost Estimate for Poit Qcsure Monitoring
and Maintenance (disposal facilities only)
VII I. CERTIFICATION
I ce«ilv ufldM peruitv or law thu I Kjv«
docyirwnii. 4nd Ihil tuwd on mv inquiry o« iho>«r
i mtornvuion rt true, accurate, and
ng tH« pOMjbtiicv o( rtn* ^nd
*nd *m rjmilur wnf th« miormjtion iub"»med m thu j
imm«ji,nel» res»n«bl« «x obMininn rh« miotmtiion t
jf* ttui 'f»nf Jnr M«ni«cjm ptm^ltwii tor >ubmining ulte
EPA Form S700»13»(5-M) (
Tide
11-U)
Signature 01 Authorized
P-7
Date
Page ' of —
-------
APPENDIX G
STATE HAZARDOUS WASTE CONTACTS
-------
Alphabetized State Listing Of Hazardous Waste Contacts
Alabama
L»n8 Division
Alabama Department of Environmental Management
State Cao'toi
Montgomery AL 3ft 130
i205i 271 -7730
Alaska
£PA Region X
Waste Management Sranen
MS- 530
1200 S'«tn Avenue
Seattle. WA 98101
(206> 442-2777
American S«MMM
f» OenHf Intor motion Of form* Contact
American Samoa Government
Deoanmem of PgW* Works
Ptoo Pago. American Samoa 96799
(Commercial Call 633-41161
*»•*/ Your Comototod form* To
U S EPA Region IX
TO»ICI and Watt* Management Division
215 Fremont Sir««i
San Francicco. C* 94105
Anxon*
rp O6l»«n Information of formt Contact
Antona 0«o*t'1''««« °' M«ait« S«rvtca«
200S N C*mr»i, Soo»« 301
Pho«n.ii. A2 S5OOS
(«02) 257-0022
Mtul Youf CoavittoO form* To.
U S EPA Maqiofl |X
To*ic* ana Wan* M
215 frtmont St'Mt
San Francicco. CA 94105
Commonwealth of Monti Mariana islands
fs Ooitin irtlotmtiian or fof"S Conner
ot Puoue M«aun »n<3 gnwcro
Strv.cts
Arkansas 0«oanm«ni o* Pollution Control
Solid and Hatardous Matar >aif
P 0 Bos 9583
uni« *»oen. A« 72219
iSOD 562-7*44
To Qbt»in trtlormmort or form* Conttct
California 0«o*t"'»nt of
Tome SuDttanca* Control Oi*i»>on
71* P St'tn
Saeramtnto. CA 95814
(916)324-1781
Mtil four ComptftOfi formt To.
U S EPA P.»g«xi IX
Toxics and Watt* Mana?**"**!
215 Frafnom Str««t
San Francisco. CA 94105
Coto»ado 0«e«ftm«ni of Haann
Ws«t« Man«9«m«n
4210 E 11inAo*n
Mul Your Comc/tttft form$ To
U S EPA Region IX
Tones 1"0 W«$t« Man*9*mt^l O'v.i.or
2 1 5 F'tmo^i Si' t«t
San f'lncnco CA 941 OS
Connecticut
Connecticut Otoartment of Environmental P'oted'On
Hijjfaoui Materials Managerieni unn
State Office Suitainq
1 65 Caouoi Ave
Marrtofd, CT06106
(203)566-5712
Delaware Oeosnmeni of Natural Hesourcet »«<3 £nv
-------
To OttWi Intormotiori or formt Contact-
Hawaii 0*o«nm*nt o« Haoitn
EnwronmomM Protocwon and Hoartft S*oneM Otviw«n
Noiao-and MMMtien
PO Bo. 3378
Honolulu. HI 9M01
(SOfll 4M-307S
US EPAHogiortlX
Touca and WMM Management Onna«on
21 S *re««ont Slfeot
San Franciaco. CA94105
EPA Region X
Weete Management
MS S30
<2M> 442-2777
t*A tf f
Illinois Environ
lection Agent
Control
. IL S270C
(217)7«2-«7«1
NCAA
US. EPA Noawn V
P 0. lei A3M7
OMC^O. It 6Oe«0
US EPAM«oionV
WftCtC M49f^99fTMft
^ 0. IOB A3M7
I312)8M-«14«
U.S EPA Motion VII
726 Mi
IUnM«Citv. KSM101
(8 16) 374-6534
OoDOftmont o< ^ooftn ono tflvif oomont
Bur*«u at W««t« M«n*o*fnom
. Sldg. 321
KS M620
(*13)M2-93«0
Komnaky
Ot«i«ion at WMM M*n*»»mont
Komucky OoooAiviont *o/
toono Plus. •ui>»09 No. 2
Ff •nkfon. KV 40W1
1902) M4-«71«
Qu«lity
PO Bo. 94X7
ftmon Rou««. UA 7O*O«
(SO4I342-1227
'" r*u
/i«r*tf or t**r»cifr>*tic wttlt in
M».n« DoMnmoni of Envtronmomai Prenoetion
Sur««u of Oil *n4 H«uroous M«l»ri«li Contrw
Oivmon of Lictnting «rvd Enforcomont
S(*t« HOUM— Sidion 1 7
(207)289-2691
M«ryi«nd 0«o*rtm«nt of H««!tn and M«ot«l
Watt* M»n»g«m«rn Aqminmrinon
201 WMI Pr«tton St..
8«Himor«. MO 21201
(301)383-9740
On* Wimor
tenon. MA 021 01
(•17U92-8W1
of Envirefim«fli«i Quality
P.CKA Acnvnios
U.S. EPA Mown V
WMW M«n*a*mont
PO. lo>A3S«7
Chicago. IL 6O«tO
(312)M6-614t
To Ootawt Informtoon or forms Contact'
Minnoaou Pollution conver Aoancy
Solid and Huardoua Watt* Omaion
It3» Woat County Nd.. B-2
. MNM113
(61 2) 297-1 779
M«W Yottr Cv*f*to4 form* To:
U S EPA flogion V
Wasto Manaoomom Omaion
P 0 .to* A3M7
Cn««oe. IL 60990
Omaton o« Solid and Haurdoua Watt* Man«q«m«nt
MiMttaiooi Ooponmom »f Natural MMOUTCM
PO Boa 10389
Jaoiaon. MS 39209
1601)981-9078
MlMoun
MiMourt 0«o«nm«nt ol Natural H*»ourcM
W«»i« Manea«m*nt Proorvm
P 0 8o« 1368
J«rl«rson City. MO 65102
(314) 751-3241
Montana 0«c«nm*ni o« H*»tth and Environmental Sci«nc«t
Solid and Haiardous W«*t» Bureau
Coquoaii Building. P.oom 8201
Holona. MT 99620
1404) 444.2821
Nooraaka Oooartmont o< Emnronmontal Control
Mauroout W«M« Managomont Socsion
PO Bo* 94877
Lincoln. NE 68909
(402)471-2186
EPA Pom 87OO-12 (Mow. 6-B6)
G-2
-------
To Otftwi Inform*** Of tan** Contact
Navada Oaoarwant at Cenaorvetion and Natural Nasourcaa
Oiviaion of Invtrenmawai Protection
Cawtoi Camoia*
Caraon City. NV 11701
(702) 111-4870
Mori Your Con***** formt r*
U.S. If A Nation IX
Tones and Win* Manatamam Division
215 Frsmont Siraat
San FrsnciSCO. CA »410S
Naw Hamgantra Oaoartmant of Haaltn and Waifara
Off tea of Wssta Manatomam
Haa«n and Watfara
Hacon Ortva
Concord. NM 033O1
1803) 271 -MOt
Division of Waata Manatamam
»Advise* ~—-
or formt Cotnoct
of Cmnrenmcntal
32 £ M*now«r Straw
PQ. %m CN021
Trarnon. NJ OM25
ItOt) 292-«341
formt To.
U.S IM Nation N
Air and Waata Manaoamam OMnon
NawYort. NY 10271
HataroouaWa
imorooamam Division
PO. •«• Ml
Santa N.
(90t) M«*0020 bet. 340
NawYor*
To Ottotft Information or formt Corxoct
Haw York Daoanmarn of Invwonmamal Conaarvatien
Otvtawn o< Solid and Haxaraowa vVaan
Manrfaat Saetion
SO Wort ftd.. Room 20f
Albany, NY 12233-0001
(51«)*87-0430
Moti Your ComtHotof formt To:
U.S. IPA Na«i«n II
Air and Waata Manaf amant Division
2* Faoafsi Plata
Y 1027t
SotM and Naaardau* Waata Manaaamant traneft
in»»ron mental Hoatw S action
Oaeanmaw of Human Naaowreaa
Owiaion of Hoaitn Sarvwaa
3O« Norm Wilmington Straot
PO i«i20t1
. NC 27802-20t1
(t1») 713-21 7t
NortfiOalMta
Norm Dakota Daeartmont o< H«aitn
Oiviaion of Hasareous Waata
Manaoamam snd Spocvai Studiaa
1 200 Misaouri Ava.. Moom M2
tiamartk. NO MM1
(701I224-23M
QMS)
MCiA Acttvtttaa
US iPAMavioaV
Waaia Manag amant Oiviaion
P 0 lo« A3587
Chicaoo. it. OOfltO
Oklahoma
US CPAHa«ionVl
Air snd Maiardous Matanaia Division
1201 ElmStraat
Intar-Firtt Two Suilding
Oanaa. TX 75270
(2U)787-»M5
IPA. Naoion x
Waata Managamam Irancn
MS 130
1200Si0nAvanuo
Saatt)a.WAM101
I20«l 442-2777
for tntormotton On Stoto AoiutromofH*:
Oraoan Oaoanmam of f nvironmanul QuaiHv
Haiaroeua and Solid Waata Manaaamant Onnaion
PO SOB 1760
Portland. OH t7207
(S03)22»-«913
U.S. IPA Notion IN
Wssta Manaoamam Branefi
MS3HW34
Ml Cmwtnut Straw
. PA 11107
(21515I7.73M
To Obtom Irttormotiort Or fount Comott
Imnronmamai Quality
Una Pollution Control Aroo
PO. BOB 11 AM
Samureo. PN 00010-14M
(•09) 722-043*
Marf Your Comgiotoo' formt To:
U.S. IPA Nation H
Air and Waata Manatamant Oivia»on
21 Padarai Plan
NawVonu NY 10271
Nhoda Island
P-noda island Oaoartmant of Invironmamai Manaeamant
Oiviaion of Air and Hasardaua Matanaia
204 Cannon lid*
75 Davis Straat
Providanca. Ni 02tOt
(401) 277-2717
M
•uraau of Solid and Hacaraoua Wa
.... lanatomam
Soutn Carolina Oapartmant of Moaitn and Inviranmantal Control
2800 lull Straat
CotuiMM. SC 21201
(103) 758-IM1
loutti Dakota
Soutn Dakota Daoanmant of Watar and Natural Mao ureas
Offtea of Air Quality and Solid Waata
Jo* Foaa lutMina
Piorra. SO 57501
(60S) 773-3321
D
Tannssiaa Oapanmant of Hoaltn and Inwranmant
Customs Houaa, 4m Ploar
701 Broadway
Naanvtua. TN 37201
(11II 741.3424, 2177, 3111
IPA Parm 870O.12 ll-ll)
G-3
-------
1 100 W«« 49tn SirMt T
. TX 717M
UM«
-602
C«0>1l*
TX ?tt1 1
AMif. NMM 4231
U.
for*. MY t037t
i QV wVV9*^Vf vYTlNK
, VA »21»
U.S CM A«fMfl X
W«tt %Mn»nm>o
MS 930
IttOSntftAvtnv*
SMflM. WAM101
(2M) 443-2777
leotegy
WA HI04
U01
M«uf •!
^ 0
Wl M707
ttrmtt*
U.S. IM M«9*on V
«700*1X
60701
G-4
------- |